Loading...
HomeMy WebLinkAbout08-4844GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF llEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I INC. TRUST 2006-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. SUSAN M. KLING RONALD L. KLING a/k/a RON L. KLING JR. Mortgagors and Record Owners 2310 New York Avenue Camp Hill, PA 17011 Defendants Term /? No. 0$ - ,fggq l'iv; I Tep, CIVIL ACTION: MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. 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 NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE I PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. 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 ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 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/homeowncrs/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 69861 FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff is DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I INC. TRUST 2006-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 , 7105 Corporate Drive, PTX C 35 Plano, TX 75024. 2. The names and addresses of the Defendants are SUSAN M. KLING, 2310 New York Avenue, Camp Hill, PA 17011 and RONALD L. KLING a/k/a RON L. KLING JR., 2310 New York Avenue, Camp Hill, PA 17011, who are the mortgagors and record owners of the mortgaged premises hereinafter described. 3. On July 06, 2006 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR SUPERIOR HOME MORTGAGE CORPORATION, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1965, Page 3424. The mortgage has been assigned to: DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I INC. TRUST 2006-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8, by assignment of Mortgage. Plaintiff is the real party in interest pursuant to a purchase or transfer of the mortgage obligation from the last record holder and an Assignment of Mortgage to Plaintiff has been and/or will be lodged for recording with the Recorder of Deeds in the ordinary course of business. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for December 01, 2007 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ....................................................................................$96,285.74 Interest from 11/01/2007 through 07/18/2008 at 9.7900% .......................$6,739.02 Per Diem interest rate at $25.82 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$4,814.29 Late Charges from 12/01/2007 to 07/18/2008 .............................................$334.48 Monthly late charge amount at $41.81 Costs of suit and Title Search ......................................................................$900.00 Monthly Escrow amount $126.00 $109,073.53 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendants have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $109,073.53, together with interest at the rate of $25.82, 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: ATTORNEY FOR PLAINTIFF GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER., ESQUIRE VERIFICATION MMKBOW as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: MARK WHOP, I ST VICE Pdftbff 23 10 New York Avenue Camp Hill, PA 17011 - SUSAN M. KLING and RONALD L. KLING a/k/a RON L. KLING JR. E.XhibitA Jul 15 2008 4:09PM HP LHSERJET 3330 w1L2SOMMU awA drl%m ql'Mdewdpiwfwrf,alAA>wA.b?M'w1?MtMW '?yw??? /7.a w ?l1ou+4d ?Ctinw..•+ill?f/h. BA MliLMXaVeex*s rdm Orlwy fiYcAMp:mwAwb tiww"ftIw prw1??6AwD'RMAnirS?AIAJ? dnwYwwMrtlll+lA7il: Lwrlw?rMN?A Ai1?IMr?.bwaR 100jiwJt+rr <rwgJiwwi?0/4r wJMw]Irl.pwrr wf A?AAiKlwkw w1r? AA1Cdi I?O?MMAM ? JrLtlMaafaAAMgMn+er w wAwA7l?d?w[1uuAbulaA at?llOAMr 7lAtlrwiuR CwPlN4lwmp?? ' BH 1965PG3445. /1Sl2006 10:36:36 AM CUMBERUWO COUNTY P. 31.. 1nst.9 200633310 - Page 22 0(22 E.,Xhibit B Wounbrdde-- HOME LOANS PO Box 9048 Temecula, CA 92589-9048 Send Payments To: PO Box 660694 Dallas, TX 75266-0694 Send Correspondence to. PO Box 5170, MS SV314B Simi Valley, CA 93065 080429-7 SLOPA1 PRESORT First-Class Mail U.S. Postage and Fees Paid WSO 1054-10 1111111111111111111111 7113 8257 1472 6639 7016 Ron L Kling 2310 NEW YORK AVE CAMP HILL, PA 17011-7315 ®Country m& HOME LOANS P.O. Box 660694 Dallas, TX 75266-0694 send Payments to: PO Box 660694 Dallas. TX 752 66-0 694 04728/2008 Certified Mail: 7113 8257 1472 6839 7016 Return Receipt Requested Regular Mail Ron L Kling 2310 NEW YORK AVE CAMP HILL, PA 17011-7315 Account No.. 73231727 Property Address: 2310 New York Ave Camp Hill, PA 17011-7315 Current Servicer: Countrywide Home Loans Servicing LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default and the lender Intends to foreclose Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM THEMAP) may be able to help to save Vour home. This Notice explains how the program works. To see If HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counsetina Agency. This Notice contains important legal information. N you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACIbN EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACNSN OBTENGA UNA TRADUCC16N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRtSTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Ron L Kling PROPERTY ADDRESS: 2310 New York Ave Camp Hill, PA 17011-7315 LOAN ACCT. NO.: 73231727 ORIGINAL LENDER: CURRENT LENDER/SERVICER: Countrywide Home Loans Servlcina LP HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS Please WN you acmurt number on all dNeks and correspndenm. We may harp you a fee foram payment reluned or rejedad by yourlinancal Irallabn, subjaa to appimble lay. Acmunt Number. 73231727$ • Make your check payable to Countrywide Hone Loans Ron L Kling Balance Due for charges listed above: $5,353.79 as of 412 872 0 0 8. • Write your accolntnumber on 2310 New York Ave your check or money order Pimw ulzWe-mail nlomaton on the iev sided Ms mupon. • White in any additional amounts ycu are including (If total is Add OOnal more than $5000, please send Pmripal cartmed check) aLCPA1 • Dont attach your check to the p=n coupon Addtpnar • Dantindudecorrespondence • Dontsend .son Countrywide Escaw PO BOX 660694 ahe Dallas, TX 75266-0694 Ilhhhlhlhlhhhlhlhllhh llh llhhhhllhrlhlhhhlhhllhlhhhl lh?lhlllhhhl Check Tdal 073231727600000535379000535379 IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT" % YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face' meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHNI THE NFVT CONSUMER CREDIT COUNSELING AGENCIES - 11 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 thi..-ty (30) days after the date of this meeting. The names. ts.oaava -A rere ? - -? --- - - set fort[ at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender 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 face-to-face meeting. YOU Ml1ST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at 2310 New York Ave Camp Hill, PA 17011-7315 IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due Monthly Charges: 12/01/2007 Late Charaes: 12101/2007 Other Late Charges Total Late Charges: Uncollected Costs: Partial Payment Balance: TOTAL DUE: YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable) $4,811.20 $209.05 $163.80 $182.50 ($12.76) $5,353.79 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 $5,353.79, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. E-mail use: Providing your e-mail address below will allow us to send you information on your account Account Number. 7SM727 Ron L Bing E-mail address Harr we III* )air P All accepted payments of principal and interest will be applied te the longest outstanding installment due, unless otherwise expressly prohibited or limited by law. If you submit an amount in addtion to your scheduled monthly amount, we will apply you payments as follows: (i) to outstanding monthly payments of principal and irtere-% (ii) escrow deficiencies, (ill) late charges and other amounts you owe in oonnection with your loan and (iv) to reduce the outstanding principal balance of your loan Please specify I you wart an addtional amount applied to future payments, rather than principal reduction. PepO?Nd dieft Country fide's policy is tD not accept postdated dhedcs, unless specifically agreed to by a loan counselor or technician Payments must be made either by cashiers check, certified check or money order made payable and sent to: Countrywide at P.O. Box 660694, Dallas, TX 75266-0694. You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter. (Do not use if not applicable) IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender Intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (301 DAYS, the lender also intends to instruct its adomeys to start legal action to foreclose upon your mortgaged property IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attomey's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (301 DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth In this notice will restore your mortgage to the same position as H you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - it is estimated that the earliest date that such a Sheriffs Sale of the mortgage property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Countrywide Nome Loans Servicing LP Address: P. O. Box 660694 Dallas, TX 73266--0694 Phone Number: 1.800-669.0102 Fax Number. 1-00S-577-3432 Contact Person: MS P7X-36 Attention: Loan Counselor EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff s sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may 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. Y:`C 7113 8257 1472 6839 7016 Your loan is in default. Pursuant to your loan documents, Countrywide may, enter upon and conduct an inspection of your 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 (Hi) determine the identity of the occupant. if you do not cure the default prior to the inspection, other actions to protect the mortgagee's interest in the property (including, but not limited to, winterization, securing the property, and valuation services) may be taken. The costs of the above-described Inspections and property preservation efforts will be charged to your account as provided In your security Instrument. If you are unable to axe the default on or before May 28, 2008, Countrywide wants you to be aware of various options that may be available to you through Countrywide to prevent a foreclosure sale of your property. For example: • Repayment Plan: It is possible that you may be eligible for some form of payment assistance through Countrywide. Our basic plan requires that Countrywide receive, up front, at least 1/2 of the amount necessary to bring the account current, and that the balance of the overdue amount be paid, along with the regular monthly payment, over a defined period of time. Other repayment plans also are available. • Loan Modification: Or, it is possible that the regular monthly payments can be lowered through a modification of the loan by reducing the interest rate and then adding the delinquent payments to the current loan balance. This foreclosure alternative, however, is limited to certain loan types. • Sale of Your Property: Or, if you are willing to sell your home in order to avoid foreclosure, it is possible that the sale of your home can be approved through Countrywide even if your home is worth less than what is owed on it. • Deed-in-Lieu: Or, if your property is free from other liens or encumbrances, and if the default is due to a serious financial hardship which is beyond your control, you may be eligible to deed your property directly to the Notehdder 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 May 28, 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 CUMBERLAND COUNTY Adams County Interfaith CCCS of Western PA Community Action Commissioi Housing Authority 2000 Linglestown Rood of Captial Region 40 E High Street Harrisburg, PA 17102 1514 Derry Street Gettysburg, PA 17325 888.511.2227 Harrisburg, PA 17104 717.334.1518 717.232.9757 Loveship, Inc. Maranatha PHFA 2320 North 5th Street 43 Philadelphia Avenue 211 North From Street Harrisburg, PA 17110 Waynesboro, PA 17268 Harrisburg, PA 17110 717.232.2207 717.782.3285 717.780.3840 800.342.2397 ®Counby *iw HOME LOANS PO Box 9048 Temecula, CA 92589-9048 Seri! Peymonft To: PO Box 660694 Dallas, TX 752664694 Send Conespondenceto: PO Box 5170, MS SV314B Simi Valley, CA 93065 0eaze-7 8LQPA7 PRESORT First-Class Mall U.S. Postage and Fees Paid WSO 1054-10 I?IIIIYIQII II91111111 7113 8257 1472 6839 7023 IIIIIIIIIIII18111111111111111111111111111111111111111111111111 Susan M KNng 2310 NEW YORK AVE CAMP HILL, PA 17011-7315 M ® countrywide - HOME LOANS P.O. Box 660694 Dallas, TX 75266-0694 Send Paymerds to. PO Box 660694 Dallas, TX 752 6 6-0 694 04/28/2008 Certified Mail: 7113 8257 1472 6839 7023 Return Receipt Requested Regular Mail Susan M Kling 2310 NEW YORK AVE CAMP HILL, PA 17011-7315 FORECLOSURE This is an official notice that the mortgage on your home is in default. and the lender Intends to foreclose Speclfic Information about the nature of the default Is Provided In the attached Pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM 1HEMAPI may be able to help to save your home. This Notice explains how the Program works. To see If HEMAP can help, You must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with You when You meet with the CounseNna Agency. This Notice contains Important legal information. H you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICAC16N OBTENGA UNA TRADUCCII)N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NLJMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Susan M Kling PROPERTY ADDRESS: 2310 New York Ave Camp Hill, PA 17011-7315 LOAN ACCT. NO.: 73231727 ORIGINAL LENDER: CURRENT LENDER/SERVICER: Countrywide Home Loans Servicina LP HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS • Make your check pay" to Countrywide Hone Loans • Write your account number on your dredt or money order • Write in any additional amounts you are mcludn (If total is more than $5000, please send certified check) • Dort attach your check to the payment coupon • Dont include correspondence • Dont send cash M Account No.: 73231727 Property Address: 2310 New York Ave Camp Hill, PA 17011-7315 Current Servicer: Countrywide Home Loans Servicing LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM Please wile you accourr nunber on all dgcke and cortespondenoa M may charge you a fee forarry payment retuned or rgected by your finance) Irettrlbn, subject to applicable lay. Account Number: 792317274 Susan M Ming Balance Due for charges listed above: $5,353.79 as of 4!28/2008. 2310 New York Ave Please v*le emai blormaton w the eveise side of the mulem. Ad it"i Rnapel aLfpA7 Add gong) Fscmw Countrywide PO BOX 660694 phe Dallas, TX 75266-0694 Ilrrrlrlrl rrlrlrllrrrllrrllrrrrlirrlrlrrrlrrllrlrrrlrrlrrl lllrrrl Check Taal 073231727600000535379000 535379 IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1883 i(THE "ACT's 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-Five (35) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE 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 thiriy.five (351 days after the date of this meeting. The progeny is hocxea are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thiry-five (35) days of your face-to-face meeting YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at 2310 New York Ave Camp Hill, PA 17011-7315 IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due Monthly Charges: 12/0112007 Late Charges; 12/01/2007 Other Late Charges Total Late Charges: Uncollected Costs: Partial Payment Balance: TOTAL DUE: YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not ar Mlicable) $4,811.20 $209.05 $163.80 $182.50 ($12.76) $5,353.79 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY-FIVE (35) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $5,353.79, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY-FNE (35) DAY PERIOD. E-mail use: Providing your e-mail address below will allow us to send you information on your aocourt Account Number: 7SM721 Susan M Kling E-mail address Haw we pat yar popnoItK JN accepted payments of principal and interest will be applied to the longest outstanding installment due, unless otherwise expressly prohibited or limited by law. If you submit an amount in addition to your scheduled monthly amount, we will apply your payments as follows: (I) to outstanding monthly payments of principal and interest, (4) escrow deficiencies, (M) late charges and other amounts you owe in connection with your loan and (iv) to reduce the outstanding principal balance of your loan Please specify If you wart an additional amount applied to future payments, rather than principal reduction. PaMed daft Courtrywide's policy is to not accept postdated checks, unless specifically agreed to by a loan counselor or technician Payments must be made either by cashiers check. certified check or money order made payable and sent to Countrywide at P.O. Box 660694, Dallas, TX 75266-0694. You can cure any other default by taking the followina action within THIRTY-FIVE (35) DAYS of the date of this letter. (Do not use if not applicable) IF YOU DO NOT CURE THE DEFAULT - H you do not cure the default within THIRTY-FIVE (35) 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-FIVE (351 DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY-FIVE (35) 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 SAL - If you have not cured the default within the THIRTY-FIVE (351 DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default In the manner set forth In this notice will restore your mortgage to the same position as H you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - it is estimated that the earliest date that such a Sheriffs Sale of the mortgage property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender-. Countrywide Home Loans Servicing LP Address: P. Q Box 660694 Dallas, TX 73266-0694 Phone Number: 1.800-669.0102 Fax Number: 1-W5-377-3432 Contact Person: MS PTX-36 Attenflon: Loan Counselor EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and adomey'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. M 7113 8257 1472 6839 7023 TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Your loan is in default. Pursuant to your loan documents, Countrywide may, enter upon and conduct an inspection of your property. The purposes of such an inspection are to (i) observe the physical condition of your property, (ii) verify that the property is occupied and/or (iii) determine the identity of the occupant. If you do not cure the default prior to the inspection, other actions to protect the mortgagee's interest in the property (including, but not limited to, winterization, securing the property, and valuation services) may be taken. The costs of the above-described Inspections and property preservation efforts will be charged to your account as provided In your security Instrument. If you are unable to cure the default on or before June 2, 2008, Countrywide wants you to be aware of various options that may be available to you through Countrywide to prevent a foreclosure sale of your property. For example: • Repayment Plan: It is possible that you may be eligible for some form of payment assistance through Countrywide. Our basic plan requires that Countrywide receive, up front, at least 1/2 of the amount necessary to bring the account current, and that the balance of the overdue amount be paid, along with the regular monthly payment, over a defined period of time. Other repayment plans also are available. • Loan Modification: Or, it is possible that the regular monthly payments can be lowered through a modification of the loan by reducing the interest rate and then adding the delinquent payments to the current loan balance. This foreclosure alternative, however, is limited to certain loan types. • Sale of Your Property: Or, if you are willing to sell your home in order to avoid foreclosure, it is possible that the sale of your home can be approved through Countrywide even if your home is worth less than what is owed on it. • Deed-in-Lieu: Or, if your property is free from other liens or encumbrances, and if the default is due to a serious financial hardship which is beyond your control, you may be eligible to deed your property directly to the Notehdder 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 June 2, 2008 as outlined above will result in the acceleration of your debt. Time is of the essence. If you have any questions concerning this notice, please contact Loan Counseling Center immediately at 1-800-669-0102. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY Adams County Interfaith CCCS of Western PA Community Action Commissia Housing Authomy 2000 Unglestovn Road of Captial Region 40 E High Street Harrisburg, PA 17102 1514 Derry Street Gettysburg, PA 17325 888.511.2227 Harrisburg, PA 17104 717.334.1518 717.232.9757 Loveship, Inc. Maranatha PHFA 2320 North 5th Street 43 Philadelphia Avenue 211 North Front Street Harrisburg, PA 17110 Waynesboro, PA 17268 Harrisburg, PA 17110 717.232.2207 717.762.3285 717.780.3940 800.342.2397 co r ? 00 - 7 GOLDBECK WCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I INC. TRUST 2006-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 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. SUSAN M. KLING RONALD L. KLING a/k/a RON L. KLING JR. 2310 New York Avenue Camp Hill, PA 17011 Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. Term No. 08-4844 By: GOLDBECK McCAFFERTY & McKEEVER MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF w X_ W F w U w W ,'% r CASE NO: 2008-04844 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS KLING SUSAN M 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 KLING RONALD L A RON L KLING JR the DEFENDANT , at 1800:00 HOURS, on the 8th day of September, 2008 at 2310 NEW YORK AVENUE CAMP HILL, PA 17011 by handing to RONALD L KLING 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 14.00 Affidavit .00 Surcharge 10.00 00 ?il?g1of ?.. 30.00 Sworn and Subscibed to before me this day So Answers: 4e? R. Thomas Kline 09/22/2008 GOLDBECK MCCAFFERTY MCKEEVER By: - Deputy Sheriff was served upon of A. D. SHERIFF'S RETURN - REGULAR CASE NO: 2008-04844 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS KLING SUSAN M ET AL TIMOTHY REITZ Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon KLING SUSAN M DEFENDANT , at 1336:00 HOURS, on the 19th day of September, 2008 at 1076 LANCASTER BLVD APT 2 MECHANICSBURG, PA 17055 BRENDA FINEBURG, ROOMMATE by handing to ADULT IN CHARGE a true and attested copy of COMPLAINT - MORT FORE the together with and at the same time directing Her attention to the contents thereof. 18.00 11.00 .00 10.00 .00 39.00 Sheriff's Costs: Docketing Service Affidavit Surcharge V z ok f Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 09/22/2008 GOLDBECK MCCAFFERTY MCKEEVER By : Lien ty Sheri of , A. D. V. I 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-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. SUSAN M. KLING RONALD L. KLING a/k/a RON L. KLING JR. (Mortgagor(s) and Record Owner(s)) 2310 New York Avenue Camp Hill, PA 17011 Defendant(s) PRAECIPE FOR JUDGMENT No. 08-4844 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 SUSAN M. KLING and RONALD L. KLING a/k/a RON L. KLING JR. by default for want of an Answer. Assess damages as follows: Debt Interest from 06/19/2009 to Date of Sale per diem at $25.82 Total $119,569.14 (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED LINTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FRO E COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or deliver/d/e arry againstwhom judgment is to be entered and to his attorney of record, if any, after the default occurred and at ys prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 rT. McKeever for Plaintiff 129 AND NOW 31J /M A) "- , Judgment is entered in favor of DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUS E FOR MORGAN STANLEY ABS CAPITAL I INC. TRUST 2006-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 and against SUSAN M. KLING and RONALD L. KLING a/k/a RON L. KLING JR. by default for want of an Answer and damages assessed in the sum of $119,569.14 as per the above certification. Prothonotary 69861FC 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: October 10, 2008 TO: RONALD L. KLING a/k/a RON L. KLING JR. 2310 New York Avenue Camp Hill, PA 17011 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I INC. TRUST 2006-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 7105 Corporate Drive PTX C 35 Plano, TX 75024 vs. SUSAN M. KLING RONALD L. KLING a/k/a RON L. KLING JR. Plaintiff (Mortgagor(s) and Record Owner(s)) 2310 New York Avenue Camp Hill, PA 17011 Defendant(s) TO: RONALD L. KLING a/k/a RON L. KLING JR. 2310 New York Avenue Camp Hill, PA 17011 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 08-4844 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC b Irvine Roy Carlisle, PA 17013 717-243-9400 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 69861FC 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: October 10, 2008 TO: SUSAN M. KLING 2310 New York Avenue Camp Hill, PA 17011 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I INC. TRUST 2006-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 7105 Corporate Drive PTX C 35 Plano, TX 75024 vs. SUSAN M. KLING RONALD L. KLING a/k/a RON L. KLING JR. (Mortgagor(s) and Record Owner(s)) 2310 New York Avenue Camp Hill, PA 17011 TO: SUSAN M. KLING 2310 New York Avenue Camp Hill, PA 17011 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Tenn No. 08-4844 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 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 69861FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: SUSAN M. KLING 1076 Lancaster Boulevard, Apartment 2 Mechanicsburg, PA 17055 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I INC. TRUST 2006-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. SUSAN M. KLING RONALD L. KLING a/k/a RON L. KLING JR. (Mortgagor(s) and Record Owner(s)) 2310 New York Avenue Camp Hill, PA 17011 Defendant(s) TO: SUSAN M. KLING 1076 Lancaster Boulevard, Apartment 2 Mechanicsburg, PA 17055 DATE OF THIS NOTICE: October 10, 2008 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 08-4844 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, SUSAN M. KLl NG, is about unknown years of age, that Defendant's last known residence is 1076 Lancaster Boulevard, Apartment 2 Mechanicsburg, PA 17055, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Allies, or otherwise within the provisions of the Soldiers' Congress of 1940 and its Amendments. cc of the United States or its Sailors' Civil Relief Action of Date: VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. I. That the above named Defendant, RONALD L. KLING a/k/a RON L. KLING JR., is about unknown years of age, that Defendant's last known residence is 2310 New York Avenue Camp Hill, PA 17011, and is engaged in the unknown business located a/ii known address. 2. That Defendant is not in the Military or Naval Servi96 of/4he United States or its Allies, or otherwise within the provisions of the Soldiers' and , ailq' s' Civil Relief Action of Congress of 1940 and its Amendments. Date: GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I INC. TRUST 2006-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 7105 Corporate Drive PTX C 35 Plano, TX 75024 vs. Plaintiff IN THE COURT OF COMMON PLEAS ACTION OF MORTGAGE FORECLOSURE SUSAN M. KLING RONALD L. KLING a/k/a RON L. KLING JR. (Mortgagor(s) and Record owner(s)) 2310 New York Avenue Camp Hill, PA 17011 Defendant(s) No. 08-4844 of Cumberland County CIVIL ACTION LAW ORDER FOR JUDGMENT Please enter Judgment in favor of DEUTSCHE BANK NATIONAL TRUST FOR MORGAN STANLEY ABS CAPITAL I INC. TRUST 2006-HE8, MORTGAG CERTIFICATES, SERIES 2006-HE8 , and against SUSAN M. KLING and RON L. KLING JR. for failure to file an Answer in the above action within (20) days (or is the United States of America) from the date of service of the Complaint, in the su o1 Y AS TRUSTEE '-THROUGH KLING a/k/a RON ,days if defendant is ,69.14. Michael T. 1 Attorney for I hereby certify that the above names are correct and that the recise residence address of the judgment creditor is DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FIAIc701 AN STANLEY ABS CAPITAL I INC. TRUST 2006-HE8, MORTGAGE PASS-THROUGH CERT, SERIES 2006- HE8 7105 Corporate Drive PTX C 35 Plano, TX 75024 and that the name(s) and address(es) of the Defendant(s) is/are SUSAN M. KLING, 1076 Lancaster Boulevard, Apartment 2 Mg, PA 17055 and RONALD L. KLING a/k/a RON L. KLING JR., 2310 New York Avenue Camp Hi ; GOLDBECK1 BY: Michael T A ttorney for P, cKeever & McKEEVER ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $96,285.74 Interest from 11/01/2007 through $15,388.72 06/18/2009 Reasonable Attorney's Fee $4,814.29 Late Charges $794.39 Costs of Suit and Title Search $900.00 Escrow Payments Due 11 X $126.00 $1,386.00 $119,569.14 GOLDBECKD BY: Michael T Attorney for PA & McKEEVER 41 AND NOW, this O W7 day of 2009 damages are assessed as above. NAMASS &1,t, -7 -7 Pro Prothy nF P L THE L4lr !" ? ?? V'UiY ? J? v4:L; ,dry ?k# 3 evy? y ,Q??.? r1d76G/ ItAV 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-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff No. 08-4844 vs. SUSAN M. KLING RONALD L. KLING a/k/a RON L. KLING JR. (Mortgagors and Record Owner(s)) 2310 New York Avenue Camp Hill, PA 17011 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:? ??,1Cr /U• 1??? Deputy If you have any questions concerning the above, please contact: Michael T. McKeever Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 WM61 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-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 7105 Corporate Drive PTX C 35 Plano, TX 75024 vs. SUSAN M. KLING RONALD L. KLING a/k/a RON L. KLING JR. Mortgagor(s) and Record Owner(s) 2310 New York Avenue Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Plaintiff No. 08-4844 Defendant(s) PRA ECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 06/19/2009 to Date of Sale per diem at $25.82 (Costs to be added) GOLDBECK McC BY: Michael T. M Attorney for Plai> 119,569.14 TY & McKEEVER LL_ o ? zo a¢x 00 ? z O ? ax ? w ,b ? W o oc ad?? Z [a'°O C)w O F o z? d?ww o x C) W QR;°ow H ww?x z x w ? CA QHz y z `? O v W a ° cv N U W ? o a b ? Q o U ° d ? W C7 ? z d o a x Goldbeck McCafferty & McKeever BYE: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff "LU 1 SC:HE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I INC. TRUST 2006-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 7105 Corporate Drive PTX C 35 Plano, TX 75024 vs. Plaintiff SUSAN M. KLING RONALD L. KLING a/k/a RON L. KLING JR. (Mortgagor(s) and Record Owner(s)) 2310 New York Avenue Camp Hill, PA 17011 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 08-4844 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I INC. TRUST 2006-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 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: 2310 New York Avenue Camp Hill, PA 17011 1.Name and address of Owner(s) or Reputed Owner(s): SUSAN M. KLING 1076 Lancaster Boulevard, Apartment 2 Mechanicsburg, PA 17055 RONALD L. KLING a/k/a RON L. KLING JR. 2310 New York Avenue Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: SUSAN M. KLING 1076 Lancaster Boulevard, Apartment 2 Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE RONALD L. KLING a/k/a RON L. KLING JR. 2310 New York Avenue Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PALISADES COLLECTION LLC; PROVIDIAN NATIONAL BANK 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 CARLISLE HOSPITAL AND HEALTH SERVICES AWAITING FOR LIENHOLDER'S ADDRESS PALISADES COLLECTION LLC; PROVIDIAN NATIONAL BANK AWAITING FOR LIENHOLDER'S ADDRESS 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 2310 New York Avenue Camp Hill, PA 17011 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best f1fies l knowledge or information and belief. I understand that false statements herein are made subject to th pPa. C.S. Se ction 4904 relating to unswom falsification to authorities. DATED: June 18. 2009 GOLDBECK BY: Michael Attorney fq1 cUArrEKI Y & McKEEVER McKeever, Esq. intiff FIB :, , f,•,,ssY ,r TIC 2009.' 22 08-4844 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- HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. SUSAN M. KLING RONALD L. KLING a/k/a RON L. KLING JR. Mortgagor(s) and Record Owner(s) 2310 New York Avenue Camp Hill, PA 17011 Defendant(s Term No. 08-4844 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: KLING JR., RONALD L. a!k%a RON L. KLING RONALD L. KLING a/k/a RON L. KLING JR. 2310 New York Avenue Camp Hill, PA 17011 Your house at 2310 New York Avenue, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on Wednesday, December 09, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $119,569.14 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I INC. TRUST 2006-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 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: 08-4844 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-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 , the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1- 866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure / YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 08-4844 2 Liberty Avenue Carlisle, PA 17013 08-4844 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 homer etention(&.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 69861 FC. 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 19106-1532 215-825-6318 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I INC. TRUST 2006- HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 7105 Corporate Drive PTX C 35 Plano, TX 75024 vs. Plaintiff SUSAN M. KLING RONALD L. KLING a/k/a RON L. KLING JR. Mortgagor(s) and Record Owner(s) 2310 New York Avenue Camp Hill, PA 17011 Defendant(s of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-4844 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: KLING, SUSAN M. SUSAN M. KLING 2310 New York Avenue Camp Hill, PA 17011 Your house at 2310 New York Avenue, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on Wednesday, December 09, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $119,569.14 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I INC. TRUST 2006-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 08-4844 IN THE COURT OF COMMON PLEAS To prevent this Sheriffs Sale you must take immediate action: 08-4844 I . 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-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 , the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-825-6329 or 1-866- 413-2311. 2• You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). 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. 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 08-4844 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://Www.phfa.org/consumers/homeowners/r al.asx. 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 k oldbecklaw com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 69861 FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 08-4844 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- HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 7105 Corporate Drive PTX C 35 Plano, TX 75024 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW Plaintiff vs. SUSAN M. KLING RONALD L. KLING a/k/a RON L. KLING JR. Mortgagor(s) and Record Owner(s) 2310 New York Avenue Camp Hill, PA 17011 Defendant(s) Term No. 08-4844 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: KLING, SUSAN M. SUSAN M. KLING 1076 Lancaster Boulevard, Apartment 2 Mechanicsburg, PA 17055 Your house at 2310 New York Avenue, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on Wednesday, December 09, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $119,569.14 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I INC. TRUST 2006-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE ACTION OF MORTGAGE FORECLOSURE To prevent this Sheriffs Sale you must take immediate action: 08-4844 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-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 , the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1- 866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed,org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 08-4844 2 Liberty Avenue Carlisle, PA 17013 08-4844 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 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 69861 FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 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-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. SUSAN M. KLING RONALD L. KLING a/k/a RON L. KLING JR. Mortgagor(s) and Record Owner(s) 2310 New York Avenue Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NO. 08-4844 CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Michael T. McKeever, Esquire hereby certify that I am the attorney of record I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has co Act. Ke Plaintiff in this action, and with all the provisions of the Michael T. D Attorney for G0J9 viZ!'R ;?u vY ?A ? •"1 _ 1 ; LI 1 ?`...! 1. .e .. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N008-4844 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-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 Plaintiff (s) From SUSAN M. KLING AND RONALD L. KLING A/K/A RON L. KLING, JR, (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 $119,569.14 L.L. $.50 Interest FROM 06/19/2009 TO DATE OF SALE PER DIEM AT $25.82 -- TO BE DETERMINED Atty's Comm % Atty Paid $198.00 Plaintiff Paid Date: 06/22/2009 (Seal) REQUESTING PARTY: Due Prothy $2.00 Other Costs TO BE ADDED Curtis R. Long, Prothonotary By:. /L // Depu y Name: MICHAEL T. MCKEEVER, ESQ. Address: SUITE 5000, MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 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 69861FC CF: 08/12/2008 SD: 12/09/2009 $119,569.14 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I INC. TRUST 2006- HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 7105 Corporate Drive PTXC35 Plano, TX 75024 Plaintiff vs. SUSAN M. KLING RONALD L. KLING a/k/a RON L. KLING JR. Mortgagor(s) and Record Owner(s) 2310 New York Avenue Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-4844 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: ( ) Personal Service by the Sheriffs Office/competent adult (copy of return attached). (?1 Certified mail by Michael T. McKeever (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Michael T. McKeever, Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by Michael T. McKeever (original receipt(s) for Certified Mail attached). ( ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Michael T. McKeever, Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, BY: Michael T. McKeever, Esquire Attorney for Plaintiff ?LL. o d O o0 u N? ?SlOW N ?t 7 -0 a N 00 'Till O a 000 ? w /0 c> Q m K? S V Q C r m ? a G7 r =m?? ?dO d All ¢Z Q O E Z cm M m I.- N CL U v b `? Z p V K ? R UJ d N Za O Z M F wLL U- 0 w zJ 4 o Z L) v? t? o NCQO t ?- 000 aZNLU U m m LLI CL N4 S Y o ]'G a cNn L Q,n m f3 LLI N zp )O? 4 d N W 0 3: E o U') :D w CL v d? N 0 O a m 'b Z N ,? r 10V al ww cE DOEp? am:z °- ll) = cS r-- u, 4 v 7 0. m fll 06 c a Z a m E ag. m a 0 a m 0 c r "m tl O 0 N oy 0 N c6 a? m 7 Z X Z N m Z y N a 00 4 at C4 NO 2 O N z? d ?a Y v pC 06 L V Z ? J Y ? LL Zd co N a. ' i m? O G G C? MN G C04 CD © p° hl w Q N 6 1 ® Cl Q 5 ??11NR o o g a ts Q rn N d m ` 0 yx? ansEc ?U- O E a7 ? a1 'D = a1 v- Cn {p m U N 7 U V E 11 SK ?r ?L Oa7 Q? `o `o ao m m N c N O p c d m c L _ z 00 E It U J u W y _E c o, c N °a V W Y a? w m P of x (n aS < Z) ???? y W N O Cl. 13 =LjU j 2Q c?' c CO -i _ ZQJ U) 0 ZQ' o 0 O U 0 F W F- m U z ZZO? W Z Z ZCO W E y Z'yv o ro > 8L J J Qn 0Y J} Q? . n c?ow o ZW W Y ????? U W> w- w M °1 U OF-Zc°j -iU) ON JN a? F in W Q D_ ? Q vYC,LiK QUOY-jr? aWQ UJW mm a)aW?Qtp EJI--J_O zOso=M E M z U r a N slAL 5T ? c 4,4 a ADILV?i M v ?Lo (b r- c6 m m C O C m E m U) Q T V R a m m c m CL _C O a R m 0 Y C d m d ~ a E a? ? M C N IL Q E O O O o U O Z 4) C'4 O Y z m N J a Z ui O M 0 cu o Y a M N U) O Na z 7 0 3 a N Y Y 00 o c a ? J E U 0 z> a a Q c Z o? o O rx N N ? m E : ''^^ V U Z a? d LL J a ti Y c co M E LL_ Z J T ? ? Q Z,o o _ d LL O U) io U) ( a c0 (n z LL O a) co ,AG G ' i?G ? m e? N (J r- U. 0 • a) S W TN ?? zO>O C0 in O f? p? G LL 0 00 N L v ~ 5 0 ;11N n o p > CO ,F •' a' ? O C ? R C 1 . y t .y p 7 N V Q V L a a.n C L m N m cg =U ER = C R R ? E Rv a °= Cc- O N U x a« °a ` Q - 05 a ` d c obi N a <- o C L o U _ E y 7 J - o c r w o6 l in cr W ? ? ? ? E 23 Z m w N U c • o Q J Z ? `o cL U 5 o 'R (0o E R E z JLLI u? U X _U _Ua>ti a? ????? J Q y L Q Lu N q U U CD C) o a (D IE L-0 `00 ? CL 16 E E z? C ~ z H w co Lu w ? yQ 8 m vYpWdN ov a C? CD en W p $y a) ? cW RmpaG? E -j ?JO w Z E F- 8 zO.-c=cm .- N M v L6 cD f-? ad c m a_ C O a m O m H m Q E V O N fT Cl N c0 0 N m U) N >. o C 7 O U A- v N C O L N 2 a U U- ti M LL L CO CO a m z J Y J z O i2 c? z J Y J J Q z ON w C? z J Y z Q U) D COO UNITEOSTA?iTLS AMALSEICEW 1 0 6 Ilk Q Z Date Produced: 07/06/2009 GOLDBECK MCCAFFERTY & MCKEEVER i A., m L., J?W& The following is the delivery information for Certified MailT"Item number 7111 4342 3630 0063 7283. Our records indicate that this item was delivered on 07/0212009 at 03:28 p.m. in CAMP HILL, PA, 17011. The scanned image of the recipient information is provided below. Signature of Recipient: d u 1,' ...n cV' , Address of Recipient:' ry 2310 tidw y0 RK RVE [t I Thank you for selecting the Postal Service for your mailing needs. If you require additional assistance, please contact your local post office or Postal Service representitive. Sincerely, United States Postal Service The customer reference number shown below is not validated or endorsed by the United States Postal Service. It is solely for customer use. Customer Reference Number: 4340453 16625576 69861 SK12-09 UNlTEDSTATES .?_.V.. .v. I'05TdLSERVKE. Date Produced: 07/06/2009 GOLDBECK MCCAFFERTY & MCKEEVER Q The following is the delivery information for Certified Mail'"ftem number 7111 4342 3630 0063 7290. Our records indicate that this item was delivered on 07/02/2009 at 03:28 p.m. in CAMP HILL, PA, 17011. The scanned image of the recipient information is provided below. Signature of Recipient: Address of Recipient: ry 2310 tiew YORK , RVE a Cgllrg c4 R,?L- 170 /1 Thank you for selecting the Postal Service for your mailing needs. If you require additional assistance, please contact your local post office or Postal Service representitive. Sincerely, Z United States Postal Service The customer reference number shown below is not validated or endorsed by the United States Postal Service. It is solely for customer use. Customer Reference Number: 4340453 16625576 69861 RK12-09 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 I INC. TRUST 2006- HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. SUSAN M. KLING RONALD L. KLING a/k/a RON L. KLING JR. Mortgagor(s) and Record Owner(s) 2310 New York Avenue Camp Hill, PA 17011 Defendant(s) Term No. 08-4844 SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I INC. TRUST 2006-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 , 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: 2310 New York Avenue Camp Hill, PA 17011 1.Name and address of Owner(s) or Reputed Owner(s): SUSAN M. KLING 1076 Lancaster Boulevard, Apartment 2 Mechanicsburg, PA 17055 RONALD L. KLING a/k/a RON L. KLING JR. 2310 New York Avenue Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 2. Name and address of Defendant(s) in the judgment: SUSAN M. KLING 1076 Lancaster Boulevard, Apartment 2 Mechanicsburg, PA 17055 RONALD L. KLING a/k/a RON L. KLING JR. 2310 New York Avenue Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: LOWER ALLEN TOWNSHIP AUTHORITY C/O STEVEN P. MINER/DALEY ZUCKER MEILTON MINER & GINGRICH, LLC 120 LIMEKILN ROAD NEW CUMBERLAND, PA 17070 LOWER ALLEN TOWNSHIP 2233 GETTYSBURG ROAD CAMP HILL, PA 17011 PALISADES COLLECTION LLC; PROVIDIAN NATIONAL BANK 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 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 CARLISLE HOSPITAL AND HEALTH SERVICES 361 Alexander Spring Road Carlisle, PA 17015 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 2310 New York Avenue Camp Hill, PA 17011 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: November 23, 2009 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff 20 99 0 "C -3 P Z= 0 5 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R-Anderson Sheriff - r Jody S Smith ' Chief Deputy Edward L Schor PP Solicitor Deutsche Bank National Trust Company Case Number vs. Susan M Kling 2008-4844 SHERIFF'S RETURN OF SERVICE 09/28/2009 07:41 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on 09-28-09 at 1941 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 Susan M. Kling and Ronald L. Kling, located at 2310 New York Avenue, Camp Hill, Cumberland County, Pennsylvania according to law. 09/28/2009 07:41 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on 09-28-09 at 1941 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: Susan M. Kling, by making known unto, Ronald L King, adult in charge, at 2310 New York Avenue, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 09/28/2009 07:41 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on 09-28-09 at 1941 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: Ronald L. Kling, by making known unto, Ronald L King, adult in charge, at 2310 New York Avenue, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 12/04/2009 Property sale postponed to 116/2010. 01/04/2010 Property sale postponed to 2/3/2010. 01/20/2010 Property sale cancelled on 1/20/2010 01/20/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ is returned STAYED, per letter of instruction from Attorney McKeever SHERIFF COST: $773.97 SO ANSWERS, January 21, 2010 V?NY R ANDERSON, SHERIFF A) L 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-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HF..8 7105 Corporate Drive PTX C 35 Plano, TX 75024 of Cumberland County CIVIL ACTION - LAW Plaintiff vs. SUSAN M. KLING RONALD L. KLING a/k/a RON L. KLING JR. (Mortgagor(s) and Record Owner(s)) 2310 New York Avenue Camp Hill, PA 17011 ACTION OF MORTGAGE FORECLOSURE Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 08-4844 DEUTSCHE. BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I INC. TRUST 2006-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 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: 2310 New York Avenue Camp Hill, PA 17011 I.Name and address of Owner(s) or Reputed Owner(s): SUSAN M. KLING 1076 Lancaster Boulevard, Apartment 2 Mechanicsburg, PA 17055 RONALD L. KLING a/k/a RON L. KLING JR. 2310 New York Avenue Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: SUSAN M. KLING 1076 Lancaster Boulevard, Apartment 2 Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS RONALD L. KLING a/k/a RON L. KLING JR. 2310 New York Avenue Camp Hill, PA 17011 1 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 PALISADES COLLECTION LLC; PROVIDIAN NATIONAL BANK 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 CARLISLE HOSPITAL AND HEALTH SERVICES AWAITING FOR LIENHOLDER'S ADDRESS PALISADES COLLECTION LLC; PROVIDIAN NATIONAL BANK AWAITING FOR LIENHOLDER'S ADDRESS 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 2310 New York Avenue Camp Hill, PA 17011 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best f personal knowledge or information and belief. I understand that false statements herein are made subject to th pe ]ties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: June 18, 2009 GOLDBECK cCAFFERTY & McKEEVER BY: Michael K McKeever, Esq. Attorney f Plaintiff I 08-4844 GOLDBECK McCAFFERTY & McKEEVER BY: Michael 1'. 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- HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. SUSAN M. KLING RONALD L. KLING a/k/a RON L. KLING JR. Mortgagor(s) and Record Owner(s) 2310 New York Avenue Camp Hill, PA 17011 Defendant(s) Term No. 08-4844 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: KLING JR., RONALD L. a/k.ia RON L. KLING RONALD L. KLING a/k/a RON L. KLING JR. 2310 New York Avenue Camp Hill, PA 17011 Your house at 2310 New York Avenue, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on Wednesday, December 09, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $ 119,569.14 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANI.EY ABS CAPITAL I INC. TRUST 2006-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 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: 08-4844 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-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 , 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.pliiladelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 08-4844 2 Liberty Avenue Carlisle, PA 17013 I 08-4844 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. uud.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(cr 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 69861 FC. Para information en espanol puede communicarse con Loretta al 215-825-6344. 08-4844 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6318 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I INC. TRUST 2006- HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 7105 Corporate Drive PTX C 35 Plano, TX 75024 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW Plaintiff vs. SUSAN M. KLING RONALD L. KLING a/k/a RON L. KLING JR. Mortgagor(s) and Record Owner(s) 2310 New York Avenue Camp Hill, PA 17011 Defendant(s Term No. 08-4844 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: KLING, SUSAN M. SUSAN M. KLING 2310 New York Avenue Camp Hill, PA 17011 Your house at 2310 New York Avenue, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale OD Wednesday, December 09, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $119,569.14 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I INC. TRUST 2006-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE ACTION OF MORTGAGE FORECLOSURE To prevent this Sheriffs Sale you must take immediate action: 08-4844 I . 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-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 , the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-825-6329 or 1-866- 413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 { 08-4844 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 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 69861FC. Para infonnacion en espanol puede communicarse con Loretta a] 215-825-6344. ALL THAT CERTAIN tract or Parcel of land and premises, situate lying and being in the Township of Lower Allen in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEING Lot No. 110 on the Plot of Lots of Spring Lots Colony, said Plan being recorded in the Cumberland County Recorder's office in Miscellaneous book 14, pa ;e 257, located on the North side of New York Avenue. 200 feet from Schuylkill Avenue, -f onting 40 feet on New York Avenue and extending back an even width 150 feet to Nina Alley. HAVING erected thereon a one story from dwelling house known as 2310 New York Avenue, Camp Hall, Pennsylvania. BEING THE SAME PREMISES BY DEED DATED 07/06/2006, GIVEN BY RONALD L. KLING, JR. TO RONALD L_ KLING, JR. AND SUSAN M_ KLING, HUSBAND AND WIFE AND RECORDED 09/12/2006 IN BOOK 276 PAGE 3118 GRANTED AND CONVEYED UNTO RON L_ KLING, JR. AND SUSAN M. KLING BEING KNOWN AS 2310 NEW YORK AVENUE, CAMP HILL PA 17011 TAX PARCEL NO: 13-23-0549-058 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NOOS-4844 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-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 Plaintiff (s) From SUSAN M. KLING AND RONALD L. KLING A/K/A RON L. KLING, JR, (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 $119,569.14 L.L. $.50 Interest FROM 06/19/2009 TO DATE OF SALE PER DIEM AT $25.82 -- TO BE DETERMINED Atty's Comm % Atty Paid $198.00 Plaintiff Paid Date: 06/22/2009 (Seal) REQUESTING PARTY: Due Prothy $2.00 Other Costs TO BE ADDED Curtis R. Long, Prothonotry By: A, 'WIvIll, Depu y Name: MICHAEL T. MCKEEVER, ESQ. Address: SUITE 5000, MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 Real Estate Sale # On August 19, 2009 the Sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA Known and numbered as, 2310 New York Avenue, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 19, 2009 By: Real Estate Coordinator The Patriot-News Co. 812 Market St. Harrisburg, PA•17101 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 i4e Patr1*otwXtws Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Leslie Kramer, 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: 10/23/09 10/30/09 11/06/09 to and'su cribed before me this 16 of November, 2009 A.D. Notary Public COMMONWEALTH OF PENNSYLVANIA No4ariai -Seal Sherrie L. Kisner, Notary Public City Of Harrisburg, Dauphin County My Commission moires Nov. 26 2011 Member. Pennsylvania Association of Notaries Writ No. 2008.4844 Civil Term Deutsche Banat National Trust Company, as Trustee for Morgan Stanley ABS Capital I, Inc., Trust 2008-HFS, Mortgage Pass- Through ,iCertiflcoss,. Series Atty- MI haslT. McKeever ALL THAT Ci??RTt?tN tract or Panel of land and premises, sitae lying and being in the Township of Lower Allen in the County of Cumberland and Commonwealth of Pennsylvania, mote particularly described as follows; BEING Lot No ,;110 on the Plot of Lots of Spring Lou Colony, said Plan being recorded in the Cumberland County Recorder office in Miscellaneous book 14, page 287, located on the North side of New York Avenue, 200 feet from Schu A,venue,fronting 40 feet on New York Ave* extending back an even width 150 HAVING erected theream a one story from dwelling house known as 2310 New York Avenue, Camp Hall, Pennsylvania. BEING THE SAME PREMISES BY DEED DATED 07/0612006, GIVEN BY RONALD L. KLING, lR. TO RONALD L. KIING, JR. AND SUSAN M KING, HUSBAND AND WIFE AND RECORDED 0911?) M IN BOOK 276 PAGE 31, GRANTED AND CONVEYED UNTO,RON L. KLING, ]R. AND SUSAN M. KLING BEING KNOWN AS 2310 NEW YORK AVENUE, CAMP HILL PA 17011 TAX PARCEL NO: 1.3-23-0549-058 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 23, October 30 and November 6, 2009 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Marie Co4e, Editor SW`6RN TO AND SUASCRIBED before me this 6 da of November, 2009 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNT! My Commission Expires Apr 28, 2010 Writ No. 2008-4844 Civil Deutsche Bank National Trust Company, as Trustee for Morgan Stanley ABS Capital I, Inc., Trust 2006-HE8, Mortgage Pass-Through Certificates, Series 2006-HE8 vs. Susan M. Kling, Ronald L. Kling a/k/a Ron L. Kling, Jr. Atty: Michael T. McKeever ALL THAT CEPTAIN tract or Parcel of land and premises, situate lying and being in the Township of Lower Allen in the County of Cumberland and Commonwealth of Pennsylva- nia, more particularly described as follows; BEING Lot No. 110 on the Plot of Lots of Spring Lots Colony, said Plan being recorded in the Cumberland County Recorder office in Miscella- neous book 14, page 287, located on the North side of New York Avenue, 200 feet from Schuylkill Avenue, fronting 40 feet on New York Avenue and extending back an even width 150 feet to Nina Alley. HAVING erected thereon a one story from dwelling house known as 2310 New York Avenue, Camp Hall, Pennsylvania. BEING the same premises by deed dated 07/06/2006, given by Ronald L. Kling, Jr. to Ronald L. Kling, Jr. and Susan M King, husband and wife and recorded 09/12/2006 in Book 276 Page 3118 granted and conveyed unto Ron L. Kling, Jr. and Susan M. Kling. BEING KNOWN AS 2310 NEW YORK AVENUE, CAMP HILL PA 17011. TAX PARCEL NO: 13-23-0549- 058. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY tLite sst .n P11 ?a'? .... PENS YLVA Deutsche Bank National Trust Company vs. Case Number Susan M Kling (et al.) 2008-4844 SHERIFF'S RETURN OF SERVICE 03/22/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. 03/28/2012 03:20 PM - Deputy Ryan Burgett, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 2310 NEW YORK AVE., MECHANICSBURG, PA 17055, Cumberland County. SHERIFF COST: $109.86 SO ANSWERS, May 25, 2012 RON R ANDERSON, SHERIFF -`)sl -6 - _,: rite aherr ie-.. i 76' f3- KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff DEUTSCHE $ANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY A-$S CAPITAL I INC. TRUST 2006-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006HE8 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff VS. SUSAN M. KLING RONALD L. FLING a/k/a RON L. KLING JR. (Mortgagor(s) and Record Owner(s)) 2310 New York Avenue Camp Hill, PA 17011 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 08-4844 DEUT?CHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I INC. TRUST 2006-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 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: 2310 New York Avenue Camp Hill, PA 17011 1.Name and address of Owner(s) or Reputed Owner(s): SUSAN M. KLING 2310 New York Avenue Camp Hill, PA 17011 RONALD L. KLING a/k/a RON L. KLING JR. 2310 New York Avenue Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: SUSAN M. KLING 2310 New York Avenue Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE RONALD L. KLING a/k/a RON L. KLING JR. 2310 New York Avenue Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: LOWER ALLEN TOWNSHIP AUTHORITY C/O STEVEN P. MINER/DALEY ZUCKER MEILTON MINER & GINGRICH, LLC 120 LIMEKILN ROAD NEW CUMBERLAND, PA 17070 LOWER ALLEN TOWNSHIP 2233 GETTYSBURG ROAD CAMP HILL, PA 17011 PALISADES COLLECTION LLC; PROVIDIAN NATIONAL BANK 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 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 CARLISLE HOSPITAL AND HEALTH SERVICES 361 Alexander Spring Road Carlisle, PA 17015 PALISADES COLLECTION LLC; PROVIDIAN NATIONAL BANK C/O PHILIP C. WARHOLIC ESQUIRE PO BOX 5866 HARRISBURG, PA 17110 LOWER ALLEN TOWNSHIP C/O STEVEN P. MINER/DALEY ZUCKER MEILTON MINOR & GINGRICH LLC 1035 MUMMA RD STE 101 WORMLEYSBURG, PA 17043 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 2310 New York Avenue Camp Hill, PA 17011 I verify that the statements made in this affidavit are true and co to the best of T"ffurygon and belief. I understand that false statements her n are ade subject to the penalties of 18 Pa C.S. lion 4904 relating to unsw falsification to authorities. DATED: By: , XML LAW GRO , P.C. Michael McKeever Pa. ID 56129 -Jay E. Kivitz Pa. ID 26769 -Lisa Lee Pa. ID 78020 _Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 -Thomas Puleo Pa. ID 27615 -Ann E. Swartz Pa. ID 201926 -Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff 08-4844 KAL 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- HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 7105 Corporate Drive PTXC?5 Plano, TX 75024 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE vs. SUSAN M. KLING RONALD L. KLING a/k/a RON L. KLING JR. Mortgagor(s) and Record Owner(s) Docket No. 08-4844 2310 New York Avenue Camp Dill, PA 17011 Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: KLING, SUSAN M. SUSAN M. KLING 2310 New York Avenue Camp Hill, PA 17011 Your house at 2310 New York Avenue, Camp Hill, PA 17011 is scheduled to be sold at Sheriff s Sale on ;Wednesday, June 06, 2012, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce Ithe court judgment of $119,569.14 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I INC. TRUST 2006-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 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: 08-4844 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-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 , the back payments, late charges, costs and reasonable attomey'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)- 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.philadelphiafed.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 Carlisle, PA 17013 08-4844 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.hudgov 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 ora/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 home=ntion@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 69861FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ALL THAT CERTAIN tract or Parcel of land and premises, situate lying and being in the Township of Lower Allen in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEING' Lot No. 110 on the Plot of Lots of Spring Lots Colony, said Plan being recorded in the Cumberland County Recorder's office in Miscellaneous book 14, page 287, located on the North side of New York Avenue. 200 feet from Schuylkill Avenue, fronting 40 feet on New York Avenue and extending back an even width 150 feet to Nina Alley. HAVING erected thereon a one story from dwelling house known as 2310 New York Avenue„ Camp Hall, Pennsylvania. BEING THE SAME PREMISES BY DEED DATED 07/06/2006, GIVEN BY RONALD L. KLING, JR. AND RECORDED 09/12/2006 IN BOOK 276 PAGE 3118 GRANTED AND CONVEYED UNTO RONALD L. KLING, JR. AND SUSAN M. KLING, HUSBAND AND WIFE BEING KNOWN AS 23 10 NEW YORK AVENUE, CAMP HILL PA 17011 TAX PARCEL NO: 13-23-0549-058 08-4844 KML'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- HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 7105 Corporate Drive PTX C'35 Plano, TX 75024 IN THE COURT OF COMMON PLEAS Plaintiff vs. SUSAN M. KLING RONALD L. KLING a/k/a RON L. KLING JR. Mortg4gor(s) and Record Owner(s) 2310 New York Avenue Camp Hill, PA 17011 Defendant(s', of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 08-4844 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: KLING JR., RONALD L. a/k/a RON L. KLING RONALD L. KLING a/k/a RON L. KLING JR. 2310 New York Avenue Camp Hill, PA 17011 Your house at 2310 New York Avenue, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on Wednesday, June 06, 2012, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $119,569.14 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I INC. TRUST 2006-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 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: e 08-4844 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-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 , 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). 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: b=://www.philadelphiafed.orp/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. 1F 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 08-4844 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://?uww.phfa.orz/consumers/homeowners/real aux. 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?tf,-ntion@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 firin's Homeowner Retention Department is David Fein who can be reached at 215- 825-63118 or Fax: 215-825-6418. Please reference our Attorney File Number of 69861FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ALL THAT CERTAIN tract or Parcel of land and premises, situate lying and being in the Township of Lower Allen in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEING Lot No. 110 on the Plot of Lots of Spring Lots Colony, said Plan being recorded in the Cumberland County Recorder's office in Miscellaneous book 14, page 287, located on the''North side of New York .Avenue. 200 feet from Schuylkill Avenue, fronting 40 feet on New York Avenue and extending back an even width 150 feet to Nina Alley. HAVING erected thereon a one story from dwelling house known as 2310 New York Avenue, Camp Hall, Pennsylvania. BEING THE SAME PREMISES BY DEED DATED 07/06/2006, GIVEN BY RONALD L. KLIING, JR. AND RECORDED 09/12/2006 IN BOOK 276 PAGE 3118 GRANTED AND CONVEYED UNTO RONALD L. KLING, JR. AND SUSAN M. KLING, HUSBAND AND WIFE BEING KNOWN AS 23 10 NEW YORK AVENUE, CAMP HILL PA 17011 TAX PARCEL NO: 13-23-0549-058 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-4844 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-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 Plaintiff (s) From SUSAN M. KLING, RONALD L. KLING A/K/A RON L. KLING JR. (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: $119,569.14 L.L.: Interest FROM 6/19/2009 TO DATE OF SALE PER DIEM AT $25.82 Arty's Comm: % Due Prothy: 2.25 Arty Paid: $997.97 Other Costs: Plaintiff Paid: Date: 1/27/12 O'A David D. uell, Prothonota (Seal) By: 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 TRUE COPY FROM RECORD fn Testlmony when{, I here unto set my hand and the Seal Of gild L01Nt at Cadisle, Pa. This of Prothonotary On February 6, 2012 the Sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA, known and numbered as 2310 New York Avenue, Camp Hill, PA, 17011 more fully described on Exhibit"A" filed with this writ and by this reference incorporated herein. Date: February 6, 2012 d" B -? V Y• For Claudia Brewbaker, Real Estate Coordinator r: +L" t ,06 '? ?` 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- HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 7105 Corporate Drive PTX C 35 Plano, TX 75024 vs. )NO TP k C J" 2 AN 10: _!',",BERLAND COUN I ",ENNSYLVANIA IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff No. 08-4844 SUSAN M. KLING RONALD L. KLING a/k/a RON L. KLING JR. (Mortgagor(s) and Record owner(s)) 2310 New York Avenue Camp Hill, PA 17011 Defendant(s) TO THE PROTHONOTARY: PRAECIPE TO VACATE JUDGMENT Kindly vacate the judgment upon payment of your costs only. By: 11 LAW GROUP, P.C. ael McKeever Pa. ID 56129 Yis ch a a Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff ? 449-?Up? IM V? IL -)-I I ; q KML LAW GROUP, P.C. Suite 5000 - BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 f ?) ?' T,& P`1 ? . '?.. -0 COUNT" BERLAN EIANSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I INC. TRUST 2006-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff VS. SUSAN M. KLING RONALD L. KLING a/k/a RON L. KLING JR. (Mortgagor(s) and Record owner(s)) 2310 New York Avenue Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 08-4844 PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended without prejudice upon payment of your costs only. KML LAW GROUP, P.C. F/K/A-GOLDBECK McCAFFERTY & McKEEVER By: richael McKeever Pa. ID 56129 ay E. Kivitz Pa. ID 26769 -Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 Thomas Puleo Pa. ID 27615 David Fein Pa. ID 82628 _Andrew Gornall Pa. ID 92382 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff . KML LAW GROUP, P.C. Suite 5000 - BNY 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-HE8, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE8 Plaintiff vs. SUSAN M. KLING RONALD L. KLING a/k/a RON L. KLING JR. (Mortgagor(s) and Record Owner(s)) Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-4844 CERTIFICATE OF SERVICE Jessica Doebley, hereby certifies that he/she did serve true and correct copies of Praecipe to Discontinue and End and Praecipe to Vacate Judgment and all supporting papers attached hereto upon Defendant, by first class mail, postage pre-paid, on (p f I Q 12 SUSAN M. KLING 2310 New York Avenue Camp Hill, PA 17011 RONALD L. KLING a/k/a RON L. KLING JR. 2310 New York Avenue Camp Hill, PA 17011 KML LAW GROUP, P.C. F/K/A GOLDBECK McCAFFERTY & MCKEEVER By: L ?sica Doebley, Legal Assistant jdoebley@kmllawgroup.com 215-825-6327 (Direct Phone)