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HomeMy WebLinkAbout08-5395SHAPIRO & DENARDO, LLC BY: CHRISTOPER A. DENARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 DANIELLE BOYLE-EBERSOLE, ESQUIRE, ATTORNEY I.D. NO. 81747 MICHAEL CLARK, ESQ., ATTORNEY I.D. NO. 202929 / ILANA ZION, ESQ., ATTORNEY I.D. NO. 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 08-033261 U.S. Bank N.A., in its capacity as Trustee for the registered holders of MASTR Asset Backed Securities Trust 2005-WMC1, Mortgage Pass-Through Certificates PLAINTIFF ; VS. Steven L. Wilson ; 1409 Goodyear Road Gardners, PA 17324 DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: ivil erM COMPLAINT - 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 THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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 Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES, USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN LA CORTE EN FORMA ESCRITA SUS DEFENSAS O SUS OBJECIONES A LAS DEMANDAS EN CONTRA DE SU PERSONA. SEA AVISADO QUE SI USTED NO SE DEFIENDE, LA CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO O NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ES PEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO O SUS PROPIEDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DI ERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 SHAPIRO & DENARDO, LLC BY: CHRISTOPER A. DENARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 DANIELLE BOYLE-EBERSOLE, ESQUIRE, ATTORNEY I.D. NO. 81747 MICHAEL CLARK, ESQ., ATTORNEY I.D. NO. 202929 ILANA ZION, ESQ., ATTORNEY I.D. NO. 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 08-033261 U.S. Bank N.A., in its capacity as Trustee for the registered holders of MASTR Asset Backed Securities Trust 2005-WMC1, Mortgage Pass-Through Certificates PLAINTIFF vs. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: O k - .33 95 G, Qg JZ4A1 Steven L. Wilson 1409 Goodyear Road Gardners, PA 17324 DEFENDANT(S) COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, U.S. Bank N.A., in its capacity as Trustee for the registered holders of MASTR Asset Backed Securities Trust 2005-WMC1, Mortgage Pass-Through Certificates, the address of which is, 12650 Ingenuity Drive Orlando, Florida 32826, brings this action of mortgage foreclosure upon the following cause of action: 1. (a) Parties to Mortgage: Mortgagee: Mortgage Electronic Registration Systems, Inc., as nominee for WMC Mortgage Corp. Mortgagor(s): Steven L. Wilson (b) Date of Mortgage: December 27, 2004 (c) Place and Date of Record of Mortgage: Recorder of Deeds Cumberland County Mortgage Book 1892 Page 3818 Date: December 29, 2004 The Mortgage is a matter of public record and is incorporated herein as provided by Pa. R.C.P. No. 1019(g). A true and correct copy of the Mortgage is attached hereto and marked as Exhibit "A" and incorporated herein by reference. (d) Assi timents: Assignor: Mortgage Electronic Registration Systems, Inc., as nominee for WMC Mortgage Corp. Assignee: U.S. Bank N.A., in its capacity as Trustee for the registered holders of MASTR Asset Backed Securities Trust 2005-WMC1, Mortgage Pass-Through Certificates Date of Assignment: As Recorded Recording Date: As Recorded 2. Plaintiff is, therefore, either the original Mortgagee named in the Mortgage, the legal successor in interest to the original Mortgagee, or is the present holder of the mortgage by virtue of the above-described Assignment(s). 3. The real property which is subject to the Mortgage is generally known as 1409 Goodyear Road, Gardners, Pa 17324 and is more specifically described as attached as part of Exhibit "A": 4. The name and mailing address of each Defendant is: Steven L. Wilson, 1409 Goodyear Road, Gardners, PA 17324 5. The interest of each individual Defendant is as Mortgagor, Real Owner, or both. 6. The Mortgage is in default because the monthly installments of principal and interest and other charges stated below, all as authorized by the Mortgage, are due as of October 1, 2007 and have not been paid, and upon failure to make such payments when due, the whole of the principal, together with charges specifically itemized below are immediately due and payable. 7. The following amounts are due as of August 31, 2008: Principal of Mortgage debt due and unpaid interest currently due and owing at 9.5% per annum calculated from September 1, 2007 at $3.83 each day Late Charge of $6.31 per month assessed on the 16th of each month from October 16, 2007 to August 16, 2008, (11 Months) Suspense/Unapplied Balance Accrued Late Charges Appraisal Fees Property Inspection Title Search/Report Fees Attorneys' Fees and Costs TOTAL $14,732.22 $1,401.78 $69.41 ($12.87) $174.23 $111.00 $31.50 $250.00 $1,500.00 $18,257.27 8. Interest accrues at a per diem rate of 3.83 each day after August 31, 2008, that the debt remains unpaid, and Plaintiff may incur additional attorneys' fees, as well as other expenses, costs and charges collectible under the Note and Mortgage. 9. The attorneys' fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriffs sale. If the Mortgage is reinstated prior to the sale, reasonable attorneys' fees will be charged based on work actually performed. 10. Notice pursuant to the Homeowners' Emergency Mortgage Assistance Act of 1983, 35 P.S. § 1680.402c, et seMC ., was sent to each individual Mortgagor at their mailing address and/or the mortgaged property address by first-class mail and certified mail. Pursuant to the act of December 21, 1998 (P.L. 1248, No. 160) (Act 160), this Notice contains the information required by the act of March 14, 1978 (P.L. 11, No. 6), 41 P.S. Section 403 et seq., and separate Notice of Intention to Foreclose is not required. Copies of the Notice are attached hereto as Exhibit "B". WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in rem in favor of Plaintiff and against Defendant, in the amount set forth in paragraphs 7 and 8, together with interest, attorneys' fees and for other expenses, costs, and charges collectible under the Note and Mortgage and for the foreclosure and sale of the mortgaged premises. Date: DMOR S & D File No. 08-033261 SHAPIRO & DENARDO, LLC BY: &W- oun Attorneys for Plain f sair3 +OCERT P. ZIEGLER "ECD;IDER DF DEEDS 7'1 2301 ca 29 nf,10 49 LeNw?c??i cm. uwmm 10962 a¦Irsasap ?: ucnrts O AG _ t+eahltaiiaes 11.Oi THIS MORTGAGE is nulde this 27 tRM r 0.aolaiba0L between the Mortgagor, HTxV r b WILOOet of o.e.rb.r, 2004 (het+cin "Barmw&"). =d rho bicntgagoo. MFRS. "MW. is Motto Blearnatic Syaten" Inc. P,um is s eepa' cotPe 86,6 *0 is netiag rololy as a mmdoee for L ukr and LendIA RMCC sots and mW MM5R5 is otgatdwd and exit order the laws of l telawanG and bu m addteas and a >f 2026. Hint, bQ 4&%I-Z026, wJ- (SW MM RS. SOP mTba of P'.0. Aax mic aamtna= . Optp . is a crnPq MVWIW Md. tang MKIM the laws of CUarat=& addrtmis P-0. MW 54069 Ws AVGWJM, CL 90064-0089 ti?wae (bemiu lAndtel. SAS, 180LT8WOf 'a' °d to I AMkr in the principal I= of U.S. $15, 000. 00 iy4?s hT evidenced by Barrowtr's dote dated 15naaaabnr 37, $004 which ad va th damns and reuearalr tbeteof Oweln'Wft") Ptowlding for molly inWmn of prin*at and intetesL w ith fhe balance the lddebtedner% ff W wo= Pald, dot attd Payable on Ja+nn>Atry lo, 2020 TO SECURE to Leodar The rqmy=t of ma iadebtedueas evidenced by the Now, wltb P4' m m of all otbar sums, with die bAmmt ft"wo, adraacad in eaootdanoe bta+:wlth to #4thct the Waft seal m *m=a-, the of tide hMct> bye; and the pWonalKt of the wyea mda and'8mcv U Of Bvmulm li wAm mngti=4 Btnrower does VW to the mkt sins and aWFz of mW the foltowing" ?? Leodet and Lendar"a anoeeraot: wad aaaigtta) t,Mp pWcM located is the Couuy of Suue ofPotmaylveua:_ XIf.VAMA - 5ornnd Nlatgr=e_ TIaO-BTiM,r/88LMC t1Flttrpttbt O'1UI'R116?Cp gom7v-.- a+rn/:oar PRee t of7 8K 1892PG3818 Eoooo nl&)D4 I I A 'd I IlOt7tas 1?L DiBCi;ZD9'2? ?? 110t7e1E Bt1i011bi » TEIT ??, AC4ZD »i'0 1tltb IQDZ A PAIM X221 aP liI1D which has the eddreas of 1409 GOMT>rAit a=, UUMMM P'enasylvatda 17324 MP (berein "Property Addrosa"); (SOV04 city). ?] MOM UM with all the Ott now or b mdbw accord an the property, and nit eavetnaaata dghta, reach Mom and Of the all g. mid MM add opmpmy (Or a be and r+e 60 la poet of on p if B atty °n??,br dda legal tide tode Ilse lnoe?eu wooed to $onower ^ JIMtM wdm*m& Old mm hat Wd ady in &a Scm* coatam MM (aa nolubme for Lander and Leadees ai ccum md * ha, if mmmzy to ' ?rirtb hw ur thota fit, inclm&C but not GntiCed 10, to ?) h, tall the s" Alk rtt Pr to 0 "ei" lo or as of fl* b fmaclose and required of Lauder pa; and to take any action "gO et and Oovfty the ?epe?F. a0ked of dw saw bwft as -W bm dm right to except for 4E?ctambtaoces of derma and r mwmm dm $0rrnwer ww Mid dW 40 Pmrhy mb and %Q defend ?g dw prop" gnat aU dematda, subject to mmmkmmt of mmd. L- >'?aoea! of P ? Viand Career oaf and ax?x as fnlloaa;+ lndebte9neei evidenced by ft Not aunt( late daro, 13on? " > r pay vrhen doe the prindpal and inoeerat Z- plaltds fbr'Paaaaea aural ? provided in the Note, Par to Leader on die dry nwq* pay?q Subject to sae doe an* #a e'iaO NOW, MM doe Nato to a dle M wais pveraid by in 1511 a Lander fall, & SM VVM shalt for: (a) yeady tues and aaaesmmata Which .p OW, (b) yntiy loaaauold ptymeatt or `? a? inf°r'tr over dda Montage as a lieu on dm rgppty; ro) lt:omd m* cm tbC ftolwiy, if any, (c) yearly hazard w Pmmitmn; (d) Yawly flood bwaremax p gmbm % if any. Tbm items, we called.7mow Iiams Leader WW dale, Collect and hold Fogda m an amomat not 10 exceed the ma><ittrma ataoant a lends' 1br a %datzUy tray. at afsted mortgage loan may mgokc ton Be+raw l miaow "cum under die faded Real 110110 Soulemeot Proocdmes Act of 1974 as ntawuled from tittae oo, 12 U.S.G f 2601 et mq. (W-SFA"). amI- modier lap that applies to the POD t namt. I,eOder If so. under way, at any tigm, copra and hold launch in an amo mt not to exceed &a Iftm may dao AmOmt of Ftaada &a on dte bads of cturleut data +tdd marooabla e0notea of exPon hVCV of fVteae F.easvw AeU or odter*iw in accardamae wA tapgt Wa lasso. The Punch shall be held in en inadtntlca reboot: drip am iryoted eodty (including L mdIar, if Lender is sash ma fnsoitudon) or in gay FedwW Hama Learnt' Leader ' or the Fonda to pyty the p9=W Io"L Laodor may not $brtowra ftar aPP?r aoaiyzrnd die eaetnw atxoont. of Pmtda, ae sunfly and applicable law venfyltg the gm" lw m. tadeaa Leaft Tanya 3'MW t lraotatist on doe Panda paw 1, in aamb such a charge. However, Leader may n9Wn 80,vwer to Pay a oAO- dMe age far an independent real cam tax r+epm tftg cornice need by Leader in mmndm MM IN$ loan, Uwe" wficable h- des oftrwise, U man agreement is made or appypbig law ?? bftrM to be paid, Leader " not be req*W TD agm PAY B my iMEM or emninip on the FW4& $orrowat and 'm u0l in nvAidag, h W"cr, that WW= drill be paid an On Pmtdv. I.,$. shaft give in 8anonrr, witboatt dwp, the Ada Mg Of 00 Rmds, d*wl gC oaths and debits to ails Pmds and The pupose for wldch each debit to If the Ftmdi Laid ?°? au atiditiotarl aegnity for all amps seaaed by this by Leader eyemd the AMOQ s pemltted to be held Bmmwer far aloe a em Paads in ecaortlaaa wltlt the rwjWrmmft of gtibrpitapplieeb .la If w, dyI.e+moo ehalf the p ?t to held by Leader at any dme ie not =Mdem to the ublo lade the ont PRY Aaerosv Ixms ;vhtm don, Lander may so o noatifq Bthe Funds Borrower in P 04NUVAa UKWOgM ti4gMUMWr DOC DOW"u-M W23130ar PrteZofl !cats9it9 BK 1892PG3819 110278!6 11087283 wridng. and, in such case borrower e6aU pay to Leader tbo one= necessary to make Up the defdeocy. Borrower aball make up the defid nacy in no mote Om twelve monthly PaynumM at Leader's sole ddatxotion. Upon Payment in fide of all am secured by this Mortgage, Leader OW prumpsyy tdimd to Borrower any Funds held by Trader. If, under pterwtph 17, Leader aball acquire or sell the Property, Lander, prior to doe acquisition or sale of the Property, shall agtply any Dodds held by Tend at dro praeof acquirition or sale as & credit agaloat the sums secoaed by this Mortptge, the Note cation of lNer taws. UWen applicable law provides otimwiae, all payoments received by Lander under and parngraphs t acid 2 bored shall bo applied by Leader Stu in payment of astsoamts payable to Lowder by Borrower under Pwa rsph 2 Wed, rhea to interest pay" on the Nato, and then to the prioelpal of the Noon. 4. Prior Moeiga®es sad Datde of Trtrsti C.himW Leal. Boamm shill Peidam all of barowees obHgkdona under my murtaa8a, dead of tmet or other security ageeemeat with a dttn whack has priority ova Ibis Mortgap, Including Borrowor'a covemntr to molm payments wbea due, Borrower &M U pry or taww to be paid all taxes, MseaoU" and adter charges, Enos and bapoeidons att ibatsbie to the Property whicb may attain a priority ova this ;+ModpgA and to seebold p%ya wn or pound rtxhos, if atty. S. Bs arni Ionvanae. Borrower shall keep the avr ovauent2 saw existing at heradtor trot ed on the Pmprrty Wand Apium loss by Me, Ituacda included witlda Iht bras "extended coverage", and such other bazw* at Leodcr may regoim and in such amounts and for nook periods m 1-der may regaise. govidedL C elm ? pop iftg On ins shall be chosen by Borrower sobject to Vp uM by Leodw, approyd shaII rot be Wwwonabiy whit d& AD insoemce policies and reaewats *creof AA be in it than atxxpuble to Lender and shall haclode a emodard mortM Clause In favor of and in a fens acceptsMa to Leader. Leader dhdl lave dw right to Wd the policies cad rrmewals t creof. sabjeat to the Itxa1a of any mcstgapte, deed of atilt of ausar snewlty opowmat with a lice Which bas pdadty over dda Morepp. In the OVCM of loss, Borrower "sin prompt notice to die insar== carder ad Lender. Lender mry maim pewof of k»s if not made ley by Borrow. If rho Property is abandoned by Borrower, or K Baemwer tgdls to ragxmd to L=dw wit n 30 days from the dsm rodeo is nter'1od by Leader to Boriovattr that the ist a?nee an-da offer to sotlle a benelioc, Tamler a satbodsod to collect sod apply the iasnrom ptoeaeds at Ltmder's option of the Property a to the saws sonored by this Mortpgo, d Nwrra don acted Mh pe or Pfwu ty Lafaeboldsi CAndotaNd IN.- Planned Usdt DerellopatulL Bonvwer trial! k=V that Property in good rqW and shall not ooaupit waste or pertait impsiston A at deterioration of dw Propeety ad shall eoanpty with the ptovldm of any lase if this btmtpp is an a leasehold. if tbb Mortgage is on a Unit in a nondontirdsan a a plsaaed unit &-M ME no c a. Bottowa *NU perfform all of Rom Ws obBge=w watts the ded=W w or cavemses otoll" of tit the condors adorn or plamsed a dt deveiopmeftt, to Wawa sad replanons of the candommium or planned unit developmeM and cowtitoent documents. 7. ftoftclUe of Filer $ 9*01 q. if Borrower tills to perfarm die covanaaor and sgssem cm contained in this Mortgage, or if any action of proceeding it OMMenced wltielt naarlttlly dfix a Leader's interest in the Ptopcty, then Larder, at Leader's opdarh, upon notice to Barroww' MW MWM each appesrEWW' diaberse such stoma, including ruserm ble attorneys' tea, and tab Inch action M a zteeaauy to pn*mt Letat)cf't ieteteat, If t carder tmegohed mar4W hwwrance as a coodtdon of melting des loan shed by this Mortgeps, Beeravsor shell pay the presnioma required to maintain aueh insurance in CROct until Such time to the requirement for such insurance tertainawa in auvrdan¢e with Boaower'a and Leader's written apeeaswt or applicable law. Any smovists dabarrsed by Under parwitat to this peragrsph 7, with merest taeraoat. at the Note rata, shall become additional hebbaadness of Harrower wznrod by rids lVlt gqW Unless Botroom and LmJw agree to other cams of payment, swdt amounts shall be pwj" upon notim from Larder to llwrowot requawks payaMeeat thereof, Nothing eonlained in this par Vq* 7 31ts11 require Lender to incur may apewse at take any acfm hereunder. & bwps ikm Lender may mda or cause to be merle ressomble entries opera and Wspecdoas of the Pwperty pmvided dot Lander shell give Blur over notice prior to any such inspection sptxifylwg rewasble c name dmt'fbr tnlaoed to L ander's Inoarat in the Property. 9. Candmstatloei. The p mcmda of any award or claim for damages, dirW or Conseepentiai, in oorm..,atiw n'c,tic,,un., with any eomdet aadon or odd taking of rho Prt>perty. or part thereof or for conveymm in lieu of candcrm utr ht toby assigiaed aad:shaU be pdd to Leader, subjectto the ternaa of any mortgage, deed of tnw or other security gmnant with alien which has ptiodtp over this Mortgage. PEtt 4MVAMA - 8aooad MMgxP - M -£ AAMM.MiC TJ UMM tN8'1 UKmT Nero 3W noamAa Pap 3 d7 xea»aa.vra aainnaol B!t i 892PG3820 11097/99 11007445 It Borrower Not Roleosed; Fostee once By Lenders Not a Waver. Extea>non of the am for Payment or modjfle don of albOttization of rho sums secured by this Mortgtage Sn by Larder Borrower and wad llasur in imereet Of Baxrwm Shall not operate to release, is my uwkner ' the liability of the original any oatwcaxsorl to interest- rvwa'a Lender shall m be ra plied to conmaoxtce paoccafflop against such sumbaw or refwe to mend time for pgymnet or otlWMas modify amortization of the am wzured by this Wctgap by now of ter demand made by the Original Barnarer and Boa~$ saeoeeaotl in Interest. Any fatbewabft Loader in exerew,19 anY right or mmody hereunder, err othetwise lkffmdod by aappHcabio law, vi au oat be a waivtx of Or preclude the exercise of any etch right or remedy. 11. Soemoors wad Aftigns Ber9adi Joint and Several I sihiglal Ce ritnem The WYMnntm and fiats betcla coutaimd. shall Wad. wad the rights boreandar shag infer to, thentalpredvo aoeeasats sad uqu of I?atdes mad BOMMCF, aatbject W the Me"' lane Of pa NFVb Id be mf. All mveannp rid a wrens of B 'A' M*Pft ormw- sb9U b0 Joint and several. Arty Borrower who eo•ligos this Mort;xiM but does aot "mm the Note, (a) u this b(WA a only Lo timctPa, OVA and W*fty lieu Borroeag interest is the Property to Leader arkder r and of theta Mortgage, (b) is not palonalhy liable no the Note or tinder this Mortgage, and (c) agues that my ethos Borrower hetntmder may agree to extend, modify, forbear, or =kc my other accommodations with regard to the am of this Mortgage at tha Nose within dear BOrrewWa consent turd without relcasing that Bonvwa or a dU ft this p as to that Borrogror'1 intatW in the ftVctty. 1S. Nedm auvA for my notice ragah d under appliMble law 1o be van In owbaunumer, (a) any notice to Bono waar provided far is this Mortgage shall be Om by doliverisS it or by =dH4 3och notice by certified mail addressed to Bmumor at dw Property Address or at mob other address as Borrower may dasigau by notice to Leader as provided herein, and (b) any notice to Lander 9bsll bC given by cect fliod mail b LtlstierIa addteas stated ltaea b or to such od= aft= as Ltatdrt may by metiers to BOrrvww as provided borein• Any nodes provided for is this Mortgage shall be deemed to have bees given to Borrower or Lender when given in the maw designalaxi Haan, 13. Goverrdng 14w; Semabillty. The slate and IN49 laws applicable to this Mortgage shall be the laws of rho jobdistien is which the Wopatty is located. The fol+agodng som nce 00 not hinds the s Mlle"gr of Federal law to this Mortgoga In the event Um say prw4dao or d=se of this Moagage er die Note OooaShptm with sppliabde law, sack conflict shall not amt otber prvvidooo of this Mortgage or the Note which can bo given effect wiHroot the 9orllieft psomision, and to this tad the proodgas of tlds Mortgage and the Nate are declared to be AV VM ? Asa, .n"C ". "874 tMe and "t??rnSW feW 10CWC 90 wane to the extent not prohibited by 14. Dwwwee-& COW. Bmtuvw shall be fiunished a COafarmld copy of the Ncsta; and of this Mortgage at the tlmo of execution or after recardarm hereof. celmb ? rtlor Lord Ap+e U=L Borrower "MM all of Borrower's dAi diMsundo say haute ungr-v ameet, rtP* Or odter ltlaa agrament which Barrvwar 009M late with tender. Leer; at Leader's option, may require Bwo??w/w?? to alreeute and deliver to Lwdbr. In a farm acceptable to Lender, 1, aaalgnmtm of say rights, olarirrt9 or tlehom which Borrower may barvt sgama pafics. vd" aatpply rebut, materials or services in coaneroon with rats made to the Propety. 1ti. Troooftr of rite Props* or a Beratt bond In Borrower. if all ar any part of the Wag aty or any interest in it is sold or transferred (or if a beneficiai ima its qw9vr is add or trandared std Borrower is not s n9aaal Parton) Without Lapws prior Adam consent, Lender may, at its 000% requite. h`atnedim paymom in full of all sums secured by this h1w.&{ gtt. However, this option shall not be exercised by Lander if exercise ie prohibited by federal law sus of the dais a/fteas Mootgop. If Lender exermoss thin optics, La Ww 6A give Btnrowcr notice cf aceelerapoa. The W= &ail provide a period of not loss than 30 days from the dais the mWee is dslivemd or rnalled within which U roww most pay aU Brans secured by this MearWp. If BOMWet fail to pq+ thapa.m.?.a?l?ma prior tera?re v_xJ*atloa of this pampa, Leada rosy invoke my tmedles paadtted by this mortgage without further waft or den-ad m Baramwer. NON-UNM?RYM COVENANTS. Boarowa andLcndarlbrowcovarmt and aggtee a folim, 17. A cederadw, Remedies. Upon B?yw?mww's breach Of sty covenant or agteetne nt of Borrower in this MU428e, bd!?g the ctrver>t M to pay wh . en due any, sums recmad by this Mortgage, Lewder _ prior to AcWl radon shall give notice tO Bortvwtx a9 provided by applicable law ; (2) the action rr_guvired to Cure mach breech; (3) a date, not lour than 30 yes ammgoomdrings; from tM daft ft aodax:is ha trailed to BOMWer, by which such breach must be cured; end (4) that Mute to sate such breach an or Woes, ob-, Pats MnVAMA - Second ?&"ple-1110..>!MAMM.MC UM rOM MMUMM nOWWau Fong 9100 ooavrrar.V" esnaneo> Faae of 7 8K I892PG382 I 110276a5 11017415 date Rxdfwd in the notice tray teat in woo n wn of the waoae secured by this Mcegaae, foreclosure by jndieial plncadiag. and ago of the Ptopctty. The notice shall further inform Borower of the dOt to r kwb to rater acceleration and the right to assert in the fote+cloaocr procetf ing the nonexistence of a defrmlt or any ad= dadenoo of Borrower to acaden?dou and forectocum If the breach is not wired on or before the date tpecltiod in the notice, Lender, at Latdar'a option, tray dochm all of the scans secured by this hdmtgW to be immadlately due and payable vadmrt further demand and may foreclose tlda Mortgage by judicial ,pioweding, Leader shall be entitled to collect in such proceeding an expenses of foreclostue, including, but not limited to. reasonable arsoroeya' fees. and costs of docusentaay evidence, abstracts and title repose. IB. BoMwee$ Right to Rdoditft NoWthstaddins I mder'I acceleration of the stmts oeaucd by this Mortgage due to Hocrovoer's breach, Borrower shall ban the dgM to have my praoeedinp began by Leader to enforce dtis hIMMe dhoot flied at ray time prior to at last once hour before the earmuencenwat of biddh* at a sheritl's We or tatter axle purrs a nt to Ole Mortgage if: (a) Bottower pays Leader ad stmt wbkh would be then due under this MasWp and as Now bad no ac dustim oomred: (b) Borrower cares A brewhes of say odxr covenants or agmrnents of Borrower oont&W in d* Mmtpge: (c) Bearawer pays all reaaoeablo expenses incurred by Lcmde: in educing the covauxote and spteoments of Borrower contained in this MorWge, and in cafteittg LMWI renAbdies as psov(ded in puaeraph 17 dtamd. b0ulln& bat not Hu tted to. taasoad* attorneys' feat;. stud (4) Bamwer piss sacb acdoa as Loeb r my comoaably regdw to aerate ant der: lion of 06 Mattgage, Lender's intme in the Property and Bonvvmes obligation to pay the mate aewred by this Mortpgo shall continue, uffimQadeed. Upon smolt paynrea, and case by Darnwe4 this Mortgage and the obligations secured hereby sba11 remain in, foil fusee and effect as if no acceleration had occtumd. It. AwlpmW of VAski AKw6*aW of Rwiver, Lander to Paaaestdaa, As. additional wwrity bertoodet. Barvwer hereby aasieas to Lender the rants of the PtopcM, provided that Bocrowa shall, prior to aecekratiea under pargeWb 17 bereef or abandonment of the Propary, bows the right to collect artd retain such recta as tiny bt econe dne ad payable. Upon owderatioa under pmagnpb l7 hereof tw a6agtdaaaent of ate Propor(y. Lander. in ixrsao by spot or by ju"Oy appduW tdxiva WM be onNed to now uptak taco posseadioa of and as oup fate Property told to ooUca dot: meets of the hap" those past dtu. All rat's collected by Larder of *a rsotdret astsR be sppW first to payment of ate costs of maa02eat of the property sad oullecdm of renia, includit4 but not limited to, receiver's fee, pr(eadw s on server's bonds and rta wcable o=ocys' fees, and then to tht: auras accred by this Mortgage. I andtr and des receiver shell be liable to account only for Otero m b acuttily received. ZO Rdeme. Upon payment of all straw soared by duds Mortgage, No MccWv and the coerce comayed =ball twWam and booms void. After auch occurrence, Lender shell disdmp rand udsfy this Mortga a wlthoat charge to Borrower. Boa~ shad pay arty reeordauon costs. 11. lab"d last* After, judgmeaaL Borrower agrees that the interest rate payaWo after a jtxtpwm is enacted on the Now or in an action of mortgage fmcclanare shad be the race stated in the Note. = Rldera. > EFMtMC$ IS I; MHEY MAM TO TM RIDER(s) ATTACM HMTO AND MADE A FART HlBi8OF FOR ALL PURPOSES: C] Adjosfable Rate Rider ? Coudeminian Rider Sownd How Rider Balloon Rider ? P1soned Unit Devdopmett Rider Riweeldy Payramt hider 14 Fondly Rider Q Odw(s) it >iailoon tai r p8NN8tCLVA71rln - ae0uld Magge-flea _7rNAlAJIBL,MC UtrlPOSdte IIasi AUMaNr #arm 3215 eocu7m Brae 5 of 7 e007nua.vu eats!/coos BK 1892PG3822 RRQUWr FOR NOTICE OF DBN'AULT AND FORECLOSUIR UNDRR SXAWIM uos?ass MOR MAGn OR DE M OF TRUST Aorrower sod Lender ragma the holler of may mtn Wp, deed of uwt or odw onotm benme with a Ha winch hos ptiarity ova dds Mortgage to give Notice to Lauer, at Lender's oddest set faath an page ow of this Mostpga, of any dd ah nodes ibo superior atcm at mce and of any sale or other fom4osum anion. IN VTrNPSS WIMPOF. Baovwer has excmed this a c? A4,,- G- z q ; Z?v - Borrows - SUM L MILSClf - DIt a tViaoeeses: PSN MVAMA - Seemd Monger -1180 -FNMA#M MC MWORM YNNYig1Y>WT FW= Sp9 DUUMA4 teQb d? .vu 0!/!/9001 Bid 1892PG3823 iios?asa iioa?sss [Space Below M& Use For A,dugwtedFmeot] Co®monwcalth of fft , Co"Ay of p u h1 t6 tflX< Aw• A Oa this the Z7r)V day of L evo)Mdoc , t OV#l beftm me, 04fs b4.".fv4* the ottdrrdped ofbvcr, PMO-HY vpmvd 5 7?'t?tw? tJ &K o If known to ma (or asdsfwwdly Fovea) to be the prom(s) whoae nams(t) 15 anbKdbed to the within inaGrtnneat and acbmwledgod that W a the same for tthe pmposea heroin cmWwbL In w,tness wbct:of, I hereunto act oty hand atsd officlsl seal. NR 7fAAYtLSfEAL CHPJII DAMRM. fWyTARY PUBW wy? WwwASM ? rt?a7 y p+llsL/e- Tide Of omcer My Commwm Expires: 6AT%giN Tlhl (f RF9lYDffi? o p?1TLt ROOD rig LL,il 0.71 the 3 f1CQ lender i& wimac my hand dds 27tb day of D.aswbox, 2004 Agent oftoWa PENN MVAMA - Swmd Maotpp - 140-FNMMM.1MC UN OttlM MTREMO NT PorA JaJ! loft DOMM7 oder l.v" ovin)"n BK 1892PG382q SCHEDULE C LEGAL DESCRIPTION Title No. 17962 ALL THAT CERTAIN piece, parcel or tract of land, situate, ying and being in Ckkinson Township, Cumberland County, Pennsylvania, more particulorty bounded, limited and described as follows, to wit HOUNDED on the West by property now or formerly of Robert Barbour; on the South by propety now or formerly of the Estate of Foster Roakey; on the l=ast by property now or formerly of Howard Starner, and on the North by property now or formerly of F=art King; having a width on the North end South ends of 100 feet, more or lees. and extending in depth on the West side of 550 That, more or less, and on the East side 575 feet, more or less, and being improved with a frame house known and numbered as R.D. No. 2, Box 1428, Gardners, Pennsylvania 17324. BEING THE SAME PREMISES which Grayson P. Showers, widow, by DoW dated November 3, IM and recorded November 9, 1996 in the office of the Recorder of Deeds in and for Cumberland County, PenneyhWIs in Record Book 130, Page 1136, granted and conveyed unto Zena M. Wfison, Grantor herein, her heirs and assigns. AND THE SAID Zena M. Wilson has strw% married and is now known as Zen* M. Keys. AND THE SAID Scott A. Keys, husband of Zena M. Keys, Joins in this Deed waiving al of his right, title, and in? in or to the hereindescribed property. UNDER AND SUBJECT To an Easement Agreement dated August 29,1995 and recorded November B,1996 In Record Book 507, Page 837. 8K 1892PG3825 Loan Servicing,,' -17 12650 Ingenuity Drive Orlando, Florida 32826 O C WE N December 03, 2007 U WWW.OCWEN.COM VIA First Class Mail VIA Certified Mail (return receipt requested) Certified Number: 71069017515118948786 Reference Code: 0710 Steven L. Wilson 1409 Goodyear Road Gardners, PA 17324-0000 Loan Number: Property Address: '1 11/rL00 DACT91.11 34175786 1409 Goodyear Road, Gardners, PA 17324-0000 PLEASE SEE THE ENCLOSED DOCUMENT This communication is a debt collector attempting to collect a debt; any information obtained will be used for that purpose. OCWEN Loan Servicing_ 7 " 12650 Ingenuity Drive . Orlando, Florida 32826 O C W E N December 03, 2007 APPENDIX A ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE WWW.OCWEN.COM This is an official notice that the mort a e on our home is in defaul and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM MAP may be able to hell) to save our home. This Notice explains how the program works To see if HEMAP can beh>t You must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN THIRTY (30) DAYS OF THE DATE OF THIS NOTICE Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving -your County are listed at the end of this Notice. If you have any questions -you may call the Pennsylvania Housing Finance Agency toll free at 1-800- 342-2397 (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any Questions representatives at the Consumer Credit Counseling Agency may be able to help explain it You may also want to contact an attorney in your area The local bar association may be able to help You find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION, OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO A ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. USTED 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): Steven L. Wilson PROPERTY ADDRESS: 1409 Goodyear Road Gardners, PA 17324-0000 LOAN ACCT. NO.: 34175786 ORIGINAL LENDER: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CURRENT LENDER/SERVICER: OCWEN DACT91.11 ms communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. .......... OCWEN Loan Servicing, r' 12650 Ingenuity Drive -. C W Orlando, Florida 32826 O E- N WWW.OCWEN.COM HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -Under the Act you are entitled to a tem]porary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice During that time you must arrange and attend a "face- to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED"HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your 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). DACT91.11 finis communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. , .... ......... ....... . OCWEN Loan Servicing, 12650 Ingenuity Drive 0 O C W E E " N Orlando, Florida 32826 WWW.OCWEN.COM HOW TO CURE YOUR MORTGAGE DEFAULT Brine it up to date) NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property located at: 1409 Goodyear Road, Gardners, PA 17324-0000 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 2 payments in the amount of $ 126.13 from October 01, 2007 through December 03, 2007 DETAIL SUMMARY : Principal and Interest ................................. $ 252.26 Interest Arrearage ..................................... $ 0.00 Escrow .................................................. $ 0.00 Late Charges ........................................... $ 149.06 Insufficient Funds Charges ........................... $ 0.00 Fees / Expenses ........................................ $ 5.21 Suspense Balance (CREDIT) ........................ $ 12.87 Interest Reserve Balance (CREDIT) ................ $ 0,00 TOTAL DUE .......................................... $ 393.66 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 $393.66, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by Money Gram, Cashier's Check Certified Check or Money Order made payable and sent to OCWEN P.O. BOX 6440 CAROL STREAM, IL 60197-6440 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 riehts to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY-period, you will not be required to Day attorney's fees. OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale You may do so by payine the total amount then past due, plus any late or other charees then due reasonable attornev's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writine by the lender and by Performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. DACT91.11 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. OCWEN Loan Servicing, 12650 Ingenuity Drive ?o O C W E N Orlando, Florida 32826 WWW.OCWEN.COM EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 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 rind out at any time exactly what the required payment or action will be by contacting the servicer. HOW TO CONTACT THE SERVICER: Name of Servicer: OCWEN Address: P.O. BOX 24737 WEST PALM BEACH, FL 334164737 Phone Number: 800-310-9229 Fax Number: 407-737-6300 Contact: Performing Collections Dept. EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may or X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO 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 (3) 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. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY DACT91.11 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. r U.S. Bank N.A., in its capacity as Trustee for the registered holders of MASTR Asset Backed Securities Trust 2005-WMC1, Mortgage Pass-Through Certificates v. Steven L. Wilson VERIFICATION The undersigned is Foreclosure Facilitator of Ocwen Loan Servicing, LLC on behalf of U.S. Bank N.A., in its capacity as Trustee for the registered holders of MASTR Asset Backed Securities Trust 2005-WMC1, Mortgage Pass-Through Certificates and as such is familiar with the records of said corporation, and being authorized to make this verification on behalf of Plaintiff an officer of the corporation and being authorized to make this verification on behalf of Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint are taken from records maintained by persons supervised by the undersigned who maintain the business records of the Mortgage held by Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information-and belief of the undersigned. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Ocwen Loan Servicing, LLC on behalf of U.S. Bank N.A., in its capacity as Trustee for the registered holders of MASTR Asset Backed Securities Trust 2005-WMCI, Mme Pass-Through Cert?flcates Date: AUG 2 9 2006 Nmfie: Anna V. Ji Title: US Foreclo: Company: US. Ba Loan: 34175786 08-033261 00 ,G CD b Z` v SHERIFF'S RETURN - REGULAR CASE NO: 2008-05395 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND US BANK N A VS WILSON STEVEN L TIMOTHY R BLACK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon WILSON STEVEN L the DEFENDANT , at 0019:35 HOURS, on the 15th day of September, 2008 at 1409 GOODYEAR ROAD GARDNERS, PA 17324 by handing to KATHY WILSON WIFE OF DEFENDANT a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 11.00 Affidavit .00 Surcharge 10.00 I a4o -710 8 00 t/39.00 Sworn and Subscibed to before me this day of , So Answers: 00 R. Thomas Kline , 09/16/2008 SHAPIRO & DENARDO By: r79 00 /Deputy Sheriff A. D. CASE NO: 2008-05395 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND US BANK N A VS WILSON STEVEN L R. Thomas Kline Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon OCCUPANT the DEFENDANT , at 0019:35 HOURS, on the 16th day of September, 2008 at 1409 GOODYEAR ROAD GARDNERS, PA 17324 by handing to KATHY WILSON OCCUPANT/WIFE OF STEVEN WILSON a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 1v1b1?04 ? 16.00 Sworn and Subscibed to before me this day of So Answers: R. homas Kline 09/16/2008 SHAPIRO & DENARDO By: Deputy Sheriff A. D. SHAPIRO & DeNARDO, LLC ? BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 08-033261 U.S. Bank N.A.,in its capacity as Trustee for the registered holders of MASTR Asset Backed Securities Trust 2005-WMCI, Mortgage Pass-Through Certificates PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:2008-5395 Civil Term vs. Steven L. Wilson DEFENDANT(S) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES ' Enter Judgment IN REM in the amount of $18,574.46 in favor of the Plaintiff and against the defendant(s), jointly and severally, for failure to file an answer to Plaintiffs Complaint in Mortgage Foreclosure within 20 days from service thereof and assess Plaintiffs damages as follows and calculated as stated in the Complaint: Principal of mortgage debt due and unpaid $14,732.22 Interest at 9.5% from September 1, 2007 to October 20, 2008 (416 days @ $3.83 per diem) $1,593.28 Late charges (for certain months prior to default and every month after at a rate of $6.31 per month) $237.33 Property Inspections $52.50 Suspense/Unapplied Balance ($12.87) Appraisal Fees $222.00 Title Search Re ort Fees $250.00 Y Attorneys Fees $1,500.00 TOTAL AMOUNT DUE $18,574.46 BY: Michael J. Clark, Esquire Attorney for Plaintiff AND NOW, judgment is entered in favor of the Plaintiff and against the Defendant(s) and damages are assessed as above in the sum of $18,574.46. 08-033261 &- 75 6 ? W o. P thy. i SHAPIRO & DENARDO, LLC BY: DANIELLE BOYLE-EBERSOLE, ESQ. MICHAEL CLARK, ESQ. CHRISTOPHER A. DENARDO, ESQ. AND ILANA ZION, ESQ. ATTORNEY I.D. NOS. 81747, 202929, 78447 & 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 08-033261 U.S. Bank N.A., in its capacity as Trustee for the registered holders of MASTR Asset Backed Securities Trust 2005-WMC1, Mortgage Pass-Through Certificates PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: Q8 - 53 q( 5- 6 Vi I fierr-- VS. Steven L. Wilson 1409 Goodyear Road Gardners, PA 17324 DEFENDANT(S) STATE OF: Florida COUNTY OF: Orange AFFIDAVIT OF NON-MILITARY SERVICE THE UNDERSIGNED being duly sworn, states that he/she is over the age of eighteen years and competent to make this affidavit and the following averments are based upon investigations made and records maintained either as Plaintiff or servicing agent of the Plaintiff and that the above-captioned Defendants' last known address is as set forth in the caption and they are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended. Ocwen Loan S is g, LLC on behalf o S. Bank N.A., in its capacity as Trustee fo a regi ered holders of _ Asset Backed Securities Trust 2005- WMC1 ortga Pass-Through ertificates By: NAME: %nna V. Jimen z TITLE: US Foreclosur cilitator Sworn to and subscribed befo me this /0 - day of 2008. Notary Q 1_? Public 08-033261 w9w Ow Robes fCbilt o My CmnWm DD56M ?? 08128010 SHAPIRO & DeNARDO, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I.D. NO: PA Bar # 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 08-033261 U.S. Bank N.A.,in its capacity as Trustee for the registered holders of MASTR Asset Backed Securities Trust 2005-WMC1, Mortgage Pass-Through Certificates PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2008-5395 VS. Steven L. Wilson DEFENDANTS CERTIFICATION OF MAILING NOTICE UNDER RULE 237.1 The undersigned hereby certifies that a Written Notice of Intention to File a Praecipe for the Entry of Default Judgment was mailed to the defendant (s) and to his, her, their attorney of record, if any, after the default occurred and at least (10) days prior to the date of the filing of the Praecipe. Said Notice was sent on the date set forth in the copy of said Notice attached hereto, October 7 2008 to the following Defendants: Steven L. Wilson 1409 Goodyear Road Gardners, PA 17324 Sheena ayer, gal Assistant to Ilana Zion, Esquire for Shapiro & DeNardo, LLC SHAPIRO & DeNARDO, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I.D. NO: PA Bar # 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 08-033261 U.S. Bank N.A.,in its capacity as Trustee for the registered holders of MASTR Asset Backed Securities Trust 2005-WMC1, Mortgage Pass-Through Certificates PLAINTIFF VS. Steven L. Wilson DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2008-5395 bvillev n NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Steven L. Wilson DATE OF NOTICE: October 7 2008 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 notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTIFICACION IMPORTANTE Usted se encuentra en estado de rebeldia por no haber tomado la accion requirida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de la fecha de esta notificacion, el tribuna podra, sin necesidad de compararecer usted in corte o escuchar preuba alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos importantes. Debe llevar esta notificacion a un abogado immediatamente. Si usted no tiene abogado o si no tiene dinero suficiente para tal servicio, vaya en persona o flame por telefono a la oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Steven L. Wilson 1409 Goodyear Road Gardners, PA 17324 .. aua-"Am/? Ilana Zion, Esquire Shapiro & DeNardo, C Attorney for Plaintiff Cd ? F- 4a 01 1 -on A Cl) AM Y c tf.A OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEASCumberland County Clerk Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Curtis R. Long Prothonotary TO: Steven L. Wilson 1409 Goodyear Road Gardners, PA 17324 U.S. Bank N.A.,in its capacity as Trustee for the registered holders of MASTR Asset Backed Securities Trust 2005-WMC1, ; Mortgage Pass-Through Certificates PLAINTIFF VS. ; Steven L. Wilson DEFENDANT(S) COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:2008-5395 Civil Term NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as' dicated below. urtis R. Lo Prothonotary [XX] Judgment by Default [ ] Judgment for Possession [ ] Judgment on Award of Arbitration [ ] Judgment on Verdict [ ] Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY MICHAEL J. CLARK, ESQUIRE AT (610) 278-6800. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: U.S. Bank N.A.,in its capacity as Trustee for the registered holders of MASTR Asset Backed Securities Trust 2005-WMC1, Mortgage Pass-Through Certificates PLAINTIFF vs. () Confessed Judgment () Other File No. `2008-5395 Civil Term_ Amount Due $18,574.46 Interest October 21, 2008 to March 4, 2009 is $652.59 Atty's Comm Costs Steven L. Wilson DEFENDANT(S) TO THE PROTHONOTARY OF THE SAID COURT: The undersigned herety certifies that the below does not arise out of a retail installment safe, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant(s) See attached Legal Description PRAECGIPE FOR ATTACHEMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described +; i the attached exhibit. 49 _ Signature: ?*-- Date: 1A Print Name: Michael J. Clark, Esquire Address: 3600 Horizon Drive, Ste. 150 King of Prussia, PA 19406 Attorney for: Plaintiff Supreme Court ID # PA Bar # 202929 3 .G 9u ?,o0 6' .G L O 00 ?i 6 8 - a oo a a 7b t' SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I. D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 08-033261. U.S. Bank N.A.,in its capacity as Trustee for the registered holders of MASTR Asset Backed Securities Trust 2005-WMC1, Mortgage Pass-Through Certificates PLAINTIFF VS. Steven L. Wilson DEFENDANT(S) COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:2008-5395 Civil Term CERTIFICATE OF SERVICE I, Michael J. Clark, Esquire, Attorney for the Plaintiff, hereby certify that I have served by first.class mail, postage prepaid, true and correct copies of the attached papers upon the following person(s) or their attorney of record: Steven L. Wilson 1409 Goodyear Road Gardners, PA 17324 Date mailed: SHAPIRO & DENARDO, LLC BY: Michael J. Clark squire Attorney for Plaintiff 08-033261 d r? ? yy 3 [ n -p SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I. D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 08-033261 U.S. Bank N.A.,in its capacity as Trustee for the registered holders of MASTR Asset Backed Securities Trust 2005-WMC1, Mortgage Pass-Through Certificates PLAINTIFF vs. Steven L. Wilson ; DEFENDANT(S) COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:2008-5395 Civil Term CERTIFICATION OF ADDRESS I hereby certify that the correct address of the judgment creditor (Plaintiff) is: U.S. Bank N.A.,in its capacity as Trustee for the registered holders of MASTR Asset Backed Securities Trust 2005-WMC1, Mortgage Pass-Through Certificates c/o Ocwen Federal Bank FSB 1675 Palm Beach Blvd. West Palm Beach, FL 33401 and that the last known address(es) of the judgment debtor (Defendant(s)) is: Steven L. Wilson 1409 Goodyear Road Gardners, PA 17324 BY: SHAPIRO & DENARDO, LLC Michael J. Clark, Attorney for Plaii 08-033261 rya r ? • N ?,.? ? ? ? -t?: y '?' ?" .. 4k SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I. D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 08-033261 U.S. Bank N.A.,in its capacity as Trustee for the registered holders of MASTR Asset Backed Securities Trust 2005-WMC1, Mortgage Pass-Through Certificates PLAINTIFF VS. Steven L. Wilson DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2008-5395 Civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 U.S. Bank N.A.,in its capacity as Trustee for the registered holders of MASTR Asset Backed Securities Trust 2005-WMC1, Mortgage Pass-Through Certificates, Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 1409 Goodyear Road, Gardners, PA 17324. 1. Name and address of Owner(s) or Reputed Owner(s) Steven L. Wilson 1409 Goodyear Road Gardners, PA 17324 2. Name and address of Defendant(s) in the judgment: Steven L. Wilson 1409 Goodyear Road Gardners, PA 17324 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: U.S. Bank N.A.,in its capacity as Trustee for the registered holders of MASTR Asset Backed Securities Trust 2005-WMC1, Mortgage Pass-Through Certificates c/o Ocwen Federal Bank FSB 1675 Palm Beach Blvd. West Palm Beach, FL 33401 C/W of PA Dept of Revenue #280946 Bureau of Compliance Harrisburg, PA 17128-0946 Brenda Quayle c/o Erie Insurance Group PO Box 2013 Mechanicsburg, PA 17055 Cumberland County Adult Probation & Parole New Courthouse 3rd EL Rm302 I Courthouse Square Carlisle, PA 17013 Cumberland County Clerk of Courts Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: U.S. Bank N.A.,in its capacity as Trustee for the registered holders of MASTR Asset Backed Securities Trust 2005-WMC1, Mortgage Pass-Through Certificates, Plaintiff0cwen Federal Bank c/o Ocwen Federal Bank FSB 1675 Palm Beach Blvd. West Palm Beach, FL 33401 MERS Inc. as nominee for WMC Mortgage Corp. PO Box 2026 Flint, MI 48501 MERS Inc. as nominee for WMC Mortgage Corp. PO Box 54089 Los Angeles, CA 90054-0089 5. Name and address of every other person who has any record lien on the property: 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations 13 North Hanover Street Carlisle, PA 17013 3- . 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: TENANT OR OCCUPANT 1409 Goodyear Road Gardners, PA 17324 Occupant Kathy Wilson 1409 Goodyear Road Gardners, PA 17324 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. SHAPIRO & DENARDO, LLC BY: jlj acpk Michael J. Clark squire 08-033261 ` S Z5 A SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 08-033261 U.S. Bank N.A.,in its capacity as Trustee for the registered holders of MASTR Asset Backed Securities Trust 2005-WMC1, Mortgage Pass-Through Certificates PLAINTIFF VS. Steven L. Wilson DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2008-5395 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Steven L. Wilson 1409 Goodyear Road Gardners, PA 17324 Your house (real estate) at: 1409 Goodyear Road, Gardners, PA 17324 08-16-0210-023 is scheduled to be sold at Sheriffs Sale on March 4, 2009 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00AM, to enforce the court judgment of $18,574.46 obtained by U.S. Bank N.A.,in its capacity as Trustee for the registered holders of MASTR Asset Backed Securities Trust 2005- WMC1, Mortgage Pass-Through Certificates 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: 1. The sale will be cancelled if you pay back to U.S. Bank N.A.,in its capacity as Trustee for the registered holders of MASTR Asset Backed Securities Trust 2005-WMC1, Mortgage Pass-Through Certificates the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610) 278-6800. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two of how to obtain an attorney.) A, YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 4. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610) 278-6800. 5. 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. 6. 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 717-240-6390. 7. 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. 8. 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. 9. 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 no later than thirty (30) days from the date of the sale. This schedule will state who will be receiving the 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 date of filing of said schedule. 10. 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. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 08-033261 ALL THAT CERTAIN piece, parcel or tract of land, situate, lying and being in Dickonson Township, Cumberland County, Pennsylvania, more particularly bounded, limited and described as follows, to wit: BOUNDED on the West by property now or formerly of Robert Barbour; on the South by property now or formerly of the Estate of Foster Rockey; on the East by property now or formerly of Howard Starner; and on the North by property now or formerly of Earl King; having a width on the North and South ends of 100 feet, more or less, and extending in depth on the West side of 550 feet, more or less, and on the East side 575 feet, more or less, and being improved with a frame house known and numbered as R.D. No. 2, Box 142B, Gardners, Pennsylvania 17324. BEING THE SAME PREMISES which Grayson P. Showers, widow, by Deed dated November 3, 1995 and recorded November 9, 1995 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Record Book 130, Page 1136, granted and conveyed unto Zena M. Wilson, Grantor herein, her heirs and assigns. AND THE SAID Zena M. Wilson has since married and is now known as Zena M. Keys. AND THE SAID Scott A. Keys, husband of Zena M. Keys, joins in this Deed waiving all of his right, title, and interest in or to the hereindescribed property. UNDER AND SUBJECT TO an Easement Agreement dated August 28, 1995 and recorded November 6, 1995 in Record Book 507, Page 837. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-5395 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due U.S. BANK N.A., in its capacity as Trustee for the registered holders of MASTR ASSET BACKED SECURITIES TRUST 2005-WMCI, MORTGAGE PASS-THROUGH CERTIFICATES, Plaintiff (s) From STEVEN L. WILSON (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 gamishee(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 $18,574.46 L.L. $.50 Interest from 10/21/08 to 3/04/09 is -- $652.59 Atty's Comm % Atty Paid $174.00 Plaintiff Paid Date: 10/20/08 (Seal) REQUESTING PARTY: Due Prothy $2.00 Other Costs rothonotary By: Deputy Name: MICHAEL J. CLARK, ESQUIRE Address: SHAPIRO & DeNARDO, LLC 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 Supreme Court ID No. 202929 .,40 " . U.S. Bank N.A., in its capacity as Trustee In The Court of Common Pleas of For the Registered Holders of MASTR Cumberland County, Pennsylvania Asset Backed Securities Trust 2005-WMC1 Writ No. 2008-5395 Civil Term Mortgage Pass-Through Certificates VS Steven L. Wilson Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on November 14, 2008 at 1930 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: Steven L. Wilson, by making known unto Steven L. Wilson personally, at 1409 Goodyear Road, Gardners, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on January 13, 2009 at 1901 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 Steven L. Wilson located at 1409 Goodyear Road, Gardners, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Steven L. Wilson, by regular mail to his last known address of 1409 Goodyear Road, Gardners, PA 17324. This letter was mailed under the date of January 9, 2009 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law that this writ is returned STAYED, per attorney's instructions. Sheriff's Costs: Docketing 30.00 Poundage 18.14 Posting Bills 15.00 Advertising 15.00 Auctioneer 10.00 Law Library .50 Prothonotary 2.00 Mileage 19.80 Levy 15.00 Surcharge 20.00 Postpone sale 20.00 Law Journal 355.00 Patriot News Share of Bills r'Thomas Kline, Sheriff BY O[cj Real state Coordinator 389.21 15.52 $ 925.17 ?p??8 3 DL .6 ?5? ?r SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 08-033261 U.S. Bank N.A.,in its capacity as Trustee for the registered holders of MASTR Asset Backed Securities Trust 2005-WMCI, Mortgage Pass-Through Certificates PLAINTIFF VS. Steven L. Wilson DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2008-5395 Civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 U.S. Bank N.A.,in its capacity as Trustee for the registered holders of MASTR Asset Backed Securities Trust 2005-WMC 1, Mortgage Pass-Through Certificates, Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 1409 Goodyear Road, Gardners, PA 17324. 1. Name and address of Owner(s) or Reputed Owner(s) Steven L. Wilson 1409 Goodyear Road Gardners, PA 17324 2. Name and address of Defendant(s) in the judgment: Steven L. Wilson 1409 Goodyear Road Gardners, PA 17324 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: U.S. Bank N.A.,in its capacity as Trustee for the registered holders of MASTR Asset Backed Securities Trust 2005-WMC1, Mortgage Pass-Through Certificates c/o Ocwen Federal Bank FSB 1675 Palm Beach Blvd. West Palm Beach, FL 33401 C/W of PA Dept of Revenue #280946 Bureau of Compliance Harrisburg, PA 17128-0946 Brenda Quayle c/o Erie Insurance Group PO Box 2013 Mechanicsburg, PA 17055 Cumberland County Adult Probation & Parole New Courthouse 3rd EL Rm302 1 Courthouse Square Carlisle, PA 17013 Cumberland County Clerk of Courts Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: U.S. Bank N.A.,in its capacity as Trustee for the registered holders of MASTR Asset Backed Securities Trust 2005-WMC1, Mortgage Pass-Through Certificates, Plaintiff0cwen Federal Bank c/o Ocwen Federal Bank FSB 1675 Palm Beach Blvd. West Palm Beach, FL 33401 MERS Inc. as nominee for WMC Mortgage Corp. PO Box 2026 Flint, MI 48501 MERS Inc. as nominee for WMC Mortgage Corp. PO Box 54089 Los Angeles, CA 90054-0089 5. Name and address of every other person who has any record lien on the property: 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations 13 North Hanover Street Carlisle, PA 17013 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: TENANT OR OCCUPANT 1409 Goodyear Road Gardners, PA 17324 Occupant Kathy Wilson 1409 Goodyear Road Gardners, PA 17324 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. SHAPIRO & DENARDO, LLC BY: A?L a. (& Michael J. Clark squire 08-033261 SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I. D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 08-033261 U.S. Bank N.A.,in its capacity as Trustee for the registered holders of MASTR Asset ; Backed Securities Trust 2005-WMC1, Mortgage Pass-Through Certificates PLAINTIFF VS. Steven L. Wilson DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2008-5395 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Steven L. Wilson 1409 Goodyear Road Gardners, PA 17324 Your house (real estate) at: 1409 Goodyear Road, Gardners, PA 17324 08-16-0210-023 is scheduled to be sold at Sheriffs Sale on March 4, 2009 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00AM, to enforce the court judgment of $18,574.46 obtained by U.S. Bank N.A.,in its capacity as Trustee for the registered holders of MASTR Asset Backed Securities Trust 2005- WMC1, Mortgage Pass-Through Certificates 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: 1. The sale will be cancelled if you pay back to U.S. Bank N.A.,in its capacity as Trustee for the registered holders of MASTR Asset Backed Securities Trust 2005-WMC1, Mortgage Pass-Through Certificates the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610) 278-6800. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You maybe able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two of 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 TAKE PLACE. 4. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610) 278-6800. 5. 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. 6. 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 717-240-6390. 7. 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. 8. 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. 9. 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 no later than thirty (30) days from the date of the sale. This schedule will state who will be receiving the 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 date of filing of said schedule. 10. 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. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 08-033261 ALL THAT CERTAIN piece, parcel or tract of land, situate, lying and being in Dickonson Township, Cumberland County, Pennsylvania, more particularly bounded, limited and described as follows, to wit: BOUNDED on the West by property now or formerly of Robert Barbour; on the South by property now or formerly of the Estate of Foster Rockey; on the East by property now or formerly of Howard Starner; and on the North by property now or formerly of Earl King; having a width on the North and South ends of 100 feet, more or less, and extending in depth on the West side of 550 feet, more or less, and on the East side 575 feet, more or less, and being improved with a frame house known and numbered as R.D. No. 2, Box 142B, Gardners, Pennsylvania 17324. BEING THE SAME PREMISES which Grayson P. Showers, widow, by Deed dated November 3, 1995 and recorded November 9, 1995 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Record Book 130, Page 1136, granted and conveyed unto Zena M. Wilson, Grantor herein, her heirs and assigns. AND THE SAID Zena M. Wilson has since married and is now known as Zena M. Keys. AND THE SAID Scott A. Keys, husband of Zena M. Keys, joins in this Deed waiving all of his right, title, and interest in or to the hereindescribed property. UNDER AND SUBJECT TO an Easement Agreement dated August 28, 1995 and recorded November 6, 1995 in Record Book 507, Page 837. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEATH OF PENNSYLVANIA) NO 08-5395 Civil COUNTY. OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due U.S. BANK N.A., in its capacity as Trustee for the registered holders of MASTR ASSET BACKED SECURITIES TRUST 2005-WMC1, MORTGAGE PASS-THROUGH CERTIFICATES, Plaintiff (s) From STEVEN L. WILSON ' (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 $18,574.46 L.L. $.50 Interest from 10/21/08 to 3/04/09 is - $652.59 Atty's Comm % Due Prothy $2.00 Atty Paid $174.00 Other Costs Plaintiff Paid Date: 10/20/08 4rothonotary (Seal) By; Deputy REQUESTING PARTY: Name: MICHAEL J. CLARK, ESQUIRE Address: SHAPIRO & DeNARDO, LLC 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 Supreme Court ID No. 202929 Real Estate Sale #24 On November 6, 2008 the Sheriff levied upon the defendant's interest in the real property situated in Dickinson Township, Cumberland County, PA Known and numbered as 1409 Goodyear Road, Gardners more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 6, 2008 By: ` Real jEt"e Sergeant € Z ?01 V I Z 1 30 6001 dd'AINA0 VF.1t3.r J-4183HS 3H1 A 33WO 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: January 30, February 6, and February 13, 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. S before me this 13 day of February 13, 2009 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 YAM seem a M 74 Writ No. 2006-5395 Civil U.S. Bank N.A., in its capacity as Trustee for the Registered Holders of MASTR Asset Backed Securities Trust 2005-WMC1 Mortgage Pass- Through Certificates VS. Steven L. Wilson Atty.: Michael Clark ALL THAT CERTAIN piece, parcel or tract of land, situate, lying and being in Dickinson Township, Cum- berland County, Pennsylvania, more particularly bounded, limited and described as follows, to wit: BOUNDED on the West by prop- erty now or formerly of Robert Bar- bour; on the South by property now or formerly of the Estate of Foster Rockey; on the East by property now or formerly of Howard Starner; and on the North by property now or for- merly of Earl King; having a width on the North and South ends of 100 feet, more or less, and extending in depth on the West side of 550 feet, more or less, and on the East side 575 feet, more or less, and being improved with a frame house known and nuudmtvd ae R.D. No. 2, Boat 142B, ClwftoM Pa n glvania 17324. BRING THE SAME PREMISES wW P. Showers, widow, by Head 4sted Novesaber 3, 1995 and remdec# November 9, 1995 in the Office of the Recorder of Deeds in and for Cumberland County, Penn- sylvania in Record Book 130, Page 1136, granted and conveyed unto Zena M. Wilson, Grantor herein, her heirs and assigns. AND THE SAID Zena M. Wilson has since married and is now known as Zena M. Keys. AND THE SAID Scott A. Keys, husband of Zena M. Keys, joins in this Deed waiving all of his right, title, and interest in or to the here- indescribed property. UNDER AND SUBJECT TO an Easement Agreement dated August 28, 1995 and recorded November 6, 1995 in Record Book 507, Page 837. Ths: PF3triot-News Co. 8';2 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 i4e Patr1*otwXews Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY REAL ESTATE SALE NO. 24 Writ No. 2008-5395 Civil Term U.S. Bank N.A., in its capacity as Trustee for the Registered Holders of MASTR Asset Backed Securities Trust 2005- WMC1 Mortgage Pass-Through Certificates VS Steven L. Wilson Attorney Michael Clark LEGAL DESCRIPTION ALL THAT CERTAIN piece, parcel or tract of land situate, lying and being in Dickinson Township, Cumberland County, Pennsylvania, more particularly bounded, limited and described as follows, to wit: BOUNDED on the West by property now or formerly of Robert Barbour; on the South by property now or formerly of the Estate of Foster Rockey; on the East by property now or formerly of Howard Stainer; and on the North by property now or formerly of Earl King; having a width on the North and South ends of 100 feet, more or less, and extending in depth on the West side of 550 feet, more or less, and on the East side 575 feet, more or less, and being improved with a frame house known and numbered as RD. No. 2, Box 142B, Gardners, Pennsylvania 17324. BEING THE SAME PREMISES which Grayson P. Showers, widow, by Deed dated November 3, 1995 and recorded November 9, 1995 in the Once of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Record Book 130, Page 1136, granted and conveyed unto Zena M. Wilson, Grantor herein, her heirs and assigns. AND THE SAID Zena M. Wilson has since married and is now known as Zena M. Keys. AND THE SAID Scott A. Keys, husband of Zena M. Keys, joins in this Deed waiving all of his right, title, and interest in or to the heremilescribed property. UNDER AND SUBJECT TO an Easement Agreement dated August 28, 1995 and recorded November 6, 1995 in Record Book 507, Page 837. This ad ran on the date(s) shown below: 01 /21 /09 01/28/09 02/04/09 Sworn to and(subsc ' ed before me this 25 day of'Fe0ruary, 2009 A.D. COiYitYCONWI:?' "TH OF PENNSYLVANI,', i Notary Public s,iota' a; ; ,Ial Sherrie L. tti erzer, Notary Public C1y Of hlarrisl: w% Dauphin County My Co wnission Expires Nov. 26, 2011 Member. Pennsyhla;nia., sscciatlon of Notaries ?r 'ru N SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 08-033261 U.S. Bank N.A.,in its capacity as Trustee for the registered holders of MASTR Asset Backed Securities Trust 2005-WMC1, Mortgage Pass-Through Certificates PLAINTIFF VS. ' Steven L. Wilson DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2008-5395 Civil Term PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY: Kindly mark the Judgment entered on October 20, 2008 in the above entitled action vacated without prejudice to Plaintiff. SHAPIRO & DENARDO, LLC BY: ? ? k"' Michael J. C ark, Esquire **,- Y m " 11 CERTIFICATE OF SERVICE I, MICHAEL J. CLARK, ESQUIRE, hereby certify that on I served a true , V)Z/0/0 and correct copy of the within Praecipe to Vacate Mortgage Foreclosure Judgment upon the following parties via first class mail, postage prepaid: Steven L. Wilson 1409 Goodyear Road Gardners, PA 17324 SHAPIRO & DENARDO, LLC BY: V-\, ? V MICHAEL J. ESQUIRE Attorney for the Plaintiff n a?,t SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 08-033261 U.S. Bank N.A.,in its capacity as Trustee for the• registered holders of MASTR Asset Backed Securities Trust 2005-WMC1, Mortgage Pass- Through Certificates PLAINTIFF VS. ; Steven L. Wilson ; DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2008-5395 Civil Term PRAECIPE TO SETTLE DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above-captioned matter SETTLED, DISCONTINUED AND ENDED, without prejudice. SHAPIRO & DENARDO, LLC BY: V - Michael J. Clark, Esquire Attorney for Plaintiff DATED: 7116 /0 CERTIFICATE OF SERVICE I, Michael J. Clark, Esquire, hereby certify that on ILIJ-cl I served a true and correct copy of the within Praecipe to Settle, Discontinue and End upon the following parties via first class mail, postage prepaid: Steven L. Wilson 1409 Goodyear Road Gardners, PA 17324 SHAPIRO & DENARDO, LLC BY: A V---/ Michael J. Cl , Esquire Attorney for Plaintiff .-.` w c'=' ._ tic, +'; -?= i _y -°E7 f .4 7 `t`i 1„ ? ""?. r fw t r . .+?".'y ??, y