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HomeMy WebLinkAbout08-4279GOLDBECK Mc - Y & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 W W W.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff VS. MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Mortgagors and Real Owners 207 Eleventh Street New Cumberland, PA 17070 Defendants 68 - Jar l?tUa?? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. CIVIL AC77ON. 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIQ_Q JE USTED RESPONDA DENTRO- DE 20 DIAS DESPUES DE SER SERVu?*T rS - NECESSARIO QUE USTED, O SU ABOGADO, REG S RE CON LA ORITE EN FORMA EESCR ???S PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA TTA, EL 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 THIS FIRM IS A DEBT COLLECTOR AND WE ARE An '21E MG TO COLLECT A DEBT OW-ED TO OUR CLIENT, ANY IN?RMATION OBT INED EROM You WILL BE USED FOR THE PURPOSE OF COLLECTING 1TIE 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. 0. 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://wv??w.nhfa.org/consumers/homeowners/real asnx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretenti ffl@% ldbecklaw 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 67748FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. z. -_ - - tt to atn? ' -- COMPLAINT IN MORTG - CLOSURE 1. Plaintiff is DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7, 7105 Corporate Drive, PTX C-35 Plano, TX 75024. 2. The names and addresses of the Defendants are MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY, 207 11th Street, New Cumberland, PA 17070 and SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY, 207 11th Street, New Cumberland, PA 17070, who are the mortgagors and real owners of the mortgaged premises hereinafter described. 3. On June 09, 2006 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTINGSOLELY AS A NOMINEE FOR DECISION ONE MORTGAGE COMPANY, LLC, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1954, Page 4366. The mortgage has been assigned to: DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 by assignment of Mortgage June 30, 2008 as Instrument # 200822039. 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 October 09, 2007 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ....................... ...........$111,512.28 Interest from 09/09/2007 through 06/02/2008 at 8.9200% ....................... $7,303.00 Per Diem interest rate at $27.25 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$5,575.61 Late Charges from 10/09/2007 to 06/02/2008 .............................................$404.45 Monthly late charge amount at $44.94 Costs of suit and Title Search ......................................................................$900.00 $125,695.34 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is nn*?_ dgment of personal liability (or an m pers " ' __ent) 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 $125,695.34, together with interest at the rate of $27.25, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff s Sale of the Property. By: GOLDBECK McCAFFERTY & M4 BY: MICHAEL T. MCKEEVER., ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION 1, KERISELMAN,ASSISTANTVICE PRESIDENT , 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 the penalties of 18 Pa. C.S. 4904 relating to unswom falsification to authorities. Date: d 040 v d I SELMAN, ASSISTANT VICE PRESIDENT 207 Eleventh Street New Cumberland, PA 17070 - MARK A. MCCONNAUGHEY aWa MARK MCCONNAUGHEY and SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY E.xhifiitA Apr 30 2008 7:54RM HP LRSERJET 3330 P.22 A THAT CERTAIN piaca a ? ads foMoMra. b wit• pLS. of )and atlwta in am-d yyard of to of New am"On SapMrnber 1pp0 afld ded1 Dead In pab Survey 13, BEGINNING at • amrt an vo on"" "arthm wt {2ayd (7s) fiat 1 Ime(Ekwadl '00n? °f? ??? i?wiwd ? wMh i aegl ?W n? ?a a o? ora? lands iaw or ?!?) d W*u MOW war ?a Ewa Mbat ?? ?? (NOD a Pm a ? +Mh a alrai b a point nlalked ?.1? s of Olwia LLput a pWnt sculh pofkrt wNi+ a?stsal pain and ??Nt rah a1 d (?) aorNla WM? INOIV? ) bet t BEM Lot Na 127 in the plan of Counly M1 Deed Book Wo Vokwo o a CW Elkwood, as maaded In W corder of Daada 01111c. for D nbw and HAVING THt7tEON ERECTED a known and numbWW as 207 Elavanth StiaL 0AOOOllll"lYCYMt) SK 1954P64$83 Exhibit (B Cam Cdr P.O. Boo( 9048 Temecula, CA 92589-9048 pne-80 a To: reox e6a694 Po B Dallas, TX 75266-0694 Sind c-mSpoixteme to: PO Box 5170, MS SV3140 Simi Valley, CA 93065 2206390723 Mark MaConnaughey 20711TH ST NEW CUMBERLAND, PA 17070-1618 071210-BLovAi PRESORT First-Class Mall U.S. Postage and Fees Pald WSO 01 NON! LOANS P.O. Box 660694 Dallas, 7X 752660694 Send Payments to. PO Box 660694 (Alas, 7X 75266-0694 December 10, 2007 Mark McCormaughey 207 11TH ST NEW CUMBERLAND, PA 17070-1618 Account No.: 73108447 Property Address: 207 Eleventh Street New Cumberland, PA 17070 Current Servicer: Countrywide Home Loans Servicing LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This Is an ofWai nox.y that the morto 1MM on vour hema is In do & A and the lender intends to to oso Swdttc ' w•on about vw irs of the dNardt le erovlded M tiu Will ••i••- TM HOMUM02 NEO^ENCY MORTGAGE ASSISTANCE PROGRAw (HEM I may be able to heb to home TNs Notice elnlalns how the oroaram w a, eve vow This Notice contains important legal information. If you have any questions, representatives at the Consumer Croft 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 fnd a lawyer. LA NOTFICAC16N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CON7ENID0 DE ESTA NOTFICAC16N OBTENGA UNA TRADUCCI6N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL WMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRI:STAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CURL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDWR SU HIPOTECA. HOMEOWNER'S NAME(S): Mark McConnaughoy PROPERTY ADDRESS: 'Pe7cl--- d new cumeerland. PA 17070 LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDERISERVICER: GRUnhrvwlde Home Loans Servidna P HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY ELIGHL9 E LL ASSIST MCE WHICH CAN S•ts YOLK e.'? FROM-FORECLOSURE (HELP YOU MAKE FUTURE xGE PAYIMEINTS • Male your cla*=to =MW Morro oars xxnunberon =check or money order • you In any aftoral amourls you ore includIng mom than d $5 'please send • pWntteattadk your dkedk to the • Doht Incudekarresponderce • Dont send cash I"ffWdAPYoua Paaeewrrrrokra?ooWnmbQanaNCrotloandmmasppMyrp•. gel V•Yn?•kt nMkm•o Orropdad eyyokr Aroncsl IrotOeCR enLJ•Gitn appi(mp lent. AccowrlNLxnber.7S101N47'1 Mark McCortnaughey Balance Due for charges fisted above: $2,588.46 as of 12MOf2007. 207 Eleventh Street Psa• upd•k•an•i Wonraft on a• mmm Wedkls mupm. A4i eHwl P icp•1 BLQPAt Add ., ntlO'" Countywide PO BOX 660694 DaRas, TX 7526 75266-04 p--- Ilrrrlrlrlrr,Irl?llrrrllrrll.r.rllrrlrlrrrl,?ll,lrrrl?rlrrlrlllrrrl ak.dt Todl 073108447100000258846000258846 IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 M4E °ACr% 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 FoftEa r RF _ 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 fisted at the end of thus Notice. LtNS MEETING NNUST r?rrt n v--- -.. ?..? ..r..? T&A9rr..en...- .._ .._.- -- ---- R CREDIT COLS INr• sGGIMM _ 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 tturty (30) days after the date of this meeting. The O=s ?a"'L no "w` TO o vO N? . It is only necessary to schedule one face-todace meeting. Advise your your Itentions. APPLICATION FOR MORTGAG ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for spec information about the nature of your default.) if you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must 11 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. Orgy 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 decision after it receives your application. During that time, no foreclosure proceedings will n be be Pu p hassued sixty a d a (60) days to make a met the timerequirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 207 Eleventh Street New Cumberland, PA 17070 IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due M4mtu oagall_; 10/09/2007 $2,999.22 Late Char -c• 10109/2007 $89.88 Other Late Chases Total Late Charges: ?9 t38 Uncollected Costs: . $27 50 Partial Payment Balance: . ($315.02) TOTAL DUE: $2,588./6 YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use it not W fi jft j) TO C E D low _ You may cue the defauAt within THIRTY tain DAYS of the date of this notice BY PAYING G THEW TOTAL AMOUNT PAST DUE TO THE LENDER, WENCH IS $2,588,66, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made idwr by 2shier' check- rimed check o mas- a x rx to 7 Emd uer Pra ptr9-md addlen below WW allow us to swolyou kdamaon an you amm Accaxt ekarjber Made McCom"hey EmaN addnm Flow we hod YoW ppu to is NOW yaNOOde of ywaMd od Id" OA M mod b M aroM eWbeft mbb,rd doe, dme ors w gmnyr PdMW or bit or bw. r yen "a . awAd b Odom Is Per Mwddod ME" ommat of VA oft your twMmdo d pbr*i ad k1lowell IN w? doldmdm, bb domes Sell dow IOa am IN ooeowollm 00 yon bw mW M Is md- fiw coldoe to ph" Won of yom bm RUM slo* If JIM OW N eddbegi vUWA Row y Mwo t*rrnb, miter an FWAM dok 0w lgvWb p ft b b lot Oft twMbbd dieaki Wm goo* Oynood b iy a bmn oomndsr a bdo Mm. Countrywide at P.O. Box 660694, Dallas, TX 75266-0694. Y ' 9 : v anv oth r f ?It by akino the following action it in THIRTY (30) DA of not_oh,?r?t the Me i this letter, ( Of iF YOU DO NOT CURET ^EFAUI T - If you do not cure the default within THRTY (30) DAYS of the date of this Notice, the lender Intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property IF TFIE MORTGAGE M FORECLOS UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. R the lender refers your case to its attorneys, but you cure the deli against you, you will still be required to ?enc before the lender begins 50.01 proceedings pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even it they exceed $50.00. Any attorney's tees will be added to the amount you owe the lender, which may also include other reasonable costs. H you cure the default within the THIRTY 30 DAY period, you will not be required to pay attorney's fees. GTHER LENDER REMEDIES - The lender may also sue you personall for the under the mortgage. y unpaid principal balance and all other sums due RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and fa0closure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as speed in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice YAN restore your mortgage to the same position as If you had never defaulted. EARLIEST ELSHERIFF'S SALE 13ATE - lt is estimated that the earliest date that such a Sheriff's Sale of the mortgage property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT IM LENDER: Name of Lende-r. Count+ywMe Nome Loans Servicing LP Address: P. Q Box 660694 Dallas, 7X 73266-0694 Phone Numb _• 1.800-66"101 Fax Number. 1-805-377-3432 Contact Person: us P7x-36 Attention. Loan Counselor EFFECT OF SHERIFF'S •I - You should realize that a Sheriffs Sale will end your ownership of the mortgaged right to occupy it. If you continue to live in the property after the Sheriff s sale, a lawsuit to remove ouand property and and other belongings could be started by the lender at any time, y your furnishings ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT, TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Your loan is in default. Pursuant to your loan documents, Countrywide may, ender upon and conduct an inspection of your IN 2206390723 property. The purposes of such an inspection are to (i) observe the physical condition of your property, (ii) verify that the property is occupied and/or 01) determine the identity of the occupant. It you do not cure the default prior to the inspection, other actions to protect the mortgagee's interest in the property (including, but not limited to, winterization, securing the property, and valuation services) may be taken. The costs of the above-described Inspections and property preservation efforts will be charged to your account as provided In your security Instrument. If you are unable to cure the default on or before January 9, 2008, Countrywide wants you to be aware of various options that may be available to you through Countrywide to prevent a foreclosure sale of your property. For example: • Rea nt Plan: It is possible that you may be eligible for some form of payment assistance through Countrywide. sic Plan requires that Countrywide receive, up front, at least'/. of the amount necessary to bring the account current, and that the balance of the overdue amount be paid, along with the regular monthly payment, over a defined period of time. Other repayment plans also are available. • Loan Modification: Or, it is possible that the regular monthly payments can be lowered through a modification of the ban by reducing the interest rate and then adding the delinquent payments to the current loan balance. This foreclosure altemative, however, is limited to certain loan types. • Sale of Your Property: Or, if you are wilting to sell your home in order to avoid foreclosure, it is possible that the sale of your home can be approved through Countrywide even if your home is worth less than what is owed on it. • Deed4n4Lieu: Or, if your property is free from other lens or encumbrances, and if the default is due to a serious financial hardship which is beyond your control, you may be eligible to deed your property directly to the Noteholder and avoid the foreclosure sale. If you are interested in discussing any of these foreclosure alternatives with Countrywide, you must contact us immediately. If you request assistance, Countrywide will need to evaluate whether that assistance will be extended to you. In the meantime, Countrywide will pursue all of its rights and remedies under the loan documents and as permitted by law, unless it agrees otherwise in writing. Failure to bring your loan current or to enter into a written agreement by January 9, 2008 as outlined above will result in the acceleration of your debt. Time is of the essence. If you have any questions concerning this notice, please contact Loan Counseling Center immediately at 1-800-669-0102. I CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY FRI ANQ COUNTY d 14 S. 13th Street Adams County Interfaith Housing Authority CCCS of Western PA Harrisburg, PA 17104 40 E High Street 2000 L Road 717.213.0150 Gettysburg, PA 17325 P A 1 A 1 Harrisburg, 7102 717.334.1518 888.51,5111. .2227 Community Action Comrnissia LovesNp, Inc. of Captial Region 2320 Nafi 5ih Street Meranaths 1514 Derry Street Harrisburg, PA 17110 43 Philatielphis Avenue Harrisburg, PA 17104 717.232 220 Waynesboro, o, P Waynesboro, PA 17288 717.232.8757 . 717.782.3285 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 ACT 91 NOTICE DATE OF NOTICE: June 12, 2008 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. This is an official notice that the mortgage on our home is in default and the lender intends to foreclose. Specific information about the nature of the default is rovided 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 hel ou 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 A encv The name address and hone number of Consumer Credit Counselin A encies serving your County are listed at the end of this Notice If you have any questions you may call the Pennsylvania Housm Fmance Aaencv toll free at 1-800-342-2397. (Persons with im aired heann9 can call (717) 780-1M This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. Prepared by: GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 Fax (215) 627-7734 HomeRetention@goldbecklaw.com Date: June 12, 2008 TO: SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Homeowners Name: MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY and SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Property Address: 207 Eleventh Street, New Cumberland, PA 17070 Loan Account No.: 73108447 Original Lender: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTINGSOLELY AS A NOMINEE FOR DECISION ONE MORTGAGE COMPANY, LLC Current Lender/Servicer: COUNTRYWIDE HOME LOANS INC. HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of forth at the end of this Notice. It is only necessary V w.? v?"`i` .« w111G11 u1G ro is located are set to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your fact-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. Ivu it r.: tr Y U U ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION il''t' BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT, (If you have filed bankruptcy you can still apply for Eme enc Mort a Assistance. HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it u to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 207 Eleventh Street, New Cumberland, PA 17070 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 3 (a) Monthly payment from 10/01/2007 thru 611212008 (9 mos. at $898.74/month) $8,088.66 (b) Late charges from 10/01/2007 thru 6/12/2008 (9 mos. at $44.94/month) $404.46 (c) Other charges; Escrow, Inspec., NSF Checks (d) Other provisions of the mortgage obligation, if any (e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $8,493.12 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 $8,493.12, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check certified check or money order made payable and sent to: Attention: Act Letter Department COUNTRYWIDE HOME LOANS INC. c/o Goldbeck McCafferty & McKeever 701 Market Street Suite 5000 Philadelphia, PA 19106 HomeRetention@goldbecklaw.com 866-413-2311 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mort a e debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon vour mortgaged property IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender brings legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the rit to cure the default and prevent the sale at any time up to one hour before the Sheri fPs Sale You ma do so by A)jng the total amount then past due plus an v late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Shenffs Sale ass ecified m writin b the lender and b ormin another r uirements under the p a¢e Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately four A)12 six (61 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: COUNTRYWIDE HOME LOANS, INC. Address: 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Phone Number: 800-669-4576 Work Out Department: 800-669-0102, 877-744-7691, 800-222-9944 Fax Number: 215-825-6441 Contact Person: HomeRetention@goldbecklaw.com EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Contact: HomeRetention@goldbecklaw.com Phone Number: 800-b694576 Work Out Department: 800-669-0102, 877-744-7691, 800-222-9944 N 1 a F t? C=D C3 m --? i C -..e 5 r-? ow . 1 CASE NO: 2008-04279 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS MCCONNAUGHEY MARK A ET AL STEVE BENDER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MCCONNAUGHEY MARK A the DEFENDANT , at 0018:50 HOURS, on the 28th day of July , 2008 at 207 ELEVENTH STREET NEW CUMBERLAND, PA 17070 by handing to MARK MCCONNAUGHEY DEFENDANT a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge -71-a,10 i (?- 18.00 17.00 .00 10.00 00 45.00 Sworn and Subscibed to before me this day So Answers: r R. Thomas Kline 07/29/2008 GOLDBECK & MCCAFFERTY By: Deputy Sheriff of A. D. SHERIFF'S RETURN - REGULAR CASE NO: 2008-04279 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS MCCONNAUGHEY MARK A ET AL STEVE BENDER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MCCONNAUGHEY SUZANNE M the DEFENDANT , at 0018:50 HOURS, on the 28th day of July , 2008 at 207 ELEVENTH STREET NEW CUMBERLAND, PA 17070 TMT T TJ TAf' f f"%hTTTT TT/"TS=-,7 by handing to HUSBAND OF DEFENDANT a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 /3l Jb? .00 16.00- Sworn and Subscibed to before me this day of So Answers: r R. Thomas Kline 07/29/2008 GOLDBECK MCCAFFERTY By. Deputy Sheriff A. D. In the Court of Common Pleas of Cumberland County DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY (Mortgagor(s) and Record Owner(s)) 207 Eleventh Street New Cumberland, PA 17070 Defendant(s) PRAECIPE FOR JUDGMENT No. 08-4279 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 MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY and SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY by default for want of an Answer. Assess damages as follows: Debt Interest from 09/03/2008 to Date of Sale per diem at $27.25 Total (Assessment of Damages attached) $128,337.16 I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 X1 Michael T. McKeever Attorney for Plaintiff ^ I.D. #56129 AND NOW J( )E 4200 Pj , Judgment is entered in favor of DEUTSCHE BANK NATIO AL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 and against MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY and SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY by default for want of an Answer and damages assessed in the sum of $128,337.16 as per e above certification. othonotary Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. No. 08-4279 MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY (Mortgagors and Record Owner(s)) 207 Eleventh Street New Cumberland, PA 17070 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Curt Long Prothonotary By: "I jo'4"; )r? • per"t 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 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, MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY, is about unknown years of age, that Defendant's last known residence is 207 Eleventh Street New Cumberland, PA 17070, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: gln1o? L 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, SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY, is about unknown years of age, that Defendant's last known residence is 207 Eleventh Street New Cumberland, PA 17070, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: gI?IV? U\1'Y NI'L ?. UL A WC1 67748FC 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: August 19, 2008 TO: MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY 207 11th Street New Cumberland, PA 17070 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL 1, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY (Mortgagor(s) and Record Owner(s)) 207 Eleventh Street New Cumberland, PA 17070 Defendant(s) TO: MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY 207 11 th Street New Cumberland, PA 17070 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 08-4279 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 67748FC 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: August 19, 2008 TO SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY 207 11th Street New Cumberland, PA 17070 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY (Mortgagor(s) and Record Owner(s)) 207 Eleventh Street New Cumberland, PA 17070 Defendant(s) TO: SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY 207 11 th Street New Cumberland, PA 17070 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 08-4279 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 -"6 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 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY (Mortgagor(s) and Record owner(s)) 207 Eleventh Street New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 08-4279 ORDER FOR JUDGMENT Please enter Judgment in favor of DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7, and against MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY and SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of service of the Complaint, in the sum of $128,337.16. U U j j IC?) Michael T. McKeever - Attorney for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006- HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 and that the name(s) and last known address(es) of the Defendant(s) is/are MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY, 207 Eleventh Street New Cumberland, PA 17070 and SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY, 207 Eleventh Street New Cumberland, PA 17070; GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $111,512.28 Interest from 09/09/2007 through $9,810.00 09/02/2008 Reasonable Attorney's Fee $5,575.61 Late Charges $539.27 Costs of Suit and Title Search $900.00 Escrow Payments Due 0 X $0.00 $0.00 $128,337.16 U -w -I U gI lr4 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff AND NOW, this -91W1 day of Pef+- , 2008 damages are assessed as above. Prothy { !?1 r e? V? 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 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Mortgagor(s) and Record Owner(s) 207 Eleventh Street New Cumberland, PA 17070 Defendant(s) No. 08-4279 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 09/03/2008 to Date of Sale per diem at $27.25 128,337.16 (Costs to be added) GOLDBECK McC FE TY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff a p??x O `" W o ZH? d?WU D ? px ? O ?4 W CA Oil W?U p? ? o W?Wx oc?np'' d C) U6 UUu? d w ? . O H V d Wy O d H ? ?w os a? o? WE U w N ? ?,4 a H N v y y Q?, M O a o? C7 (jo L-N cZ, f W 41A a t n ? °I p IN 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 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. Plaintiff MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY (Mortgagor(s) and Record Owner(s)) 207 Eleventh Street New Cumberland, PA 17070 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 08-4279 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7, 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: 207 Eleventh Street New Cumberland, PA 17070 1.Name and address of Owner(s) or Reputed Owner(s): MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 2. Name and address of Defendant(s) in the judgment: MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 .I . , 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 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 207 Eleventh Street 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 2, 2008 , ' ` n n , , 7 \ ? U LrA GOLDBECK McCAFFERTY & MCKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff C') '?' c? t.s C. r, c=°s cra T1 r'i'' i- ? t't't ( ;C3 fT, ,? ?n ? 4, {??.? ?? i ? (? I ,?? 1 ?? ?C 08-4279 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006- HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. MARK A. MCCONNAUGHEY a/k/a MARK M000NNAUGHEY- SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Mortgagor(s) and Record Owner(s) 207 Eleventh Street New Cumberland, PA 17070 Defendant(s IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-4279 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: MCCONNAUGHEY, MARK A. a/k/a MARK MCCONNAUGHEY MARK A. MCCONNAUGHEY alkla MARK MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 Your house at 207 Eleventh Street, New Cumberland, PA 17070 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 $128,337.16 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006- HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 08-4279 To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7, 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 08-4279 2 Liberty Avenue Carlisle, PA 17013 f a 08-4279 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 ht •/t?.phfa org/consumers/homeowners/real.Wx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionggLoldbecklaw.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 67748FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. Ca 4_> Sys '.. ? ? ? -? r Q M r 08-4279 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL 1, INC TRUST 2006- HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW Plaintiff vs. MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Mortgagor(s) and Record Owner(s) 207 Eleventh Street New Cumberland, PA 17070 Defendant(s; ACTION OF MORTGAGE FORECLOSURE Term No. 08-4279 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: MCCONNAUGHEY, SUZANNE M. a/k/a SUZANNE MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 Your house at 207 Eleventh Street, New Cumberland, PA 17070 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 $128,337.16 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006- HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 08-4279 To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7, 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 08-4279 2 Liberty Avenue Carlisle, PA 17013 08-4279 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 hltp://www.phfa.org/consuiners/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 67748FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. ?'' iJ ,?.., ? , ? ?, i.; `?r t=? . ? i 4 .+ lf.ti w ?, W } .. ? .? ~? +?. ' ??? ..-t r'? s' -,?. ??? ALL THAT CERTAIN piece or parcel of land situate in Second Ward of the Borough of New Cumberland, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described based on a survey by Michael C. D'Angelo, PLS, dated September 25, 1995 and recorded with Deed in Deed Book 150, Page 12, as follows, to wit: BEGINNING at a point on the Northern line of Eleventh Street, a distance of two hundred fifty-six and fifty-four hundredths (256.54) feet East of the Northeast corner of Bridge and Elevenths Streets and marked with a steel pin; thence North twenty-eight (28) degrees twenty-five (25) minutes thirty-three (33) seconds West seventy-eight (78) feet along other lands now or formerly of David A. Krulac to a point marked with a steel pin; thence South sixty-one (61) degrees thirty-four (34) minutes twenty-seven (27) seconds West thirty-seven (37) feet along lands now or formerly of Mary A. Krulac to a point marked with a steel pin; thence South twenty-eight (28) degrees twenty-five (25) minutes thirty-three (33) seconds East seventy-eight (78) feet along lands now or formerly of Gloria Lynn to a point marked with a steel pine; thence along the Northern line of Eleventh Street South sixty-one (61) degrees thirty-four (34) minutes twenty-seven (27) seconds West thirty-seven (37) feet to a point marked with a steel pin and place of BEGINNING. BEING Lot No. 127 in the Plan of Lots called Elkwood, as recorded in Recorder of Deeds Office for Cumberland County in Deed Book "M" Volume 5, Page 498. MUNICIPALITY: Borough of New Cumberland HAVING THEREON ERECTED a dwelling known and numbered as 207 Eleventh Street, New Cumberland, PA 17070 TAX PARCEL #: 26-23-0541-266 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-4279 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7, Plaintiff (s) From MARK A. MCCONNAUGHEY A/K/A MARK MCCONNAUGHEY AND SUZANNE M. MCCONNAUGHEY A/K/A SUZANNE MCCONNAUGHEY (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 $128,337.16 L.L. $.50 Interest FROM 9/3/08 TO DATE OF SALE PER DIEM AT $27.25 Atty's Comm % Due Prothy $2.00 Atty Paid $180.00 Plaintiff Paid Date: SEPTEMBER 3, 2008 (Seal) REQUESTING PARTY: Name MICHAEL T. MCKEEVER, ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Other Costs Deputy Telephone: 215-627-1322 Supreme Court ID No. 56129 Deutsche Bank National Trust Company In The Court of Common Pleas of VS Cumberland County, Pennsylvania Mark A. McConnaughey a/k/a Mark Writ No. 2008-4279 Civil Term McConnaughey and Suzanne M. McConnaughey a/k/a Suzanne McConnaughey R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Michael McKeever. Sheriffs Costs: Docketing 30.00 Poundage 3.53 Advertising 15.00 Posting Handbills 15.00 Law Library .50 Prothonotary 2.00 Levy 15.00 Mileage 34.00 Surcharge 30.00 Postpone Sale 20.00 Share of Bills 14.92 3? 01 $17q.15 ? ??? i So Answers: R. Thomas Kline, Sheriff BY c Real Estate ergeant -D C19 CGt'LI a/-7 12- 4, 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 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY (Mortgagor(s) and Record Owner(s)) 207 Eleventh Street New Cumberland, PA 17070 Defendant(s) No. 08-4279 AFFIDAVIT PURSUANT TO RULE 3129 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7, 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: 207 Eleventh Street New Cumberland, PA 17070 1.Name and address of Owner(s) or Reputed Owner(s): MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 2. Name and address of Defendant(s) in the judgment: MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 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 207 Eleventh Street 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 2, 2008 ?AMIA 7 \ AB Q GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 084279 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7, Plaintiff (s) From MARK A. MCCONNAUGHEY A/K/A MARK MCCONNAUGHEY AND SUZANNE M. MCCONNAUGHEY A/K/A SUZANNE MCCONNAUGHEY (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 $128,337.16 L.L. $.50 Interest FROM 9/3/08 TO DATE OF SALE PER DIEM AT $27.25 Atty's Comm % Due Prothy $2.00 Atty Paid $180.00 Other Costs Plaintiff Paid Date: SEPTEMBER 3, 2008 (Seal) REQUESTING PARTY: Name MICHAEL T. MCKEEVER, ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 LcFULY Real Estate Sale #74 On September 8, 2008 the Sheriff levied upon the defendant's interest in the real property situated in Borough of New Cumberland, Cumberland County, PA Known and numbered as 207 11 th Street, New Cumberland more fully described on Exhibit "A" tom'' filed with this writ and by this reference incorporated herein. Date: September 8, 2008 By: Real Es a ),Sergeant 08-4279 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006- HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE vs. MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Mortgagor(s) and Record Owner(s) Term No. 08-4279 207 Eleventh Street New Cumberland, PA 17070 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: MCCONNAUGHEY, SUZANNE M. a/k/a SUZANNE MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 Your house at 207 Eleventh Street, New Cumberland, PA 17070 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 $128,337.16 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006- HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 08-4279 To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1- 866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 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 08-4279 2 Liberty Avenue Carlisle, PA 17013 08-4279 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 hLtp://www.12hfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention&goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 67748FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 08-4279 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006- HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE VS. MARK A. MCCONNAUGHEY a/k/a MARK M000NNAUGHEY- SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Mortgagor(s) and Record Owner(s) Term No. 08-4279 207 Eleventh Street New Cumberland, PA 17070 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: MCCONNAUGHEY, MARK A. a/k/a MARK MCCONNAUGHEY MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 Your house at 207 Eleventh Street, New Cumberland, PA 17070 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 $128,337.16 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006- HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 08-4279 To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1- 866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 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 08-4279 2 Liberty Avenue Carlisle, PA 17013 08-4279 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.orWconsumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionggoldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 67748FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 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 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Mortgagor(s) and Record Owner(s) 207 Eleventh Street New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-4279 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 09/03/2008 to Date of Sale per diem at $27.25 $128,337.16 (Costs to be added) GOLDBECK CAFFERTY & McKEEVER BY: Michael f McKeever Attorney fo laintiff Q -'- y' h? Q G = a = Z' 0 pONQg$ 00 ?r LL- z?o ? z ax aQ,i? N O a ?a¢W xxxc7 10, O 41 U b 0 00 W., zzp U SUU to oNU w o w ?Oo? ¢ o z U x ¢ w a??' U un QF N N U a? U ?. a y U N U M U N ati"'.. O N w? ,? ,c O N N V ? y O O b ? a 04 ALL THAT CERTAIN piece or parcel of land situate in Second Ward of the Borough of New Cumberland, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described based on a survey by Michael C. D'Angelo, PLS, dated September 25, 1995 and recorded with Deed in Deed Book 150, Page 12, as follows, to wit: BEGINNING at a point on the Northern line of Eleventh Street, a distance of two hundred fifty-six and fifty-four hundredths (256.54) feet East of the Northeast corner of Bridge and Elevenths Streets and marked with a steel pin; thence North twenty-eight (28) degrees twenty-five (25) minutes thirty-three (33) seconds West seventy-eight (78) feet along other lands now or formerly of David A. Krulac to a point marked with a steel pin; thence South sixty-one (61) degrees thirty-four (34) minutes twenty-seven (27) seconds West thirty-seven (37) feet along lands now or formerly of Mary A. Krulac to a point marked with a steel pin; thence South twenty-eight (28) degrees twenty-five (25) minutes thirty-three (33) seconds East seventy-eight (78) feet along lands now or formerly of Gloria Lynn to a point marked with a steel pine; thence along the Northern line of Eleventh Street South sixty-one (61) degrees thirty-four (34) minutes twenty-seven (27) seconds West thirty-seven (37) feet to a point marked with a steel pin and place of BEGINNING. BEING Lot No. 127 in the Plan of Lots called Elkwood, as recorded in Recorder of Deeds Office for Cumberland County in Deed Book "M" Volume 5, Page 498. BEING THE SAME PREMISES BY DEED DATED 06/09/2006, GIVEN BY DEBORAH A. IKEHARA, NOW KNOWN AS DEBORAH A. OAKLEY AND ROBERT J. OAKLEY, JR., HER HUSBAND TO MARK MCCONNAUGHEY ANS SUANNE MCCONNAUGHEY, HIS WIFE AND RECORDED 06/15/2006 IN BOOK 275 PAGE 732 INSTRUMENT # 2006-021065. MUNICIPALITY: Borough of New Cumberland HAVING THEREON ERECTED a dwelling known and numbered as 207 Eleventh Street, New Cumberland, PA 17070 r w? TAX PARCEL #: 26-23-0541-266 Gold eck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY (Mortgagor(s) and Record Owner(s)) 207 Eleventh Street New Cumberland, PA 17070 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 08-4279 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7, 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: 207 Eleventh Street New Cumberland, PA 17070 1.Name and address of Owner(s) or Reputed Owner(s): MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 2. Name and address of Defendant(s) in the judgment: MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 TNar- !A ?Y 2099 OCT 20 Atli 9: 57 Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Mortgagor(s) and Record Owner(s) 207 Eleventh Street New Cumberland, PA 17070 Defendant(s) CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Michael T. McKeever, Esquire hereby certify that I am the attorney of r I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has Act. Michael T. cKeeve Attorney /or plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NO. 08-4279 the Plaintiff in this action, and l with all the provisions of the Fii-L D THE 2009 OCT 20 Ah S: 57 ? ? ! f rv t?t? ?. ?J:?J t 1 08-4279 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006- HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Mortgagor(s) and Record Owner(s) 207 Eleventh Street New Cumberland, PA 17070 Defendant(s; IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-4279 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: MCCONNAUGHEY, MARK A. a/k/a MARK MCCONNAUGHEY MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 Your house at 207 Eleventh Street, New Cumberland, PA 17070 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 $128,337.16 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL 1, INC TRUST 2006- HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 08-4279 To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7, 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 Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: 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 08-4279 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 t 08-4279 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.orp-,/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionggoldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 67748FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 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 08-4279 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL, 1, INC TRUST 2006- HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE vs. MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Mortgagor(s) and Record Owner(s) Term No. 08-4279 207 Eleventh Street New Cumberland, PA 17070 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: MCCONNAUGHEY, SUZANNE M. a/k/a SUZANNE MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 Your house at 207 Eleventh Street, New Cumberland, PA 17070 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 $128,337.16 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006- HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE r 08-4279 To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1- 866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadell)hiafed.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 08-4279 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 08-4279 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.orWconsumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionkgoldbecklaw.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 67748FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-4279 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY, as Trustee for MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7, Plaintiff (s) From MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY (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 $128,337.16 L.L. Interest from 9/3/08 to Date of Sale per diem at $27.25 -- to be Determined Atty's Comm % Atty Paid $381.45 Plaintiff Paid Date: 10/20/09 Due Prothy $2.00 Other Costs (Seal) REQUESTING PARTY: Name: MICHAEL T. McKEEVER, ESQUIRE Address: GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 Deputy GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Mortgagor(s) and Record Owner(s) 207 Eleventh Street New Cumberland, PA 17070 Defendant(s) Fl _ , r ?r ?r?.. ?? _ YF?1f 2010 FE3 26 Pik 3, 27 67748FC CF: 07/17/2008 SD: 03/03/2010 $128,337.16 T OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-4279 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: ? peg A,•wig so (.z/z.% /ok 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, n. .?,4 . BY: Keith C. Halili Legal Secretary a $ ? LL tD O ? O O ° a LL ?? T {? 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[mac KK K ^6 = m ??OD 0 o m n C) O C) g _ r ` z a (D U) a o ac c v v ?JNy ?m? c W ?// L ?, m? E -g O p L m t ?, wm c D g U i° m a> dl 3 z `m 00 C3 E L x.2 0 r_ 0000011 o d` m 04 Q t U w N Z.-Z O N ~ci?n_m ° a 'a O E Q z z w Lu Cb cc v I.- Id lu 0. C,4 -6 $Wmo?Woon ?uy •G1V?Qm zO Z O - p = r N cli st ui (O ti aD 1 = :3 c 0 d c d m O Y C O H 0 CL Q O (_V O C7 4 ?i m N U ?O C 7 m O U a C, R s N ? co -2 U LL ti °rQ U o LL a m } w 2 t9 Q z z 0 U U w z z } w O Q z z O U cU C w z 4z N U } w T Q z z O U U Y Of Q r w S 0 Q z z 0 U U Q Y a GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL 1, INC TRUST 2006- HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Mortgagor(s) and Record Owner(s) 207 Eleventh Street New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-4279 SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7, 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: 207 Eleventh Street New Cumberland, PA 17070 1.Name and address of Owner(s) or Reputed Owner(s): MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 2. Name and address of Defendant(s) in the judgment: MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 NEW CUMBERLAND BOROUGH 1120 Market Street New Cumberland, PA 17070 NEW CUMBERLAND BOROUGH 127 South Market Street P.O. Box 95 Mechanicsburg, PA 17055 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 207 Eleventh Street 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 unworn falsification to authorities. DATED: February25, 2010 GOLDBECK McCA FERTY & McKEEVER BY: Keith C. Halili Legal Secretary SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff , 4.a Jody S Smith 0 r Chief Deputy Edward + a ', r? t• L Schorpp Solicitor Deutsche Bank National Trust Company as Trustee vs. Mark McConnaughey (et al.) Case Number 2008-4279 SHERIFF'S RETURN OF SERVICE 12/23/2009 07:57 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on December 23, 2009 at 1955 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 Mark & Suzanne M. McConnaughey, located at, 207 11th Street, New Cumberland, Cumberland County, Pennsylvania according to law. 12/23/2009 Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on December 23, 2009 at 1955 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: Mark McConnaughey, by making known unto, Suzanne M. Mcconnaughey, wife of defendant, at, 207 11th Street, New Cumberland, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 12/23/2009 07:57 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on December 23, 2009 at 1955 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: Suzanne M. McConnaughey, by making known unto, Suzanne M. Mcconnaughey, personally, at, 207 11th Street, New Cumberland, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 03/02/2010 Property sale postponed to 5/5/2010. 04/20/2010 PROPERTY SALE CANCELLED SHERIFF COST: $995.44 April 20, 2010 f' . SO ANSWERS, RON y R ANDERSON, SHERIFF A Goldbeck McCafferty & McKeever BY: Michael T` McKee'vi,r Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW L)LU t a?rl> BANK NA"I IONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-IIE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff ACTION OF MORTGAGE FORECLOSURE' Vs. MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MC'CONNAUGHEY a/k/a SUZANNE. MCCONNAUGHEY (Mortgagor(s) and Record Owner(s)) 207 Eleventh Street New Cumberland, PA 17070 No. 08-4279 Defendant(s) AFFIDAVIT P1 RSUANT TO RULE 1129 DLUfS(`14F BANK NATIONAL "TRUST CONIP_\NY AS "I RUS"ITE FOR MORGAN STANI.I::AI3,, CAPITAL I, INC TRUST 2006-11L7 MORTGAGE PASS THROUGH C'ERIIFIC'AI LS. SERIES 2006-HE7, Plaintiffin the above action, by its attonrey. Michael I'. McKeever, F,squire. sets forth as of the date the prampe for the writ of execution was filed the followl]IL, information concerning the real property located at: 207 Eleventh Street New Cumbertand. P,? 17070 I.Name and address of O?? ner(s) or Reputed Owucr(q MARK A. NICC'ONNAUGIIEY a-kia MARK MCCONNAUGHEY 207 Eleventh Street Neva Cumberland. PA 17070 SUZANNE M. MC'CONNAU(iIIEY a'La SUZANNE MCCONN.\UGIIEY -107 Eleventh Street New Cumberland, PA 17070 I Name and address of Defendant(s) in the judgment: MARK A. MCCONNAU(;HEY a'k/a MARK MCCONNAU(JIVY 207 Eleventh Street Nc,x Cumberland, PA 17070 SUZANNE M. MCCONNAUGHEY a,'k/a SUZANNE MC'C'ONNAUGHEY 207 Eleventh Street New Cumberland. PA 17070 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 207 Eleventh Street New Cumberland. PA 17070 (attach separate sheet if more space is needed) t verify that the statements made in this affidavit are true and correct to the est my personal kno% ledge or information and belief. I understand that false statements herein are made subject t the enalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: October _15 2009 GOLDBECK c 'AFI IRTY NIcKI fVI R BY: N9ichael . McKeever. Esq. Attorney f Plaintiff' 08-4279 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff DEUTSCHE, BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006- HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGI I EY Mortgagor(s) and Record Owner(s) 207 Eleventh Street New Cumberland. PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-4279 THIS LAW IARM IS A DEBT COLLECTOR AND NN'E ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT T'O YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FRO.NI YOU NVILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: %WCONNAUGHEY, h1ARK A. a: ka MARK Nft CONNAUGHEY MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 Your house at 207 F leventh Street, New Cumberland. PA 17070 is scheduled to be sold at Sheriffs Sale on Wednesday. March 03. 2010, at 10:00 f\N1, in Commissioners Ilearing Rm 2nd FL Courthouse to enforce the court judgment oCS 128,337.16 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006- IIE7 MORTGAGE PASS THROUGH CERTIFICATES. SERIES 20064IE7 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 08-4279 To prevent this Sheriffs Sale you must take immediate action I . The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL 1, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or I - 866-413-21311. 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). YOLJ MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amormt due from the Buyer is not paid to the Sheriff: you rill remain the owner of the property as if the sale never happened. 5. Vou have a right to remain in the property until the full amount due is paid to the Sheriff and the Shcrilf gives a deed to the buyer. At that time, the buyer may brim-, 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 he receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons wli,, the proposed distribution is wrong) are tiled with the Sheriff within ten (10) davs 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: hitp:!iwww.philadelphiafed.or/foreclosure,- YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER A7'ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OU1 WIIEIZE YOU CAN GET LEGAL HELP. LEGAL SEIZVICFS INC 8 Irvine Row Carlisle, PA 17013 08-4279 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 08-4279 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.yhfa.org/consumers/homeownersi/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(c?r?oldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firms 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 67748FC. Para informacion en espanol puede cominunicarse con Loretta at 215-825-6344. ALL THAT CERTAIN piece or parcel of land situate in Second Ward of the Borough of New Cumberland, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described based on a survey by Michael C. D'Angelo, PLS, dated September 25, 1995 and recorded with Deed in Deed Book 150, Page 12, as follows, to wit: BEGINNING at a point on the Northern line of Eleventh Street, a distance of two hundred fifty-six and fifty-four hundredths (256.54) feet East of the Northeast corner of Bridge and Elevenths Streets and marked with a steel pin; thence North twenty-eight (28) degrees twenty-five (25) minutes thirty-three (33) seconds West seventy-eight (78) feet along other lands now or formerly of David A. Krulac to a point marked with a steel pin; thence South sixty-one (61) degrees thirty-four (34) minutes twenty-seven (27) seconds West thirty-seven (37) feet along lands now or fonnerly of Mary A. Krulac to a point marked with a steel pin; thence South twenty-eight (28) degrees twenty-five (25) minutes thirty-three (33) seconds East seventy-eight (78) feet along lands now or formerly of Gloria Lynn to a point marked with a steel pine; thence along the Northern line of Eleventh Street South sixty-one (61) degrees thirty-four (34) minutes twenty-seven (27) seconds West thirty-seven (37) feet to a point marked with a steel pin and place of BEGINNING. BEING Lot No. 127 in the Plan of Lots called Elkwood, as recorded in Recorder of Deeds Office for Cumberland County in Deed Book `'M" Volume 5, Page 498. BEING THE SAME PREMISES BY DEED DATED 06/09/2006, GIVEN BY DEBORAH A. IKEHARA, NOW KNOWN AS DEBORAH A. OAKLEY AND ROBERT J. OAKLEY, JR., HER HUSBAND TO MARK MCCONNAUGHEY ANS SUANNE MCCONNAUGHEY, HIS WIFE AND RECORDED 06/15;2006 IN BOOK 275 PAGE 732 INSTRUMENT # 2006-021065. MUNICIPALITY: Borough of New Cumberland HAVING THEREON ERECTED a dwelling known and numbered as 207 Eleventh Street. New Cumberland, PA 17070 TAX PARCEL #: 26-23-0541-266 08-4279 GOLD,BECK MCCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006- HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 - 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE vs. MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Mortgagor(s) and Record Owner(s) Term No. 08-4279 207 Eleventh Street New Cumberland, PA 17070 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: MCCONNAUGHEY, SUZANNE M. a;k'a SUZANNE MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY 207 Eleventh Street New Cumberland. PA 17070 Your house at 207 Eleventh Street, New Cumberland, PA 17070 is scheduled to be sold at Sheriffs Sale on Wednesday, March 03, 20107 at 10:00 AM, in Commissioners Hearing RID 2nd FL Courthouse to enforce the court judgment of S 128,337.16 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006- HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 08-4279 To prevent this Sheriffs Sale you must take immediate action 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or I- 866-413-2311. 2 You may be able to stop the sale by filing a petition askin-g 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 proceedinc>s 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: littp://www.pliiladelph afed.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 Re", Carlisle, PA 17013 08-4279 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 OS-4279 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. 0. 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 tree 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 or ,,/consumers/homeowners/real aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionLcbgoldbecklaw 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 67748FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ALL THAT CERTAIN piece or parcel of land situate in Second Ward of the Borough of New Cumberland, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described based on a survey by Michael C. D'Angelo, PLS, dated September 25, 1995 and recorded with Deed in Deed Book 150, Page 12, as follows, to wit: BEGINNING at a point on the Northern line of Eleventh Street, a distance of two hundred fifty-six and fifty-four hundredths (256.54) feet East of the Northeast corner of Bridge and Elevenths Streets and marked with a steel pin; thence North twenty-eight (28) degrees twenty-five (25) minutes thirty-three (33) seconds West seventy-eight (78) feet along other lands now or fonnerly of David A. Krulac to a point marked with a steel pin; thence South sixty-one (61) degrees thirty-four (34) minutes twenty-seven (27) seconds West thirty-seven (37) feet along lands now or fonnerly of Mary A. Krulac to a point marked with a steel pin; thence South twenty-eight (28) degrees twenty-five (25) minutes thirty-three (33) seconds East seventy-eight (78) feet along lands now or formerly of Gloria Lynn to a point marked with a steel pine; thence along the Norther line of Eleventh Street South sixty-one (61) degrees thirty-four (34) minutes twenty-seven (27) seconds West thirty-seven (37) feet to a point marked with a steel pin and place of BEGINNING. BEING Lot No. 127 in the Plan of Lots called Elkwood, as recorded in Recorder of Deeds Office for Cumberland County in Deed Book "M" Volume 5, Page 498. BEING THE SAME PREMISES BY DEED DATED 06/09/2006, GIVEN BY DEBORAH A. IKEHARA, NOW KNOWN AS DEBORAH A. OAKLEY AND ROBERT J. OAKLEY, JR., HER HUSBAND TO MARK MCCONNAUGHEY ANS SUANNE MCCONNAUGHEY, HIS WIFE AND RECORDED 06/15/2006 IN BOOK 275 PAGE 732 INSTRUMENT # 2006-021065. MUNICIPALITY: Borough of New Cumberland HAVING THEREON ERECTED a dwelling knower and numbered as 207 Eleventh Street, New Cumberland, PA 17070 TAX PARCEL #: 26-23-0541-266 WRIT OF EXECUTION and/or ATTACHMENT COMN OVWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-4279 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY, as Trustee for MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7, Plaintiff (s) From MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY (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 $128,337.16 L.L. Interest from 9/3/08 to Date of Sale per diem at $27.25 -- to be Determined Atty's Comm % Atty Paid $381.45 Plaintiff Paid Date: 10/20/09 (Seal) REQUESTING PARTY: Due Prothy $2.00 Other Costs Name: MICHAEL T. McKEEVER, ESQUIRE Address: GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 On November 5, 2009 the Sheriff levied upon the defendant's interest in the real property situated in Borough of New Cumberland, Cumberland County, PA, Known and numbered as 207 Eleventh Street, New Cumberland, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 5, 2009 By: CUOU, Real Estate Coordinator Q 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. isa Marie Coyne, Edi r SWORN TO AND SUBSCRIBED before me this 5 day of February 2010 Notary - nu ,T ,RiAL SEAL Gc' TORAH A COLLINS Notary Public CARLISLE BORO, C" S_RL ND COUNTY My Commission ExpireS Apr 28, 2010 Writ No. 2008-4279 Civil Deutsche Bank National Trust Company as Trustee for Morgan Stanley ABS Capital I, Inc. Trust 2006-HE7, Mortgage Pass Through Certificates, Series 2006-HE7 VS. Mark McConnaughey a/k/a Mark McConnaughey Suzanne M. McConnaughey a/k/a Suzanne McConnaughey Atty: Michael McKeever ALL THAT CERTAIN piece or par- cel of land situate in Second Ward of the Borough of New Cumberland, County of Cumberland, Common- wealth of Pennsylvania, more partic- ularly bounded and described based on a survey by Michael C. D'Angelo, PLS, dated September 25, 1995 and recorded with Deed in Deed Book 150, Page 12, as follows, to wit: BEGINNING at a point on the Northern line of Eleventh Street, a distance of two hundred fifty-six and fifty-four hundredths (256.54) feet East of the Northeast corner of Bridge and Elevenths Streets and marked with a steel pin; thence North twenty-eight (28) degrees twenty- five (25) minutes thirty-three (33) seconds West seventy-eight (78) feet along other lands now or formerly of David A. Krulac to a point marked with a steel pin; thence South sixty- one (61) degrees thirty-four (34) min- utes twenty-seven (27) seconds West thirty-seven (37) feet along lands now or formerly of Mary A. Krulac to a point marked with a steel pin; thence South twenty-eight (28) degrees twenty-five (25) minutes thirty-three (33) seconds East seventy-eight (78) feet along lands now or formerly of Gloria Lynn to a point marked with a steel pine; thence along the North- ern line of Eleventh Street South sixty-one (61) degrees thirty-four (34) minutes twenty-seven (27) seconds West thirty-seven (37) feet to a point marked with a steel pin and place of BEGINNING. BEING Lot No. 127 in the Plan of Lots called Elkwood, as recorded in Recorder of Deeds Office for Cum- berland County in Deed Book °M" Volume 5, Page 498. BEING the same premises by deed dated 06/09/2006, given by Deborah A. Ikehara, now known as Deborah A. Oakley and Robert J. Oakley, Jr., her husband to Mark McConnaughey ans Suanne McConnaughey, his wife and recorded 06/15/2006 in Book 275 Page 732 Instrument # 2006- 021065. MUNICIPALITY: Borough of New Cumberland. HAVING THEREON ERECTED a dwelling known and numbered as 207 Eleventh Street, New Cumber- land, PA 17070. TAX PARCEL #: 26-23-0541- 266. PROPERTY ADDRESS: 207 11th Street, New Cumberland, PA 17070. The Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE i4ePatriot News Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss 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: h 01/22/10 01/29/10 02/05/10 ? ... ............. Sworn,tda6d subscribed before rre tW ' 2 '4 iday of February, 2010 A.D. - ?f Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L. Kist-?r, Notary Public City Of Harrisburg; Dauphin County My Commission Expires Nov. 26, 2011 Member. Pennsylvania Association of Notaries Docket Number: 200&4279 Civil Term Deutsche Sank'Netlonal Trust . Comparry asTruetee for Morgan Stanley ABS Capital . I, Inc. Trust . 2006-HE7, Mortgage Pass Through Certificates, Series 2006-HE7 vs. Mark McConnaughey a/kla Mark Mcconnaughey Suzanne M McCohnaughey aWa Suzanne Mcconnaughey Atty: Michael McKeever ALL THATCERTAIN piece or parcel of land situate in Second Ward'of the Borough of New Cumberland, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described based on a survey by Michael C. D'Angelo, PLS, dated September 25, 1995 and recorded with Deed in Deed Book 150, Page 12, as follows, to wit: BEGINNING at a point on the Northem'line of Eleventh Street, a distance of two hundred fifty- six and fifty-four hundredths (256.54) feet East of the Northeast comer of Bridge and Elevenths Streets and marked with a steel pin; thence North twenty-eight (28) degrees twenty-five (25) minutes thirty-three (33) seconds West sevettty- eight (78) feet along other lands now or formerly of David A. Kndac to a point marked with a steel pin; thence South sixty-one (61) degrees thirty-four (34) minutes twenty-seven (27) seconds West thirty-seven (37) feet along lands now or formerly of Mary A. Krulac to a point marked with a steel pin; thence South twenty- eight (28) degrees twenty-five (25) minutes . thirty-three (33) seconds East seventy-eight (78) feet along lands now or formerly of Gloria Lynn to a point marked with a steel pine; thence along the Northern line of Eleventh Street South sixty- one (61) degrees thirty-four (34) minutes twenty-seven (27) seconds West thirty-seven (37) feet to a point marked with a steel pin and place of BEGINNING. BEING Lot No. 127 in the Plan of Lots called Elkwood, as recorded in Recorder of Deeds Office for Cumberland County in Deed Book "M" Volume 5 , Page 498. BEiNC} M SAME PREDM,SE;S E D (31VRN 11Y Ik; 1lRk?KtYQ4V13.AS 1J?d1Ati A f3Y W R(a831[tf I. QTY ]R., HER HUSkM TO MARK MCCONNAUGHEy ANS SUANNE MCCONNAUGHEY, HIS WIFE AND RECORDED 06115/2006 IN BOOK 275 PAGE 732 INSTRUMENT # 2006-021065. MUNICIPALITY: Borough of New Cumberland 4vING THEREON ERECTED a dwelling known and numbered as 207 Eleventh Street, New Cumberland, PA 17070 TAX PARCEL #: 26-23-0541-266 P]2'JPERTY ADDRESS: 207 11th Street, New Conberland, PA 17070 r ., t he Patriot-Xews Now you know P. O. BOX 2265 HARRISBURG, PA 17105 (717) 255-8237 BILL TO: Cumberland County Sheriff's Office Cumberland County Court House Carlisle, PA 17013 ACCT. # 2260 DUPLICATE BILL Date 01/22/10 Sheriff Sale 01/29/10 Sheriff Sale 02/05/10 Sheriff Sale Notary Fee ption Sale # Size Rate 4279 9.70 $12.00 4279 9.70 $12.00 4279 9.70 $12.00 TOTAL DUE FOR THIS SALE: Of Ad $ 116.40 $ 116.40 $ 116.40 $5.00 $ 354.20 JLC WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-4279 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006- HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 Plaintiff (s) From MARK A. MCCONNAUGHEY A/K/A MARK MCCONNAUGHEY and SUZANNE M. MCCONNAUGHEY A/K/A SUZANNE MCCONNAUGHEY (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: $128,337.16 L.L.: Interest from 9/3/2008 to Dale of Sale per diem at $27.25 Atty's Comm: % Due Prothy: $2.00 Arty Paid: $1,400.89 Other Costs: Plaintiff Paid: Date: 9/15/11 ? Zd L David D. B ell, Prothonotai;v (Sea]) Deputy REQUESTING PARTY: Name: THOMAS PULED, ESQUIRE Address: KML LAW GROUP, P.C. SUITE 5000- BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 27615 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 ri KML Law Group, P.C. Suite 5000 - BNY Independence Center I J s,M I ; c I i .,E 701 Market Street Philadelphia, PA 19106-1532 1y%UtIBERLAND 215-627-1322 _Attorney for Plaintiff ;?1= dSYL? aNIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE IN THE COURT OF COMMON PLEAS PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive of Cumberland County PTX C-35 Piano, TX 75024 CIVIL ACTION - LAW vs. Plaintiff MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Mortgagor(s) and Record Owner(s) 207 Eleventh Street New Cumberland, PA 17070 Defendant(s) TO THE PROTHONOTARY: ACTION OF MORTGAGE FORECLOSURE No. 08-4279 PRAECIPE FOR WRIT OF EXECUTION Issue Writ of Execution in the above matter: 00 0, IaA Lis. 00c6p G? 1 ?p . 00 "Iq .qq t`a ?1?.so ? y. a 0 94.00 94.00 ? 1, ?-??. g ? PA O Interest from 9/3/2008 to Date of Sale per diem at $27.25 Amount Due (Costs to be added) $128,337.16 By Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 avid Fein Pa. ID 82628 homas Puleo Pa. ID 27615 Attorneys for Plaintiff CY 5loSo5$ ¢ a O W Q Q w: N O a O U Ex W ? ? F" a ??x O O¢ a o a 3 W L a0? W?"W 2¢ fW c ?? ?zQ~ xx0? ?.?c.n O d ?U QQEO+w 000 E? o > ¢?¢¢rx acs oO Zcn Za QC¢7F" OzO?w 8 fY a zc?xU U UU U ? U oCu O o 60 CA U Z W P' °? Q o Z U, x F' W w1,0) U Z W xw ¢ `" ? Ln a x ¢ Q?z cn U w 3 ro a p; N 3?. ca cz? ? o. N BOO x o :c a 0 ALL THAT CERTAIN piece or parcel of land situate in Second Ward of the Borough of New Cumberland, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described based on a survey by Michael C. D'Angelo, PLS, dated September 25, 1996 and recorded with Deed in Deed Book 150, Page 12, as follows, to wit: BEGINNING at a point on the Northern line of Eleventh Street, a distance of two hundred fifty-six and fifty-four hundredths (256.54) feet East of the Northeast corner of Bridge and Elevenths Streets and marked with a steel pin; thence North twenty-eight (28) degrees twenty-five (25) minutes thirty-three (33) seconds West seventy-eight (78) feet along other lands now or formerly of David A. Krulac to a point marked with a steel pin; thence South sixty-one (61) degrees thirty-four (34) minutes twenty-seven (27) seconds West thirty-seven (37) feet along lands now or formerly of Mary A. Krulac to a point marked with a steel pin; thence South twenty-eight (28) degrees twenty-five (25) minutes thirty-three (33) seconds East seventy-eight (78) feet along lands now or formerly of Gloria Lynn to a point marked with a steel pine; thence along the Northern line of Eleventh Street South sixty-one (61) degrees thirty-four (34) minutes twenty-seven (27) seconds West thirty-seven (37) feet to a point marked with a steel pin and place of BEGINNING. BEING Lot No. 127 in the Plan of Lots called Elkwood, as recorded in Recorder of Deeds Office for Cumberland County in Deed Book "M" Volume 5, Page 498. MUNICIPALITY: Borough of New Cumberland HAVING THEREON ERECTED a dwelling known and numbered as 207 Eleventh Street, New Cumberland, PA 17070 TAX PARCEL #: 26-23-0541-266 BEING THE SAME PREMISES BY DEED DATED 06/09/2006, GIVEN BY DEBORAH A. IKEHARA, NOW KNOWN AS DEBORAH A. OAKLEY AND ROBERT J. OAKLEY, JR., HER HUSBAND TO MARK MCCONNAUGHEY AND SUZANNE MCCONNAUGHEY, HIS WIFE AND RECORDED 06/15/2006 IN BOOK 275 PAGE 732. IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 NO. 08-4279 Plaintiff = a - - vs. r n rrl MARK ' ? - A. MCCONNAUGHEY a/k/a MARK U ) r, != MCCONNAUGHEY "`' " SUZANNE M. MCCONNAUGHEY aWa SUZANNE ?... MCCONNAUGHEY D Defendant(s) VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief, as follows: 2. That the above named Defendant, MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY, has a last known residence of 207 Eleventh Street, New Cumberland, PA 17070. 3. That inquiry has been made with the Department of Defense as to the military status of each of the Defendants in this action. A copy of the Military Status Report is attached. 4. The Defendant is not in the military service of the United States of America as defined by the Servicemembers Civil Relief Act as amended. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn ation to aut Date: 9/12/2011 By: K LAW GROU , P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Attorneys for Plaintiff I'lep,artrnent of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Sep-12-2011 11:42:44 Last Name First/Middle Begin Date Active Duty Active Duty End Service Status Date Agency MCCONNAUGHEY MARK A. Based on the information you have furnished, the DMDC does not possess any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). )6t Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https://www.dmdc.osd.mil/appj/scra/popreport.do 9/12/2011 Page 2of 2. iffore it f'Ornm60n on ",zictive Duty Status" \cttve duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more trian 30 consecutive days. In the case of a member of the National Guard, includes ser, iIce under a call to active service authorized by the President or the Secretary of Defense for a period of more than 3d0 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARS, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:HJTMPBJ3IG https://www.dmde.osd.mil/appj/scra/popreport.do 9/12/2011 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 NO. 08-4279 c-. Plaintiff _ vs. -n r -`z MARK A. MCCONNAUGHEY a/k/a MARK `-? MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY C-s Defendant(s) c ` VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEME14BERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief, as follows: 2. That the above named Defendant, SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY, has a last known residence of 207 Eleventh Street, New Cumberland, PA 17070. 3. That inquiry has been made with the Department of Defense as to the military status of each of the Defendants in this action. A copy of the Military Status Report is attached. 4. The Defendant is not in the military service of the United States of America as defined by the Servicemembers Civil Relief Act as amended. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn fiaTs-17TNtion to Date: 9/12/2011 By: KIwIJGLAW GROUI? P.C. ?/ Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 /Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gomall Pa. ID 92382 Attorneys for Plaintiff Department of Defense Manpower Data Center Sep-09-2011 10:35:26 Military Status Report Pursuant to the Service Members Civil Relief Act Last Name i FtrstlMiddle Begin Date Active Duty Status 1 Active Duty End Date Se? Agency MCCONNAUGHEY ! SUZANNE M ;Based on the information you have furnished, the DMDC does not possess any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). Amy, A 4 - A?M_ M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the persons status by contacting that person's Service via the "defenselink-mil" URL http://www.defenselinLmiU /pis/PC09SLDR_hW. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, unproved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of-contact. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(I) for a period of more than 30 consecutive davs. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(1) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support This includes Navy TARS, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:B05ON304KM KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. Plaintiff MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY (Mortgagor(s) and Record Owner(s)) 207 Eleventh Street New Cumberland, PA 17070 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 08-4279 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7, Plaintiff in the above action, by counsel, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 207 Eleventh Street New Cumberland, PA 17070 1.Name and address of Owner(s) or Reputed Owner(s): MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 2. Name and address of Defendant(s) in the judgment: MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 IONW OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg. PA 17105-2675 NEW CUMBERLAND BOROUGH 1120 Market Street New Cumberland, PA 17070 NEW CUMBERLAND BOROUGH C/O Andrew C. Sheely, Esquire 127 South Market Street, P.O. Box 95 Mechanicsburg, PA 17055 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 207 Eleventh Street New Cumberland, PA 17070 (attach separate sheet if more space is needed) 1 verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: J By:. KML L GROUP, P. Mic McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff 08-4279 KML Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff E lr?-tJF1i;V tsc OTr001;??c? O;:RL AND O"T" DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006- HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Mortgagor(s) and Record Owner(s) 207 Eleventh Street New Cumberland, PA 17070 Defendant(s) Docket No. 08-4279 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: MCCONNAUGHEY, MARK A. a/k/a MARK MCCONNAUGHEY MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 Your house at 207 Eleventh Street, New Cumberland, PA 17070 is scheduled to be sold at Sheriffs Sale on Wednesday, March 07, 2012, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $128,337.16 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006- HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE To prevent this Sheriffs Sale you must take immediate action: 08-4279 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1- 866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE I . If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadeipwafed.orp,/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue 08-4279 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.g_ov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.qsgx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@kmllaw2roup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 67748FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff ?4` JI f . f gypp-- Y• e{ t E tf { *1' 1 1 ,s DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Mortgagor(s) and Record Owner(s) 207 Eleventh Street New Cumberland, PA 17070 Defendant(s) ?yC ???.... _ IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NO. 08-4279 CERTIFICATION AS TO THE SALE OF REAL PROPERTY Plaintiff, by counsel, hereby certifies that it has complied with the provisions of Act 91 of 1983 and/or the real property in question is not subject to the Act. By KM AW GRO , P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 9avid Fein Pa. ID 82628 homas Puleo Pa. ID 27615 Attorneys for Plaintiff SHkRIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor r'. J?1 16(ERL Deutsche Bank National Trust Company as Trustee vs. Mark McConnaughey (et al.) Case Number 2008-4279 SHERIFF'S RETURN OF SERVICE 03/21/2012 10:27 AM - Deputy Tim Black, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 207 11th Street, New Cumberland Borough, New Cumberland, PA 17070, Cumberlanc County. 03/27/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Suzanne M McConnaughey, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 207 11th Street, New Cumberland Borough, New Cumberland, PA 17070. The residence appears to be vacant and per the New Cumberland Postmaster the defendant has moved and left no forwarding address. 03/27/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Mark McConnaughey, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 207 11th Street, New Cumberland Borough, New Cumberland, PA 17070. The residence appears to be vacant and per the New Cumberland Postmaster the defendant has moved and left no forwarding address. 04/26/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $550.37 SO ANSWERS, May 25, 2012 RON R ANDERSON, SHERIFF v .L KML Law Gro p, P.Q. Suite 5000 - BN 'y Independence center 701 Market Street x,19106-1532 Philadelphia, 215-627-132 Attorney for 10inttff BANK NATIONAL TRUST DEUTSCBE ? FOR COMPANY AS TRU TO INC TORU SST 2006-PE7 STANLEY- S CAP PASS THROUGH CERTIFICATES, M ANLEY cF, -- SERIF S 2006-M7 7105 C01701te Drive PTX C-35 Plano, TX 15024 plaintiff vs. ON PLEAS COURT OF COMMON =t IN THE of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE MARK A. CCONNAUGHEy aWa MARK No. 08-4279 MCCO )UGHEY AUGHEy aWa SUZANNF- SUZANNE M. MCCONN MCCO UGHEY (Mortga r(s) and Record Owner(s)) 207 Elev to Street 17070 New Cut$tlb Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 OR MORGAN STANLEY ABS UST COMPANY AS TRUSTEE F S 2006-HE7 plaintiff in the SCHE BANK NATIONAL TRUST CATES, SERIF date the praecipe for the writ of execution was filed the EUT INC TRUST 2006-HE7 MORTGAGE PASS THROUGH Cthepra IT I, u P.C., sets forth as of the CAP counsel, KML Law Gro p, above a tion, by real property located at: followi glinformationconcerning the 207 Eleventh Street New Cumberland, PA 17070 uted Owner(s): 1.Nam end address of Owner(s) or Rep a MARK MCCONNAUGHEY MARK A. MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 MCCONNAUGHE Y M. MCCONNAUGHEZ' a/k/a SUZANNE SUZANNE 207 Eleventh Street New Cumberland, PA 17070 and address of Defendant(s) in the judgment: 2 NA. MCCONNAUGHEY aWa MARK MCCONNAUGHEY MARK 207 Eleventh Street New Cumberland, PA 17070 SUZANNE M. MCCONNAUGHEY afk/a SUZANNE MCCONI•TAUGHEY 207 Eleventh Street New Cumberland, PA 17070 e 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 NEW CUMBERLAND BOROUGH 1120 Market Street New Cumberland, PA 17070 NEW CUMBERLAND BOROUGH C/O Andrew C. Sheely, Esquire 127 South Market Street, P.O. Box 95 Mechanicsburg, PA 17055 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 207 Eleventh Street 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 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: C 13 L By: ;AV L GROUP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristin Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Ann E. Swartz Pa. ID 201926 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff a 08-4279 EML Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-825,6318 for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006- HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, 'T'X 75024 IN THE COURT OF COMMON PLEAS Plaintiff vs. MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Mortgogor(s) and Record Owner(s) 207 Eleventh Street New Cumberland, PA 17070 Defendant(s' , of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 0811279 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: MCCONNAUGHEY, MARK A. a/k/a MARK MCCONNAUGHEY MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 Your house at 207 Eleventh Street, New Cumberland, PA 17070 is scheduled to be sold at Sheriff s'I Sale on Wednesday, June 06, 2012, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $128,337.16 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006- HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 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: i 08-4279 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7, 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- 866-413L231 1. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). 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.orgjforeclosure/ 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 COUN'T'Y BAR ASSOCIATION } 08-4279 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: ftww phfa org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free, number at 1-866-413-2311 or via email at homer?tention@kmllawgroui).com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 67748FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ALL THAT CERTAIN piece or parcel of land situate in Second Ward of the Borough of New Cumberland, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described based on a survey by Michael C. D'Angelo, PLS, dated September 25, 1996 and recorded with Deed in Deed Book 150, Page 12, as follows, to wit: BEGINNING at a point on the Northern line of Eleventh Street, a distance of two hundred fifty-six and fifty-four hundredths (256.54) feet East of the Northeast corner of Bridge and Elevenths Streets and marked with a steel pin; thence North twenty-eight (28) degrees twenty-five (25) minutes thirty-three (33) seconds West seventy-eight (78) feet along Other lands now or formerly of David A. Krulac to a point marked with a steel pin; thence''South sixty-one (61) degrees thirty-four (34) minutes twenty-seven (27) seconds West thirty-seven (37) feet along lands now or formerly of Mary A. Krulac to a point marked with a steel pin; thence South twenty-eight (28) degrees twenty-five (25) minutes thirty-three (33) seconds East seventy-eight (78) feet along lands now or formerly of Gloria Lynn to a point marked with a steel pine; thence along the Northern line of Eleventh Street South sixty-one (61) degrees thirty-four (34) minutes twenty-seven (27) seconds West thirty-seven (37) feet to a point marked with a steel pin and place of BEGINNING. BEING Lot No. 127 in the Plan of Lots called Elkwood, as recorded in Recorder of Deeds Office for Cumberland County in Deed Book "M" Volume 5, Page 498. MUNICIPALITY: Borough of New Cumberland HAVING THEREON ERECTED a dwelling known and numbered as 207 Eleventh Street, New Cumberland, PA 17070 TAX PARCEL #: 26-23-0541-266 BEING THE SAME PREMISES BY DEED DATED 06/09/2006, GIVEN BY DEBORAH A. IKEHARA, NOW KNOWN AS DEBORAH A. OAKLEY AND ROBERT J. OAKLEY, JR., HER HUSBAND TO MARK MCCONNAUGHEY AND SUZANNE MCCONNAUGHEY, HIS WIFE AND RECORDED 06/15/2006 IN BOOK 275 PAGE 732. r 08-4279 ICAL Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006- HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive M C+35 Plano, TX 75024 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. MARKA. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Mortgagor(s) and Record Owner(s) 207 Eleventh Street New Cumberland, PA 17070 Defendant(s, CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 08-4279 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: MCCONNAUGHEY, SUZANNE M. aWa SUZANNE MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY alkla SUZANNE MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 Your house at 207 Eleventh Street, New Cumberland, PA 17070 is scheduled to be sold at Sheriffs $ale on Wednesday, June 06, 2012, at 10:00 AM, in Commissioners Hearing Rm. 2nd FL Courthouse to enforce the court judgment of $128,337.16 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006- HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 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: J 08-4279 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7, 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 hate of stopping the sale. (See notice below on how to obtain an attorney). 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property! as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. 'You may contact the Foreclosure Resource Center: hqp://www.philadelphiafed-org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 08-4279 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:ftww.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homer tention@kmllaw rou .com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. he 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 firr:h'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 67748FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. s ALL THAT CERTAIN piece or parcel of land situate in Second Ward of the Borough of New Cumberland, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described based on a survey by Michael C. D'Angelo, PLS, dated September 25, 1996 and recorded with Deed in Deed Book 150, Page 12, as follows, to wit: BEGINNING at a point on the Northern line of Eleventh Street, a distance of two hundred fifty-six and fifty-four hundredths (256.54) feet East of the Northeast corner of Bridge' and Elevenths Streets and marked with a steel pin; thence North twenty-eight (28) degrees twenty-five (25) minutes thirty-three (33) seconds West seventy-eight (78) feet along other lands now or formerly of David A. Krulac to a point marked with a steel pin; thence 'South sixty-one (61) degrees thirty-four (34) minutes twenty-seven (27) seconds West thirty-seven (37) feet along lands now or formerly of Mary A. Krulac to a point marked with a steel pin; thence South twenty-eight (28) degrees twenty-five (25) minutes thirty-three (33) seconds East seventy-eight (78) feet along lands now or formerly of Gloria Lynn to a point marked with a steel pine; thence along the Northern line of Eleventh Street South sixty-one (61) degrees thirty-four (34) minutes twenty-seven (27) seconds West thirty-seven (37) feet to a point marked with a steel pin and place of BEGINNING. BEING Lot No. 127 in the Plan of Lots called Elkwood, as recorded in Recorder of Deeds Office for Cumberland County in Deed Book "M" Volume 5, Page 498. MUNICIPALITY: Borough of New Cumberland HAVING THEREON ERECTED a dwelling known and numbered as 207 Eleventh Street, New Cumberland, PA 17070 TAX PARCEL #: 26-23-0541-266 BEINGjTHE SAME PREMISES BY DEED DATED 06/09/2006, GIVEN BY DEBORAH A. IKEHARA, NOW KNOWN AS DEBORAH A. OAKLEY AND ROBERT J. OAKLEY, JR., HER HUSBAND TO MARK MCCONNAUGHEY AND SUZANNE MCCONNAUGHEY, HIS WIFE AND RECORDED 06/15/2006 IN BOOK 275 PAGE 732. WRIT OF'EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N008-4279 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 Plaintiff (s) From MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY and SUZANNE M. MCCONINAUGHEY a/k/a SUZANNE MCCONNAUGHEY (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: $128,337.16 L. L.: Interest FROM 9/3/2008 TO DATE OF SALE PER DIEM AT $27.25 Atty's Comm: % Atty Paid: $1,518.73 Plaintiff Paid: Date: DECEMBER 15, 2011 (Seal) Due Prothy: $2.00 Other Costs: David D. Buell, Prothonotary By: REQUESTING PARTY: Name: MICHAEL MCKEEVER, ESQUIRE KML LAW GROUP, P.C. Address: SUITE 5000 - BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Attorney For: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 Deputy TRUE COPY FROM RECORD In TeetknwW whe eof, I heh urdo set my hwW and do teal of srd at Carlisle, Pa. Tt" 15 d" of JJ- `-e?,lCP Q, f4a'°a1Yj?/ 0 On February 1, 2012 the Sheriff levied upon the defendant's interest in the real property situated in the Borough of New Cumberland, Cumberland County, PA, known and numbered as 207 Eleventh Street, New Cumberland, PA, 17070, more fully described on Exhibit"A" filed with this writ and by this reference incorporated herein. Date: January 30, 2012 By: For Claudia Brewbaker, Real Estate Coordinator brfit! YA! f i sa1a1?C .ti 4iS 1 ftF? aJ 4(i3EH"9 fir?' 2} (3 Writ No. 2008-4279 Civil Term Deutsche Bank National Trust Company as Trustee for Morgan Stanley ABS Capital I, Inc Trust 2006-HE7 Mortgage Pass Through Certificates, Series 2006-HE7 vs. Mark A. McConnaughey a/k/a Mark McConnaughey, Suzanne M. McConnaughey a/k/a Suzanne McConnaughey Atty.: Michael McKeever IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 207 Eleventh Street, New Cumberland, PA 17070 SOLD as the property of MARK A. McCONNAUGHEY a/k/a MARK McCONNAUGHEY and SUZANNE M. McCONNAUGHEY a/k/a SUZANNE McCONNAUGHEY. TAX PARCEL #26-23-0541-266. .. , , . PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 Lis Marie Coyne, Edit SWORN TO AND SUBSCRIBED before me this 27 day of April, 2012 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 CO*MONiWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. Lis* Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz April 27, 2012 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 las to time, place and character of publication are true. Qe Patriot-Dews Co. 020 Technology Pkwy Suite 300 :Mechanicsburg, PA 17050 Inquiries - 717-255-13213 CUMBERLAND CO SHERIFF OFF!CE CUMBERLAND COUNTY Co;, !-?T 110USE ZhePatriot-1ew$ Now you know CARLISLE P/, 17013 THE PATRIOT NEWS ME SUNDAY PATRIOT NEWS Proof of Publication un;jer Act No. 587. Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Hoily Blain, being duly sworn accord, ,g to law. deposes and says: That she is a Staff Accountant of Th,; Patriot News Co.. a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its pnn::!pal office and place of business at 2020 Technology Pkwy, Suite 300, in the l ownship of Hampden. County of Cumberlar (1, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulati )n. printed and published at 1900 Patriot Drive, in the City, County and State aforesaid, that The Patriot-News and The Sunday Patriot-News were established March 4th. 1854, and September 18th, 1949 respectively, and all have been continuously oublished ever since, That the printed notice or publication which is securely attached hereto is exactly as printed and published in their reguiar daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter c f 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 sa d 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. ' This ad ran on the date(s) shown below: 200&4279 Chill Term Deutsche Bank Natlgnal T1vst 04/27112 Company as Trustee for Morgan Stanley ABS Capital I, Inc Trust 2006-HE7 Mortgage Pass Through CertRlcates, Series 2006-HE7 VS Mark A. McConnaughey a/k/a Mark McConnaughey Swcrn to and subscribed bef me this 22 day of May, 2012 A.D. Suzanne M. McConnaughey a/k/a Suzanne McConnaughey Atty: Michael McKeever ---- - IMPROVEMEN7'Sconsist of a residential Notary Public dwelling. BEING PREMISES: 207 Eleventh Street New Cumberland, PA 17070 SOLD as the property of MARK A. CCONNAUGHEY a/k/a MARK °t N OF PENNSYLVANIA CCONNAUGHEY and SUZANNE M. Notarial seal .M000NNAUGHEY a/k/a SUZANNE Sherrie L. Owens: Notary Public MCCONNAUGHEY Lowwr Paxton Twp., Dauphin County TAX PARCEL #26-23-0541-266 ?, MY Commission Expires Nov. 26, 2015 MEMB" ER PENNSYLVANIA ASSO CIAITON OF NOTARIES WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 08-4279 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPTTAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 Plaintiff (s) From MARK. A MCCONNAUGHEY A/K/A MARK MCCONNAUGHEY, SUZANNE M. MCCONNAUGHEY A/K/A SUZANNE MCCONNAUGHEY (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 helshe has been added as a garnishee and is enjoined as above stated. Amount Due: $128,337.16 L.L.: Interest FROM 9/3/2008 TO DATE OF SALE PER DIEM AT $27.25 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $2,097.60 Other Costs: Plaintiff Paid: Date: 8/21/2012 J~ ~ ' ~ ~ LLI:.r/`..~ ~e David DX. •Bu~ell, Prothonotary (Seal) Deputy REQUEST.'NG PARTY: Name: DAVID FIEN, ESQUIRE Address: KML LAW GROUP, P.C. SUITE 5000-BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 82628 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 31$0-3183 -c~ -~- w KML Law Group, P.C. Z Suite 5000 - BNY Independence Center ~ r-~- 701 Market Street ~ Philadelphia, PA 19106-1532 CCU 215-627-1322 ry Attnrnev fir Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Mortgagor(s) and Record Owner(s) 207 Eleventh Street New Cumberland, PA 17070 Defendant(s) TO THE PROTHONOTARY: --~ --~ IN THE COURT OF COMMON P] of Cumberland County CNIL ACTION -LAW ACTION OF MORTGAGE No. 08-4279 PRAECIPE FOR WRIT OF EXECUTION Issue Writ of Execution in the above matter: OIM~t~~' ~ ~ F~ ys.oo ~ I(,.oo «« i?9.95 "" ~~, 5 yy «, R3.SN"" SSo. 37 "~ r~ ~~ ~ y. b fU 1/ N `` a4. u ~~ ~y, (~C~ cc~~ . ,~ ~y~ ~ ~~~~ ma,~ Interest from 9/3/2008 to Date of Sale per diem at $27.25 Amount Due (Costs to be added) $128,337.16 . By: ie " KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 sting Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 ~ ~.,e15 attorneys for PlaintiR P,~B N -{~~ ~. ~-~~ ~ ice:.. G'3 ~ ~ rx ~~ "-- --tc~ '0 O ~' ~ = _~~ ~~ ~iB~Po rza a~9(oya ~ ~ ~n~- o~~.Lssued ~ a'-' x z~zQ~ v~ Q~O x aacsw rx N p W.7 pUE"W ~ ~ ~ Ey p ~~ag ~ ~~ ~ o W ~~ ~~~ ~w~~ o~'a w, o~ow Z~~~ ~ O~Qd~ ~ ~ O~ ~p O O~„ ' Z~~~ ~ ~~ ~ Z~ ¢~~~ p0©~ ~~ ~ ~ V x~~-+~U ~,~~.,~~ ~N o3i of E'' ~fi'r~nU ~ ~ "~ W 7. d ~~U ~ W ~ ~ `~ A U 3 ~» c M y ~ U ~ ... ~ ~ CL ~ b ~a O 4 r~ ~` r; ~ Q ... :. 3y.~ b qtpS ~ ~~. 7 ~ O Q. N «~i SI ~ ~ O ~ `~ F «; .~ cn ALL THAT CERTAIN piece or parcel of land situate in Second Ward of the Borough of New Cumberland, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described based on a survey by Michael C. D'Angelo, PLS, dated September 25, 1996 and recorded with Deed in Deed Book 1 S0, Page 12, as follows, to wit: BEGINNING at a point on the Northern line of Eleventh Street, a distance of two hundred fifty-six and fifty-four hundredths (256.54) feet East of the Northeast corner of Bridge and Elevenths Streets and marked with a steel pin; thence North twenty-eight (28) degrees twenty-five (25) minutes thirty-three (33) seconds West seventy-eight (78) feet along other lands now or formerly of David A. Krulac to a point marked with a steel pin; thence South sixty-one (61) degrees thirty-four (34) minutes twenty-seven (27) seconds West thirty-seven (37) feet along lands now or formerly of Mary A. Krulac to a point marked with a-steel pin; thence South twenty-eight (28) degrees twenty-five. (25) minutes thirty-three (33) seconds East seventy-eight (78) feet along lands now or formerly of Gloria Lynn to a point marked with a steel pine; thence along the Northern line of Eleventh Street South sixty-one (61) degrees thirty-four (34) minutes twenty-seven (27) seconds West thirty-seven (37) feet to a point marked with a steel pin and place of BEGINNING. BEING Lot No. 127 in the Plan of Lots called Elkwood, as recorded in Recorder of Deeds Office for Cumberland County in Deed Book "M" Volume 5, Page 498. MUNICIPALITY: Borough of New Cumberland HAVING THEREON ERECTED a dwelling known and numbered as 207 Eleventh Street, New Cumberland, PA 17070 TAX PARCEL#: 26-23-0541-266 BEING THE SAME PREMISES BY DEED DATED 06/09/2006, GIVEN BY DEBORAH A. IKEHARA, NOW KNOWN AS DEBORAH A. OAKLEY AND ROBERT J. OAKLEY, JR., HER HUSBAND TO MARK MCCONNAUGHEY AND SUZANNE MCCONNAUGHEY, HIS WIFE AND RECORDED 06/15/2006 IN BOOK 275 PAGE 732. KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Mazket Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPAN~~"S'~ Y TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Mortgagor(s) and Record Owner(s) 207 Eleventh Street New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSUR N0.08-4279 CERTIFICATION AS TO THE SALE OF REAL PROPERTY Plaintiff, by counsel, hereby certifies that it has complied with the provisions of Act 91 of 1983 and/or property in question is not subject to the Act. /- By: KML L GROUP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 ~lsavid Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff ~~' ~~~~~' ~ NONt~TA~1° ~~~~ a~~ Z' ~~ C~ ~ ~ Q real IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 Plaintiff vs. N0.08-4279 r.~ C ° N ~~ ~f"" N ~ ~ .... ~~ ~ ~r" C7 ~ 2C7 G -'~ MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Defendant(s) RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the --t ~~ 'L3~ :t3 C3~i -^1 Q ~ -~'t tJ "+"'i Z ~.:y Q frl ~' ~: in the above entitled matter, does hereby state to the best of his/her information and belief, as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") operated by the United States Department of Defense (httns://www.dmdc.osd.miVappj/scra/scraHome for the following individual(s): MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY, a last known residence of 332 Summit Avenue, Raleigh, NC 27603. The following information was t to search the DMDC (check all that apply): X Last Name X First Name X Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the provided, the DMDC does not possess any information indicating that the individual is on active or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 C.S.A. 4904 relating to unsworn falsification to authorities. Date ~ / 7 By: ' KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 ~~avid Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff Department of Defense Manpower Data Center ~7t8L1i~1 RViC F-ir~u~ctt t4 ~erv~cememb,~rs civil. Relief ~~~ Last Name: MCCONNAUGHEY First Name: MARK Middle Name: Active Duty Status As Of: Aug-17-2012 Results as of : Aua-17-201209:28:33 SCRA 2.3 Ort Active.Dtdy On nrJva Duly Stalin Dale Active Quty Start Date Active Duty End Date Stalin Service Component NA NA No NA This response reflects ilia ndividuels' active duty stahn based on the Arrive Dory Status Date LeR Active Duty Wghin 387 Days of Alive Duty SlaRra Date Active Duty Start Date Active Duty EM Date Status Service Component NA NA No NA This response reflects wfiere Cre irdividual left crave duly status wlhfn 367 days preceding the Active Duty Status Date The tAernber or HislFier Untt Was iJoalied d a future CNNJp b Adnro Duty on Adlve tARy StaWS Dete On1er Notification Sian Dale Order Notlfladirn End Dab Stahu Service Component NA NA No NA This response reflects wheMer the udi.idual or hislher unit has received eery norilFraaon b report for active duly Upon searching the data banks of the Department of Defense Manpower Data Carder, based on the information that you provided, the above is th status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Heath, and Coast Guard). This status includes information on a Servicemember or hislher unit receiving notification of future orders to report for Active Duty. ~,.~ „cr.~,-~. Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 ' ~ The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly kno n as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that th individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any f mily member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entiU to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.miUfaq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty s atus date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 52 (c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual le Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for dive duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty peri s less than 30 consecutive days in length were available. In the case of a member of the National Guard, this inGudes service under a call to active servi e authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by th President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization positio in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard serve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the .S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would of be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services rinds. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of rvice. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who h ve not actually begun active duty or actually reported for induction. The last Date on Active Duty entry is important because a number of protections oft SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. erroneous information will cause an en'oneous certificete to be provided. Certificate ID: NOUQJKEK6D r- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 Plaintiff vs. MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Defendant(s) C'7 p G r-a~ ~~ ~E` N ~y .... Z 0 ~'C"'C~ 3 ZO ~~ --~ ~ ""'" N0.08-4279 RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the the above entitled matter, does hereby state to the best of his/her information and belief, as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") operated by the United States Department of Defense (htt~s://www.dmdc.osd.miUappt/scra/ for the following individual(s): SUZANNE M. MCCONNAUGHEY a1k/a MCCONNAUGHEY, has a last known residence of 207 Eleventh Street, New Cumberland, PA 1 The following information was used to search the DMDC (check all that apply): X Last Name X First Name X Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the provided, the DMDC does not possess any information indicating that the individual is on active has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 C.S.A. 4904 relating to unsworn falsification to authorities. Date O / 7 ~°1' gy: KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 KJdstina Murtha Pa. ID 61858 /David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff -.-t r~~"t~ -.~ Obi -~~+ p~*t C`+ C'S'I p' ..,-. in or Department of Defense Manpower Data Center ~ Military Status Report Sep-09-~O1 l 10:35:26 Pursuant to the Service Members Crnl Relief Act ~ Last Name FT~e $egin Dnte ' Active Iimty Status Active Doty End Dt~ Service ~be~' MCCONNALIGHFY SUZANNE M Based on the information you have famished, the DMDC does not possess any information indicating the mdi ~ status. Upon searching the information data banks of the Department of Defense Manpower Data Center,. based on the information that you provided, the above i the current status of the individual as to all branches of the Uniformed Services (Army, Navy,: Marine Corps, Air Frnre, NOAA, Public Health, and Coast Guard).;. ~ ~~ Mary M. Snavely-Dixon, Direc-tar Department of Defense -Manpower Data Center 1600 Wilson Blvd, Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is art organization of the Deparhnent of Defense that maintains the.Defense Enrollment and Eligibility System (DEERS) database which is the official source of data on eligtbilty for military medical care and other eligrbr7ity systems. The DoD strongly supports the enforcement of tbe Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) {SCRA) (formerly kno as the 'Soldiers' and Sailors' Civil Relief Actof 1940). DMDC has issued htutdreds of thousaatdsof "does not possess any infosmagion indicating thatthe individual cun~ently on active duty" responses, and has experienced a smal l error rate. In the event the individual refeteneed above, or any family member, friend, or representative sorts in any manner that the individual is on active duty, or isotherwise entitled to the protections of the SCRA, you are slrongty encouraged to obtain ftatlter verificatio of the person's status by contacting flat person's Service via tbe "defenselinkmil" URL http.~!www.defenselink.rnil;'fag;pi~P(09SLDILhtmt. If you lave evidence a pen~art is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked. against you See SO USC App. §5 1(c). Tf you obtain additional information about the person (e.g, an SSN, improved accuracy of DOB, a middle name), you can submityour request against this eb site and we will provide a new certificate'for that query.. This response reflects active duty. status irrchrding date the individual was last on active duty, if itwas within the preceding 367 days. For historical info 'on, please contact the Service SCRA points:-of-contact. More information on "Active Daty Status" Active duty status as reported in this certificate is defined in accordance with. l0 USC § i01(dxl) fora period of more than 30 consecutive days. In the of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more 30 consecutive days under 32 USC § 502(f) for purposes of responding to a stational emergency declared by the President and supported by Federal funds. Al Active Guard Reserve. (AGR) members mast be assigned against an authorized mobilisation position in tbe unit they support: This inchrdes Navy TARS, Marine C ARs and .Coast Guard RPAs. Active Duty status'also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health ,ice. or the National Oceanic and Atmospheric Administration (NOAH Commissioned Gorps) for a period of more than 30 consecutive. days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be rted as on Active Duty under this certificate. -Many times orders are amended to extend the period of active duty, which would extend SCRA protections: Persons seeking to rely on this website certifi on should check to make sure the orders on which SCRA protections are based have sot been amended to extorter the inclusive dates of service. Furthermore, some p otectrons of the SERA may extend to persons who lave received ostlers to report foractive duty onto be inducted, but who have not actually begun active duty or lIy tepor#etl for induction.. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty..... Those who woukl rely on this certifirdoe are urgeu to seek qualified legal counsel to ensure flat all rights guaranteed to Service members under the SERA protected WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erron us certificate to be provided Report 1D:BOSON304ICM KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff f~.~D-f3~F~tE ~,~•~ ~ ~i~ PR!JTHQN~~`A~`1` Z~~2 ~~~ ~ ~ ~~ ~ ~ ~ ~ DEUTSCHE BANK NATIONAL TRUST PENS COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY (Mortgagor(s) and Record Owner(s)) 207 Eleventh Street New Cumberland, PA 17070 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 08-4279 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPTfAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7, Plainti f in the above action, by counsel, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was fi ed the following information concerning the real property located at: 207 Eleventh Street New Cumberland, PA 17070 1.Name and address of Owner(s) or Reputed Owner(s): MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY 332 Summit Avenue Raleigh, NC 27603 SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 2. Name and address of Defendant(s) in the judgment: MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY 332 Summit Avenue Raleigh, NC 27603 IN THE COURT OF COMMON of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE -Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 NEW CUMBERLAND BOROUGH 1120 Market Street POB 220 New Cumberland, PA 17070 NEW CUMBERLAND BOROUGH 1120 Market Street New Cumberland, PA 17070 NEW CUMBERLAND BOROUGH GO Andrew C. Sheely, Esquire 127 South Market Street, P.O. Box 95 Mechanicsburg, PA 17055 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 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 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 may be affected by the sale. TENANTS/OCCUPANTS 207 Eleventh Street New Cumberland, PA 17070 I verify that the statements made in this affidavit are true and correct to the best of my information and understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to falsification to authorities. DATED: / ~J By: ~~ KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 ~(~avid Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff 08-4279 K1V1I, Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 (215)627-1322 Attorney for Plaintiff ;.,. ~~~ ~'RQTM ~Q~ ~'A~'r' ~~rZ AUG 2 r ~~ rr: r r ~~ p~Rt AhID Ct~UNr~ DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006- HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Mortgagor(s) and Record Owner(s) 207 Eleventh Street New Cumberland, PA 17070 Defendants; of Cumberland County CTVII. ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 08-4279 THIS LAW FIRM LS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THLS 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: MCCONNAUGHEY, SUZANNE M. a/k/a SUZANNE MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGNEY 207 Eleventh Street New Cumberland, PA 17070 Your house at 207 Eleventh Street, New Cumberland, PA 17070 is scheduled to be sold at Sheriffs Sale on Wednesday, December O5, 2012, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $128,337.16 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006- HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS To prevent this Sheriffs Sale you must take immediate action: 08-4279 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7, the back payments, late chazges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1- 866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a shaze of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) aze filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.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 Cazlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Cazlisle, PA 17013 08-4279 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or . 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 67748FC. Para informacion en espanol puede communicarse con Loretta x1215-825-6344. KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff ~~ ~ r~`~ ~~ ~~ z~ i 2 DEC - ~ APB ia: ~ a ~~'3~~~f'~..A~'1~ ~~Ni'Y ~CN~VSY~Vi~NI~, DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006- HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY and SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY No. 08-4279 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. MOTION FOR SUBSTITUTED SERVICE UNDER PA.R.C.P. 430(a) Plaintiff, by and through its attorney, in support of its Motion for Substituted Service, represents as follows: 1. Plaintiff is the holder of a mortgage upon the premises 207 Eleventh Street, New Cumberland, PA, 17070, hereinafter, the "mortgaged premises". 2. Defendants, MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY and SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY, are the mortgagors and real owners of the mortgaged premises. 3. Pursuant to Cumberland County Local Rule 208.3(ax2) and/or Rule 208.3(a)(9), I, Alyk Oflazian, Esquire, hereby certify that no judge has ruled on any other matters in this case. I further certify that I am not aware that the Defendant has obtained counsel. Moreover, due to the nature of this motion, it was not possible to locate or contact the Defendant to request her concurrence. 4. The last known address of Defendant, Suzanne M. McConnaughey a!k/a Suzanne McConnaughey, is 541 Bridge Street, Apt. A, New Cumberland, PA l 7070, from our investigative search. The Sheriff has been unable to effect service of the Notice of Sale upon Defendant, Suzanne M. McConnaughey a/k/a Suzanne McConnaughey, at the mortgage premises, 207 Eleventh Street, New Cumberland, PA, 17070. The Sheriff's return states the property is vacant. Service as to 541 Bridge Street, Apt. A, New Cumberland, PA 17070, states the Defendant does not reside at the address given, per resident Mr. Carbello. 6. The following investigation was conducted in a good faith attempt to ascertain the whereabouts of Defendant, Suzanne M. McConnaughey a/k/a Suzanne McConnaughey. WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff to serve the Notice of Sale upon Defendant, Suzanne M. McConnaughey a/k/a Suzanne McConnaughey, by posting the premises and certified and regular mail to the Defendant's last known address. By. ~ ~ - KML AW GR , P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Ji~-P. Jenkins Pa. ID 306588 /Alyk Oflazian Pa. ID 312912 Attorneys for Plaintiff - ._ ~t~t Good Fa~l1 lmnat#~orr f1t the request of the taw firm identified bebw I initi~ifed air invert i~ t*~ Whersa~bours of fhe defendant identt~ed ' a5 the subject betov~r. 7h~ fallowing is truearlii:accvr~te -`epreSert~ttut+, of my investigation.. [~i~ertt~fdrt:'°Fi1e htumber. 67748F~ j ,,, Attoineyt3.aw Firm: KA~It 1~1W GRCIUP, P.G SubttVar'ne: SU~.i11VEM. MCC~NNAUGHEYa/k/a SU7.4NNFMGCt7NfVAUGHEY Property Address:.Street: 207 Ete~enth Street City: Mew Cumberland State: PA Zp; 17070 ~~" ~7ate` bf 8iitti';~ t}S11 x'1969 ProVest t=ile Nurtti~er: 343770 l.asf ttrtowo Address (as of 11129/2012) Street: 207 11Th St city: YJew Cumber)an¢ state; PA ~Q 17oro 1ti18 i r a Dew .'_ of 1Q~1 eS~~ty,Aud-'rriistratlorrhas na death record anfil" ~ ~~ oe l r Suzane nnalh o Y ~~. . Verifl~d'( ',.,,.4t 1letiEg 14f~X~CBT ~ ~ ~ , n ~ ~ : in~r~ ~~ t~ lte gt ~ i~E _ . . ~1 No Ve ~eat~ records ttflxu~. ~ !rlgtlt~y Tti~ latest " t'ettr~~from Etta c~ledil lt~'1r•~fp ore's: . Addressl. 20'7 11"I'H ST, N1=V1i CUiUtS~LANtJ, PA 17070 1618 - Address2: 541 BRlt7GE:ST APT A, t~V1i GU!lllt~R#A~i3, PA-1Tii7f]~;1983 . . ` ,~ Unable to o[ilatn Motor Vehicle Records tit; a St>iife of Perinsytva:iia. No current records found. _ t'?. .. ., . _ . .- ~utriasifi,~prd~#txusd. ..:.._ e Fulad .; ;fpt ., a ` ress~isw~re 1ent,lo~t(1 . Slates Po~i~ at r .'° M * 7J~,1, With r@~Uiil U!I`t?r~1'1~tlQrt t0 El~f~B' 0.. ;, t~ X~ f ~ ' = p l ~ 97 ~tr Vi b2 t RA~V . N , ~~ J P ~: S S ~P 1 ~lL ' = j ' BC 1 A I23 K ~ ~i tlN . 1 P~-gvx~~~ ~I'QRTLOut! r~z j Vl~N ~~T ~ Nt/'VV C~R(.~IfV©~ PA ~ ~ f);} ~U~l18~RLIA~iiQ t~AUAtTY ` 4 on ,;~~ nc>,t ieaVe A ~ vvl'tfiirt ttte ~#qst ~ d~y~; {~a riot ~ ~ r ' _ (Va phone' tts s found fot pdssible r~atives. 717,T1209~2'.C3f~ faossible nei~httrir,°H 1~Yars~er, alad'~t~ a . ,~ ,. '~iyst~'e~ Corrttt'reir~ 71'T- 423 .Cal _ ` riurrd~r A `de!' artf, Suz - .. and found tfie number tb be disoonrlected. 717-774-350: CaAed number ksted to defendant, Suzette hA'M~Contxat%ghey,. _ an#>fot~nd ~e number to tie dish. ' Data nod a ie Al aR ra H~ NH rv~ vs v we +• cn.,.,.~,~sc d ~ in ~n nc In ~~ Irv ~ . un ^ra u~, ~ uu .~e. r.. ..~. + U~ta aveNeDle in CO, CT, OE, fL, iP, IL. KY, 111. ME, liAO. MA, MI, MN, t~t5. Mt3, NH, NA flH, SC. TN; TX, NN; IMt, WY. °~ F °~i .. .. ..:. k g The frxegoinp t is_ and correct. I unders~nd thatfa~se st;dements hereto $u6jeCt:la the penaeiee of'1t! Pg,C.S.A. §49Dd relate' ~ ut-5vyorrt `lion to rider penslGes of pprfury, ! de~are That I have r~Nkx~drly'affidavrt and that the facts st8t®d In fi ere true, STATE OFFlOR1DA ~~~ ~ ~y 2~~ .` CO!)NTY OF HILLSBOft4UGH e~ Jo Scott Pro ~ Fie ber.'3437370 Sworn fo a afTamed and sighed befara me on this „_ day (seal} ~ ~_--..' oats. t~ ... ~~ Aky L.dlvfrFlo. ~ 97 ~ ~~ $ISlnabure o Pup ~o ~ ~ Prinked Naate of Notary PubNc ,~PeraCtlalty Ktrowrn. ~ }Produced. as Identification Oct. 4. 2012 12:30PM Cumberland County Sherrlf No. 3207 P. 2 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sherifff I~IE Ot 41ih1bT~f ~O" J~/d Jody S Smith ty f D Chi ~{ ' "`' 1 epu e Richard W Stewart ~ ~ ' ~` ~` Solicitor ~FFiGB 4F THE SHERIFF Deutsche Bank National Trust Company Case Number vs. 2009-4279 Mark McConnaughey (et a1.) SHERIFF'S RETURN OF SERVICE. 03/21/2012 1027 AM -Deputy Tim Black, being duly sworn according to law, states service was performed by gosling a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 207 11th Street, New Cumberland Borough, New Cumbe~daiad~PA._]~~ --- ~'Ciimberlarid Ctsunfy ~ - ~- . J J 03127 2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Suzanne M McConnaughey, but was unable to locate the Defendant in his bailiwick_ He therefore returns the within Real Estate Writ, Notice and Description, in the ~~ above litied action, as Not Found" at 207 11th Street, New Cumberland Borough, New Cumberland, PA 17070, The residence appears to be vacant and per the New Cumberland Postmaster the defendant has moved and left no forwarding address. 03/27/2 y R n e . o en tng u sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Mark McConnaughey, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ. Notice and Description, in the above titled action, as "Not Found" at 20711th Street, New Cumberland Borough, New Cumberland, PA 17070. The residence appears to be vacant and per the New Cumberland Postmaster the defendant has moved and left no forwarding address. 04!26/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction From Attorney. SHERIFF COST: $550.37 May 25, 2012 SO ANSWERS//, Rt]N R ANDERSON, SHERIFF (e) (,ou~rySune Snenfi, 1H608011, Inc IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7; et seq. Plaintiff (Petitioner) V. MARK A. MCCONNAUGHEY A/K/A MARK MCCONNAUGHEY; et al. Defendant (Respondent) CASE and/or DOCKET No.: 08-4279 Sheriff s Sale Date: 12/5/2012 AFFIDAVIT OF NON-SERVICE - ~, Complaint ~'.~~ ~ Summons Other: NOTICE OF SALE I. RYAN MARKS, certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party ,and that I attempted to serve SU7.ZANE M. MCCONNAUGHEY A/K/A SUZANNE MCCONNAUGHEY the above process on the 24 day of October, 2012, at 3:35 o'clock, PM, at 541 BR{DGE ST APT. A NEW CUMBERLAND, PA 17070 ,County of Cumberland, Commonwealth of Pennsylvania: Manner of Service: Defendant was not served because ,~ Moved ~, Unknown ~'~ No Answer ~~ Vacant ~'': Other: PER RESIDENT OF 2 YEARS, MR. CARBELLO, DEFENDANT DOES NOT RESIDE AT ADDRESS, HE INFORMED SERVER HE DOES NOT KNOW THE DEFENDANT. Service was attempted on the following dates/times: 2) Commonwealth/State of ~ ~ ) SS: County of t~av~J ) 3) Before me, the undersigned notary public, this day, personally, appeared 12 y hd. /"t ~ ~ ~f to me known, who being duly sworn according to law, deposes the following: t hereby swear or affir~~~t the facts set forth in the foregoing Affidavit ofNon-Service are true and correct. (S File Number:67748FC Case ID #:3441095 of Affiant) Subscribed and sworn t re me this 2 L day o o-t- _, 20 IZ Notary Public IGVII. Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024" vs. MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY and SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 TN THE COURT OF COMMON PLEAS OF Cumberland COUNTY No. 08-4279 MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR SUBSTITUTED SERVICE UNDER Pa.R.C.P. 430(a) Plaintiff has filed a Notice of Sheriffs Sale against Defendant, Suzanne M. McConnaughey a/k/a Suzanne McConnaughey, which the Sheriff has been unable to personally serve upon Defendant, Suzanne M. McConnaughey a/k/a Suzanne McConnaughey. As noted in the attached Motion, Plaintiff has made a good faith attempt to ascertain Defendant's whereabouts without success. Accordingly, the Court may approve alternative means of service. See Pa.R.C.P. 430(a). CONCLUSION For reasons stated above and in the attached Motion, the Court should enter an order allowing Plaintiff to serve the Notice of Sheriff's Sale upon Defendant, Suzanne M. McConnaughey a/k/a Suzanne McConnaughey, by posting the premises and certified mail and regular mail to the Defendant's last known address. By. ~~~ ~ LA' GR , P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jill~:°Jenkins Pa. ID 306588 yk Oflazian Pa. ID 3 ].2912 Attorneys for Plaintiff KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 CERTIFICATE OF SERVICE of Cumberland County No. 08-4279 Lourdes Gerena, an employee of KML Law Group, P.C., counsel for plaintiff, does hereby certify that true and correct copies of the foregoing Motion for Substituted Service have been served upon the Defendants, Suzanne M. McConnaughey a/k/a Suzanne McConnaughey and Mark A. McConnaughey a/k/a Mark McCaoonaughey this day of November, 2012, by first class mail, postage prepaid. MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY 332 Summit Avenue Raleigh, NC 27603 SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY 541 Bridge St Apt. A New Cumberland, PA 17070 SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 -~ .-;r`, By. 1 ~ , ` ti/ KML Law Group, P.C. Lourdes Gerena, Legal Secretary Direct Phone: 215-825-6338 1N THE COURT OF COMMON PLEAS ~~ I KML LAW GROUP,F.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106-1532 Attorney for Plaintiff DEUTSCHE BANK.NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN IN THE COURT OF COMMON PLEAS STANLEY ABS CAPITAL I,INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, of Cumberland County SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Term Piano,TX 75024 No. 08-4279 Plaintiff vs. MARK A.MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY ca ' SUZANNE M.MCCONNAUGHEY aWa SUZANNE MCCONNAUGHEY r�� ;.._ Mortgagor(s)and Record Owner(s) 207 Eleventh Street New Cumberland,PA 17070 _ Defendant(s) MOTION TO POSTPONE SEnUUW'S SALE Plaintiff, DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7, by and through its attorneys, in support of its Motion to Postpone Sheriff's Sale represents as follows: 1. Plaintiff is the holder of fast mortgage upon the premises,207 Eleventh Street,New Cumberland, PA 1.7070,hereinafter the"mortgaged premises." 2. Defendants are the mortgagors and record owners of the mortgaged premises. I A Sheriff's Sale of the mortgaged premises was scheduled for December 05, 2012 and then F postponed to March 06, 2013 to complete service of the notice of Sheriff's sale; then further postponed to April 03,2013 to review the loan under the Department of Justice settlement. 4. Plaintiff requests an additional postponement to June 06, 2013 to continue to review the loan under Department of Justice settlement. 5. The Honorable Albert H.Masland has previously granted a motion for alternative service in this matter. 6. The Defendant is unrepresented by counsel and the Plaintiff has no means to seek concurrence of the instant motion except by mail. 7. There is rio prejudice to any party. WIEREFORE,Plaintiff requests that the Court enter Plaintiff's proposed order,which will postpone the sale until Wednesday,June 05,2013. Respectfully submitted, By: _..✓� KML LAW GROUP,P.C. Michael McKeever Pa.ID 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.lD 78020 Kristina Murtha Pa.ID 61858 -/ avid Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Jill P.Jenkins Pa.ID 306588 Alyk L.Oflazian Pa.ID 312912 Attorneys for Plaintiff WOLF&W ttorneys at Law Date:April ,2013 By: an C.W squire 10 West High t Carlisle,PA 17013 Supreme Court I.D.No. 87380 (717)241-4436 Local Counsel for Plaintiff i i KML LAW GROUP,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106-1532 f Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I,INC TRUST 2006-HE7 MORTGAGE PASS THROUGH IN THE COURT OF COMMON PLEAS I CERTIFICATES,SERIES 2006-HE7 7105 Corporate Drive OF Cumberland COUNTY PTX C-35 Plano,TX 75024 Plaintiff VS. Term MARK A.MCCONNAUGHEY a/icla MARK No.08-4274 MCCONNAUGHEY and SUZANNE M.MCCONNAUGHEY alkla SUZANNE MCCONNAUGHEY Mortgagor(s)and Record Owner(s) 207 Eleventh Street New Cumberland,PA 17070 Defendants) MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 3129.3(b)allows a judgment creditor to postpone a sheriffs sale up to two times within a one hundred thirty day period without new notice. The postponement must be announced to all assembled bidders. As outlined in the attached motion, the Sheriff's Sale has already been postponed as allowed by Pa.R.C.P. 3129.3(b). Plaintiff seeks Court approval under, "inter alia,PaRC.P. 126,to postpone the sale again. This postponement will be announced to all assembled bidders. CONCLUSION For all the reasons discussed above and in the attached Motion,the Court should enter the attached Order postponing the Sheriffs Sale. Respectfully submitted, K MIL LAW GROUP,P.C. Michael McKeever Pa.ID 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha.Pa.ID 61858 --bavid Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Jill P.Jenkins Pa.ID 306588 Alyk L.Oflazian Pa.ID 312912 i Attorneys for Plaintiff i WOLF&WO ttorneys at Law Date:April 2013 By: . 1 t .W , square West Hi t Carlisle,PA 17013 Supreme Court I.D.No.87380 (717)241-4436 Local Counsel for Plaintiff `I - - -- I KML LAW GROUP,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106-1532 A!!9mey for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, IN THE COURT OF COMMON PLEAS INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES,SERIES 2006-HE7 of 7105 Corporate Drive CUMBERLAND PTX C-35 Plano,TX 75024 Plaintiff Term Plaintiff vs. No. 08-4279 MARK A.MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M.MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Mortgagor(s)and Record Owner(s) 207 Eleventh Street New Cumberland,PA 17070 Defendant(s) VERIFICATION David Fein,Esquire,hereby states that he is the attorney for Plaintiff herein, and that all of the facts set forth within the attached Motion to Postpone Sheriffs Sale are true and correct to the best of his knowledge,information and belief. The undersigned understands that the foregoing statements are made subject to the penalties of 18 Pa-C.S.A. § 4904. Respectfully submitted, By. KM LAW GROUP,P.C. Michael McKeever Pa.ID 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristin Murtha Pa.ID 61858 �vid Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Jill P.Jenkins Pa.ID 306588 Al yk L.Oflazian Pa.ID 312912 I Attorney for Plaintiff WOLF& F,Attorneys at Law Date:April 2013 BY: ath ,Esquire low t igh Street Car ,PA 17013 Supreme Court I.D.No. 87380 (717)241-4436 Local Counsel for Plaintiff i KUL LAW GROUP,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106-1532 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL 1, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH IN THE COURT OF COMMON PLEAS CERTIFICATES,SERIES 2006-HE7 7105 Corporate Drive OF Cumberland County PTX C-35 Plano,TX 75024" Plaintiff Term VS. No.08-4279 MARK.A.MCCONNAUGHEY alk/a MARK MCCONNAUGHEY and SUZANNE M. MCCONNAUGHEY aWa SUZANNE MCCONNAUGHEY Mortgagor(s)and Record Owner(s) 207 Eleventh Street New Cumberland,PA 17070 Defendants) CERTIFICATE OF SERVICE Jamie Golden,an employee of KML LAW GROUP,P.C.,counsel for Plaintifly hereby certifies that a copy of Plaintiffs Motion to Postpone Sheriffs Sale was mailed by first class mail, postage prepaid, to Defendant(s)on April 1,2013. MARK A.MCCONNAUGHEY aWa MARK MCCONNAUGHEY 332 Summit Avenue Raleigh,NC 27603 SUZANNE M.MCCONNAUGBEY aWa SUZANNE MCCONNAUGP F.Y 207 Eleventh Street New Cumberland,PA 17070 MARK A.MCCONNAUGHEY aWa MARK MCCONNAUGHEY 207 Eleventh Street New Cumberland,PA 17070 SUZANNE M.MCCONNAUGHEY aWa SUZANNE MCCONNAUGHEY 332 Summit Ave Raleigh,NC 27603 SUZANNE M MCCONNAUGHEY aWa SUZANNE MCCONNAUGHEY 541 Bridge St Apt A Now Cumberland,PA 17070 i Respectfully submitted, r KML LAW GROUP,P.C.- i h / �, By: "Jamie Go Legal As ' I5-825-6346 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I,INC TRUST 2006-HE7 MORTGAGE PASS IN THE COURT OF COMMON PLEAS THROUGH CERTIFICATES,SERIES 2006-HE7 7105 Corporate Drive OF Cumberland County PTX C-35 Plano,TX 75024 Plaintiff Term VS. No.08-4279 MARK A.MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY and SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Mortgagor(s)and Record Owner(s) 207 Eleventh Street New Cumberland,PA 17070 Defendant(s) ORDER AND NOW,this d2 day of 'O ode ,2013 upon consideration of Plaintiffs Motion to Postpone Sheriffs Sale and any response thereto,it is ORDERED and DECREED: That the Motion is granted and the Sheriffs Sale in the above-captioned matter is hereby postponed until Wednesday,June 05,2013,without need for further notice,costs,and advertising. BY THE COURT: J Distribution: t/KML Law Group,P.C., Attorney for Plaintiff, 7 701 Market Street,Suite 5000 Philadelphia,PA 19106 ar =v M- x;;Ij :-,u r ✓Suzanne M.McConnaughey a/k/a Suzanne McConnaughey, ry o 541 Bridge Street,Apt.A. New Cumberland PA 17070 Cj < C., ✓Mark A.McConnaughey a/k/a Mark MConnaughey, 332 Summit Avenue Raleigh,NC 27603-2352 ✓Sheriff of Cumberland County _ t 1 Courthouse Square Carlisle,PA 17013 ,yl G 67748FC KML LAW GROUP,P.C. CF:07/17/2008 Suite 5000 SD:04/03/2013 BNY Mellon Independence Center i 1 i i $128,337.16 701 Market Street Philadelphia,PA 19106-1532 2 215-627-1322 ;.,,ks.,,-: ,:, n AttoMe for Plaintiff , ` `► �" ` ' — -xx DEUTSCHE BANK NATIONAL TRUST HE COURT OF COMMON PLEAS COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL 1, INC TRUST 2006- of Cumberland County HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 CIVIL ACTION–LAW 7105 Corporate Drive PTX C-35 ACTION OF MORTGAGE FORECLOSURE Plano, TX 75024 Plaintiff Term vs. No. 08-4279 MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Mortgagor(s)and Record Owner(s) 207 Eleventh Street New Cumberland,PA 17070 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P.3129.2 (c)(2) Eileen Bowden,an employee of KML Law Group,P.C.,counsel of Plaintiff,hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: f Personal Service by therSherifFrOffiee/competent adult(copy of return attached). '( }' Certified mail by KML Law Group,P.C. (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by KML Law Group,P.C.to Attorney for Defendant(s)of record(proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s)(proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s)of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. Premises was posted by s ice/competent adult(copy of return attached). ( ) Certified Mail&ordinary mail by Sheriffs Office(copy of return attached). ( ) Certified Mail&ordinary mail by KML Law Group,P.C. (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 KML Law Group,P.C.(copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, BY: Eileen Bowden Legal Assistant Name and Address of Sender Check type of mail or service: Affix Stamp Here GOLDBECK (If issued as a SUITE 5000 ❑ Certified ❑ Recorded Delivery(International) certificate of mating, 701 MARKET STREET ❑ COD ❑ Registered or for additional copies ❑ Delivery Confirmation ❑ Return Receipt for Merchandise of this bill) PHILADELPHIA, PA e ❑ Express Mail ❑ Signature Confirmation Postmark and 19106-1532 El Insured Date of Receipt I , Handling ter,rtnw won RR Article Number Addressee(Name,Street,City,State,&ZIP Code) Postage Fee $ 02.640 Fee 1. DOMESTIC RELATIONS OF CUMBERLAND 0004285957 AUG28 2012 COUNTY PS MAILED FROM a1POODE 1910.8 PO Box 320 TENAN S/OCCUP NT „ sTA Carlisle,PA 17013 207 Ele enth Stree -- --- - - — - - 2 ew u e an , . PA DEPARTMENT OF PUBLIC WELFARE- Bureau of Chile!Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box-2675 3. Harrisburg, PA 17105-2675 NEW CUMBERLAND BOROUGH 1120 Market Street 4. New Cumberland, PA 17070 NEW CUMBERLAND BOROUGH 1120 Market Street 5, New Cumberland, PA 17070 NEW CUMBERLAND BOROUGH C/O Andrew C. Sheely, Esquire 6. Mechanicsburg, PA 17055 7. 8. Total Numbs Kof iece s% 5ec l umber of Pieces Postmaster,Per(N a of rec iving employee) Listed by Se ved at Post office See Privacy Act Statement on Reverse PS Form 3877, nary 2002(Page 1 of 2) m late by Typswr r,Ink,or Ball Point Pen 67748FC Cumberland County Sale Date: 12/05/2U MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY&SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Name and Address of Sander Check type of mail or service; Affix Stamp Here KML LAW GROUP, P.C. (N Issued as a SUITE.5000 ❑ CerMad ❑ Recorded Delivery(Internatlonsq carUticate of maNing, mENMENO E ❑ COD ❑ Registered or for addltlonel copies ! XH MARKET PHIA, P ET ❑ DeIN yconarmatlon ❑ Return Recelpt for Merchandise of this MID 02 1M $ 02,30a PHILADELPHIA, PA ❑ Expreas Mall ❑ Signature Confirmation Postmark and I 0004285851 JAN 18 2013 1 5108.1532 0 insured Date of Recebt .(MAf1J�3FR0IrthT�pIADE IAJDA. Arlicie Number Addresses(Ne M.Strest My,Sisk 8 ZIP Code) Postage Fee Handling RR ha e _ - Fes 1. MCCONNAUGHEY,SUZANNE M.alk/a MCCO AUGHE ,SUJZAN E M.fOrM SUZANNE MCCONNAUGHEY SUZA MCC01 INA UGH Y 20.7 ENventh Strtiet 341 Sri a St Apt A New Cumberland,PA 17070 New CU Berland,PA 1707 2. 5JATIO* 3. o ° 4'. y�<A DEL?t 4 5. 6. 7. 8. . Total Number of PI Total Number of Pleas Postmaster.Per(Name of receiving employes) , Listed by Sender Received at Post Ofrce See Privacy Act Statement on Reverse PS Form 3877,February 2002(Page t of 2) Complete by Typewrker, r Sall Point Pon 67748FC Cumbadand County Sale Date: 03/0612013 MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY&SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY DEUTSCHE BANK NATIONAL TRUST COMPANY AS IN THE COURT OF COMMON PLEAS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I,INC TRUST 2006-HE7 MORTGAGE PASS THROUGH OF Cumberland COUNTY CERTIFICATES,SERIES 2006-HE7 7105 Corporate Drive PTX C-35 Plano,TX 75024 084279 ` J c _ vs. Mco O .rn r l rn r MARK A.MCCONNAUGHEY a/k/a MARK N r o MCCONNAUGHEY and SUZANNE M MCCONNAUGHEY C� a/k/a SUZANNE MCCONNAUGHEY <© —p �C 207 Eleventh Street New Cumberland,PA 17070 N ORDER AND NOW,this day of 42012,upon consideration of the Plaintiffs Motion for Substituted Service under Pa.R.C.P.430(a)and it appearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendant,Suzanne M.McConnaughey a/k/a Suzanne McConnaughey,have been unsuccessful,it is, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Notice of Sheriff s Sale upon Defendant,Suzanne M.McConnaughey a/k/a Suzanne McConnaughey,by posting a copy of the Notice upon the premises 207 Eleventh Street,New Cumberland,PA, 17070,and Plaintiff is directed to serve the Notice of Sheriff Sale by certified and regular mail to the Defendant's last known address at 541 Bridge Street,Apt.A,New Cumberland,PA 17070,and that all further service of legal papers,including but not limited to motions,petitions and rules be made by certified and regular mail to Defendant's last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendant,Suzanne M.McConnaughey a/k/a Suzanne McConnaughey,by sending copies of same to Defendant's last known address by certified and regular mail and by posting the premises. Service is complete upon mailing. BY THE COURT: J. Distribution list Michael T.McKeever,Esquire,Suite 5000-BNY Independence Center,701 Market Street,Philadelphia,PA 19106-1532 SUZANNE M.MCCONNAUGHEY aWa SUZANNE MCCONNAUGHEY,541 Bridge Street Apt A,New Cumberland,PA 17070 Print Your Documents Page 8 of 10 •4 OSPS Manifest Mailing System - Page 7 -- ------------_------------------ - --------------- -------- Mails-r's Name& Address I Permit Number I Me Ver- Number 704, La.. Gxoup I 123 -t CooncctShip Progiatics 6.5 701 Market S`seet 1�'--- '----- - Suite 5000 Sequence Wumber I Class o! Mail philadelph x ia, P19106 -I 567-3 1 tti:ed Article 6/ Addreseea Name ES ES Insurance Due 7atal Piece ID Delivery Address Type Postage Fee -�nt__- Sender_____��____-_ --_---------------_______________-______-___-___-._______ _____ _--___.,-_---------- PAPAGIAWM(IS, PAMRGIOTIS D.450 4.55 9171999991703189982098 605 Park Avaoue Apartment 2G ERR 1.15 Rev Yoxk, NY-10065 C 2.95 PAPAOIRNNARIS, PANAGIOTIS 0.450 4.55 9171999991703189982104 213 Bihdale Road ERA 1.15 Tamiment, PA-10371 C 2.95 - QUIRINDOpM, SONIA 0.450 4.55 9171999991703199982111 2652 Waldo Street F" 1.15 Harrisburg, PA-17110 C 2.95 QOIRINDON00, SONIA 0.450 - 4.55 9172999991703189982128 965 State St ERR 1.15 Perth Amboy, w-09861 C - 2.95 4+tp STAr/oa QOIR1111 i60, SONIA 0.450 ��• 4.55 9171999991703169982135 910 Walters Street ERR 1.15 Hethleben, PA-10017 C 2.9 MCCOEAOWGBEy, SDEAM9 M. a/k/a 0.450 L1 � p 4.55 9171999991703169982142 541 Bridge St Apt. A ERR 1.15 ° New Canberland, PA-17070 C 2.95 MCCON1O x=y, sunya E M. a/k/a 0.450 !`�Q� 'A4' 4.55 /! 9 999991703189982159 207 Eleventh Street ERR New Cumberland, PA-11070 -C 2.95 DUM, me 0.450 4.55 9171999991703189962166 60 Willow St ERR 1.15 Lehighton, PA-18235 C 2.95 SJANLEY, DAVID D. 0.450 4.55 9171999991703169982173 52 Highland Ave ERR 1,15 Betblehen, PA-18017 C 2.95. sMLW y. DAVID H. 0.450 - 4.55 9171999991703189962180 7321 Syr Drive ERR 1.15 Rio Rancbo, NM--87144 C 2.95 ----------------------------- Page Totals 4.50 41.-00 45.50 Cumulative Totals 68 30.60 278-80 309.40 httD://T)bpdsendsuite%201ive/projects/image.aspx 1/18/2013 T IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS ;CASE and/or DOCKET No.:08-4279 TRUSTEE FOR MORGAN STANLEY ABS CAPITAL 1,INC TRUST 2006-HE7 MORTGAGE PASS THROUGH ;Sheriffs Sale Date:3/6/2013 CERTIFICATES,SERIES 2006-HE7;et seq. Plaintiff(Petitioner) V. MARK A.MCCONNAUGHEY A/K/A MARK MCCONNAUGHEY;et al. Defendant(Respondent) AFFIDAVIT OF SERVICE Complaint Summons Other:NOTICE OF SALE 1,RYAN MARKS,certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party,and that I served SUZANNE M.MCCONNAUGHEY A/K/A SUZANNE MCCONNAUGHEY the above process on the 24 day of January-,2013,at 2:45 o'clock,PM,at 207 hleventh Street New Cumberland,PA 17070,County of Cumberland,Commonwealth of Pennsylvania: Manner of Service: By posting a copy of the original process on the most public part of the property pursuant to an order of court Service was attempted on the following dates/times: 1) 2) 3) Commonwealth/State of j/4 ) SS: County of 6c ew ) Before me,the unlat otary public,this day,personally,appeared Jl!.w A. A4#-W to me known,who being duty sworn o law,deposes the following: I hereby swear or the facts set forth i n the foregoing Affidavit of Service are true and correct. Subscribed and sworn to be ( �&turc of Affiant) this��day Pile Number:67748H Case Ill 11:3529584 Notary Public IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR CASE and/or DOCKET No.:08-4279 MORGAN STANLEY ADS CAPITAL I,INC TRUST 2006-11E7 MORTGAGE PASS THROUGH CERTIFICATES,SERIES 2006-HE7;et ;`Sheriff`s Sale Date: 1210519 19 seq. Plaintiff(Petitioner) E V. MARK A MCCONNAUGHEY A/K/A MARK MCCONNAUGHEY;et al. Defendant(Respondent) i AFFIDAVIT OF SERVICE Complaint ❑summons Other: Notice of Sale -- i, Jennifer McCracken certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party, and that I attempted to serve MARK A.MCCONNAUGHEY A/K/A MARK MCCONNAUGHEY the above process on the 2_day of September,2012_at 7 :Q3 eclock_E_M,at 332 SUMMIT AVE Raleigh,NC 27603 2352 Manner of Service: By handing a copy to: An officer,partner,trustee,or registered agent of the Defendant organization who is not a plaintiff in the action" The manager,clerk,or other person for the time being in charge of a regular place of business or activity of the Defendant organization who is not a plaintiff in the action An agent authorized by the Defendant organization in writing to receive service of process for it who is not a plaintiff in the action By handing a copy to the Defendant(s) -, By handing a copy at the residence of the D'^ndant(s)to an adult member of the family with whom he(she resides or to the adult person in charge of the residence because no adult family member was found By hamling a copy at the residence of the Defendants)to the clerk or manager of the hotel,inn,apartment house or other place of lodging at which he/she resides• By banding a copy at the office or usual place of business of the Defendants)to the Defeadanes(e)agent or to the person for the time being in charge thereof. By posting a copy of the original process on the most public peat of the property pursuant to an order of court «Nam: Relationship/Tide/Position: Remarks: Description:Approximate Age AA Height OLD Weight SQ Race Sex_ Hair Defendant was not served because: D Moved i. l Unknown ❑No Answer —';Vacant 'Other: Service was attempted on the following dates/times: r. 1) 2) 3) Commonweaith/5tate of North Carolina ) SS: County of Johnston ) Before me,the undersigned rotary public,this day,personally.appeo Jf /I[�i�iEC1� to me known,who being dryly sworn according to law, deposes the following: Vswear or affirm that t forth in the foregoing Affidavit of Service are true and correct. Subscribed and sw to fore me / ( r store o ffiant) this clay of r7 20 File Number.67748FC Case ID#:3402230 � otary Public Eft*1 OYf1 NOW P1f .��.�i /�� JoWu n Cow&.HC KML LAW GROUP,P.C. Suite 5000—BNY Mellon Independence Center 701 Market Street Philadelphia,PA 19106 215-825-6320 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST IN THE COURT OF COMMON PLEAS COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I,INC TRUST 2006- of Cumberland County HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive CIVIL ACTION-LAW PTX C-35 Plano,TX 75024 Plaintiff ACTION OF MORTGAGE FORECLOSURE vs. No. 08-4279 MARK A.MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M.MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Mortgagor(s)and Record Owner(s) 207 Eleventh Street New Cumberland,PA 17070 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7, Plaintiff in the above action, ,by and through an authorized employee of its attorneys,KML Law Group,P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 207 Eleventh Street New Cumberland,PA 17070 1.Name and address of Owner(s)or Reputed Owner(s): MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY 332 Summit Avenue Raleigh,NC 27603 SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY 207 Eleventh Street New Cumberland,PA 17070 2.Name and address of Defendant(s)in the judgment: MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY 332 Summit Avenue Raleigh,NC 27603 SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY 207 Eleventh Street New Cumberland, PA 17070 3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle,PA 17013 PA DEPARTMENT OF PUBLIC WELFARE -Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O.Box 2675 Harrisburg,PA 17105-2675 NEW CUMBERLAND BOROUGH 1120 Market Street POB 220 New Cumberland,PA 17070 NEW CUMBERLAND BOROUGH 1120 Market Street New Cumberland,PA 17070 NEW CUMBERLAND BOROUGH C/O Andrew C. Sheely,Esquire 127 South Market Street,P.O. Box 95 Mechanicsburg, PA 17055 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 207 Eleventh Street New Cumberland, PA 17070 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: March 29,2013 L P, Eileen Bowden Legal Assistant SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Andersoh ( (► E D_(J Sheriff : - i�,,: pt A..ir�n�r�t�r Jody S Smith '' Q ' Chief Deputy � J�1l'I € G P .�: Richard W Stewart i BL--- �, CiJMttt!ANt 0 (:.J I-7 Y Solicitor OFFICE OFTHE SVERIFF P E 14 N-Y LVA H I�y Deutsche Bank National Trust Company vs. .Case Number Mark McConnaughey(et al.) 2008-4279 SHERIFF'S RETURN OF SERVICE 10/04/2012 12:21 PM -Deputy William Cline, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 207 11th Street, New Cumberland Borough, New Cumberland, PA 17070, Cumberland County. 12/04/2012 As directed by David Fein, Attorney for the Plaintiff, Sheriffs Sale Continued to 3/6/2013 02/28/2013 As directed by David Fein, Attorney for the Plaintiff, Sheriffs Sale Continued to 4/3/2013 04/02/2013 As directed by David Fein,Attorney for the Plaintiff, Sheriffs Sale Continued to 6/5/2013 06/04/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $788.78 SO ANSWERS, June 06, 2013 RbNrrY R ANDERSON, SHERIFF a 9! -3a (c)Coun'ySuite Sheriff,Telecsoft:Inc. KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106-1532 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN IN THE COURT OF COMMON PLEAS STANLEY ABS CAPITAL I, INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, of Cumberland County SERIES 2006-HE7 7105 Corporate Drive PTX C-35 CIVIL ACTION-LAW Plano,TX 75024 Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY SUZANNE M.MCCONNAUGHEY a/k/a SUZANNE No. 08-4279 MCCONNAUGHEY (Mortgagor(s) and Record Owner(s)) 207 Eleventh Street New Cumberland,PA 17070 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL 1,INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7,Plaintiff in the above action,by counsel, KML Law Group,P.C.,sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 207 Eleventh Street New Cumberland,PA 17070 1.Name and address of Owner(s)or Reputed Owner(s): MARK A.MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY 332 Summit Avenue Raleigh,NC 27603 SUZANNE M.MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY 207 Eleventh Street New Cumberland,PA 17070 2.Name and address of Defendant(s)in the judgment: MARK A.MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY 332 Summit Avenue Raleigh,NC 27603 SUZANNE M.MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY 207 Eleventh Street New Cumberland,PA 17070 o i 3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle,PA 17013 PA DEPARTMENT OF PUBLIC WELFARE-Bureau of Child Support Enforcement Health and Welfare Bldg.-Room 432 P.O.Box 2675 Harrisburg,PA 17105-2675 NEW CUMBERLAND BOROUGH 1120 Market Street POB 220 New Cumberland,PA 17070 NEW CUMBERLAND BOROUGH 1120 Market Street New Cumberland,PA 17070 NEW CUMBERLAND BOROUGH C/O Andrew C. Sheely,Esquire 127 South Market Street,P.O.Box 95 Mechanicsburg,PA 17055 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 207 Eleventh Street New Cumberland,PA 17070 I verify that the statements made in this affidavit are true and correct to the best of my information and belief.I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. DATED: 7 bX By: KML LAW GROUP,P.C. Michael McKeever Pa.ID 56129 Jay E.Kivitz Pa. ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 ":n--bavid Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua 1.Goldman Pa.205047 Jill P.Jenkins Pa. ID 306588 Attorneys for Plaintiff 08-4279 KML Law Group,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia;PA 19106 (215)627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN IN THE COURT OF COMMON PLEAS STANLEY ABS CAPITAL I,INC TRUST 2006- HE7 MORTGAGE PASS THROUGH of Cumberland County CERTIFICATES,SERIES 2006-HE7 7105 Corporate Drive PTX C-35 CrVIL ACTION-LAW Plano,TX 75024 Plaintiff ACTION OF MORTGAGE FORECLOSURE vs. MARK A.MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY Docket No. 08-4279 SUZANNE M.MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Mortgagor(s)and Record Owner(s) 207 Eleventh Street New Cumberland,PA 17070 Defendants 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: MCCONNAUGHEY,SUZANNE M.a/k/a SUZANNE MCCONNAUGHEY SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY 207 Eleventh Street New Cumberland,PA 17070 Your house at 207 Eleventh Street,New Cumberland,PA 17070 is scheduled to be sold at Sheriffs Sale on Wednesday,December 05,2012, at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$128,337.16 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I,INC TRUST 2006- HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7 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: } 08-4279 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I,INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7,the back payments,late charges,costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1- 866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment,if the judgment was improperly entered.You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights.The sooner you contact one,the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriff s Sale is not stopped,your property will be sold to the highest bidder.You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale.To find out if this has happened,you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer.At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house.A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty(30)days from the date of the Sheriffs Sale.This schedule will state who will be receiving that money.The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back,if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: hqp://www.philadelphiafed-org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 08-4279 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.orgLconsumers/bomeowners/real.aspx. 5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionC kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 67748FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 08-4279 KM L Law Group,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106 (215)627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN IN THE COURT OF COMMON PLEAS STANLEY ABS CAPITAL I,INC TRUST 2006- HE7 MORTGAGE PASS THROUGH of Cumberland.County CERTIFICATES, SERIES 2006-HE7 7105 Corporate Drive PTX C-35 CIVIL ACTION-LAW Plano,TX 75024 Plaintiff ACTION OF MORTGAGE FORECLOSURE vs. MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY Docket No. 084279 SUZANNE M. MCCONNAUGHEY a/k/a SUZANNE MCCONNAUGHEY Mortgagor(s)and Record Owner(s) 207 Eleventh Street New Cumberland,PA 17070 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: MCCONNAUGHEY,MARK A.a/k/a MARK MCCONNAUGHEY MARK A. MCCONNAUGHEY a/k/a MARK MCCONNAUGHEY 207 Eleventh Street New Cumberland,PA 17070 Your house at 207 Eleventh Street,New Cumberland,PA 17070 is scheduled to be sold at Sheriffs Sale on Wednesday,December 05,2012,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$128,337.16 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I,INC TRUST 2006- HE7 MORTGAGE PASS THROUGH CERTIFICATES,SERIES 2006-HE7 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: 6 i 08-4279 L The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I,INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2006-HE7,the back payments,late charges,costs and reasonable attorney's fees due. To find out how much you must pay call our office at 21.5-825-6329 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.Philadell2biafed.org/foreclosur 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 08-4279 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.or�-/consumers/homeowners/real.aspx. 5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1.-866-413-2311 or via email,at homeretention@kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 67748FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ALL THAT CERTAIN piece or parcel of land situate in Second Ward of the Borough of New Cumberland, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described based on a survey by Michael C. D'Angelo, PLS, dated September 25, 1996 and recorded with Deed in Deed Book 150,Page 12, as follows,to wit: BEGINNING at a point on the Northern line of Eleventh Street, a distance of two hundred fifty-six and fifty-four hundredths (256.54) feet East of the Northeast comer of Bridge and Elevenths Streets and marked with a steel pin; thence North twenty-eight(28) degrees twenty-five(25) minutes thirty-three(33) seconds West seventy-eight (78) feet along other lands now or formerly of David A. Krulac to a point marked with a steel pin; thence South sixty-one(61) degrees thirty-four (34)minutes twenty-seven (27) seconds West thirty-seven (37) feet along lands now or formerly of Mary A. Krula'c to a point marked with a steel pin; thence South twenty-eight(28)degrees twenty-five.(25) minutes thirty-three(33) seconds East seventy-eight(78) feet along lands now or formerly of Gloria Lynn to a point marked with a steel pine; thence along the Northern line of Eleventh Street South sixty-one(61) degrees thirty-four(34) minutes twenty-seven (27) seconds West thirty-seven (37)feet to a point marked with a steel pin and place of BEGINNING. BEING Lot No. 127 in the Plan of Lots called Elkwood, as recorded in Recorder of Deeds Office for Cumberland County in Deed Book "M" Volume 5,Page 498. MUNICIPALITY: Borough of New Cumberland HAVING THEREON ERECTED a dwelling known and numbered as 207 Eleventh Street,New Cumberland, PA 17070 TAX PARCEL-#: 26-23-0541-266 BEING THE SAME PREMISES BY DEED DATED 06/09/2006, GIVEN BY DEBORAH A. IKEHARA, NOW KNOWN AS DEBORAH A. OAKLEY AND ROBERT J. OAKLEY, JR., HER HUSBAND TO MARK MCCONNAUGHEY AND SUZANNE MCCONNAUGHEY, HIS WIFE AND RECORDED 06/15/2006 IN BOOK 275 PAGE 732. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 08-4279 Civil COUNTY OF CUMBERLAND) CIVIL ACTION–LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL 1,INC TRUST 2006-HE7 MORTGAGE PASS THROUGH CERTIFICATES,SERIES 2006-HE7 Plaintiff(s) From MARK.A MCCONNAUGHEY AWA MARK MCCONNAUGHEY,SUZANNE M. MCCONNAUGHEY A/K/A SUZANNE MCCONNAUGHEY (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 gamishee(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: $128,337.16 Interest FROM 9/3/2008 TO DATE OF SALE PER DIEM AT$27.25 Atty's Comm: % Due Prothy:$2.25 Arty Paid: $2,097.60 Other Costs: Plaintiff Paid: Date: 8/21/2012 David D.Buell,Prothonota (Seal) Deputy REQUESTING PARTY: Name:DAVID FIEN,ESQUIRE Address: KML LAW GROUP,P.C. TRUE COPY FROM RECORD SUITE 5000-BNY INDEPENDENCE CENTER in Testimony whereof"[here Flo to set my hand 701 MARKET STREET and the seat of'said Cou at Carlisle,Pa. Tbis�–2—L day of 20 PHILADELPHIA,PA 19106 Prot o�ot-3r'/ Attorney for: PLAINTIFF Telephone:215-627-1322 Supreme Court ID No. 82628 On August 31, 2012 the Sheriff levied upon the defendant's interest in the real property situated in New Cumberland Borough, Cumberland County, PA, known and numbered 207 Eleventh Street, New Cumberland, PA 17070, fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 31, 2012 4 i f' By: r Claudia Brewbaker, Real Estate Coordinator U :3 V zz 9nV ZIOZ J 1233HS 3H! JJ 301330 CUMBERLAND LAW JOURNAL Writ No. 2008-4279 Civil Term Deutsche Bank National Trust Company VS. Mark McConnaughey Suzanne M. McConnaughey a/k/a Suzanne McConnaughey Atty.: David Fein IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 207 Eleventh Street,New Cumberland,PA 17070. SOLD as the property of MARK A. McCONNAUGHEY a/k/a MARK McCONNAUGHEY and SUZANNE M. McCONNAUGHEY a SUZANNE McCONNAUGHEY. TAX PARCEL#26-23-0541-266. 64 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 26, November 2 and November 9, 2012 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. isa Marie Coyne,JEditor SWORN TO AND SUBSCRIBED before me this day of November, 2012 Notary NOTARIAL SEAL I DEBORAH A COLLINS Notary Public HiC. CARLISLE 7BOROUGH.CUMBERLAND COUNTY My Commission Expires Apr 28,2014 o The Patriot-News Co. 2020 Technology Pkwy the atr1*otwXtws Suite 300 Mechanicsburg, PA 17050 NOW you know Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, 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 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds 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: 10/26/12 2008-4279 Civil Term 11/02/12 eutsche Bank National St Company 11/09/12 Vs Mark McConnaughey Suzanne M McConnaughey, We Suzanne McConnaughey • • • • • •�• Atty: David Fein + IMPROVEMENTS consist of a residential dwelling. Sworn-t nd subscribed befor me i 9 d f Nov mber, 2012 A.D. BEING PREMISES:207 Eleventh Sir et New Cumberland,PA 17070 OLD as the property of MARK A. MCCONNAUGHEY a/k/a MARK CCONNAUGHEYanaSUZANNE, Notary Public M.MCCONNAUGHEYaSUZANNE CCONNAUGHEY TAX PARCEL#26-23-0541-266 COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L.Owens,Notary public Lower Paxton Twp.,Dauphin County MY Commission Expires Nov 26,2015 MEMBER PENNSYLVANIA ASSOCIATION OF NOTARIES