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Home My WebLink About08-7364MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel 649 South Avenue, Unit 7 #23890-DD CFC Attorney for Plaintiff PO BOX 307 SECANE, PA 19018 (610) 328-2887 Attorney ID # 52634 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES SERIES 2007-BC2 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005 : COURT OF COMMON PLEAS : CUMBERLAND COUNTY Case No : b$ lam Plaintiff VS. DEBORAH FORD 116 Lee Ann Court Enola, PA 17025 Defendant CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE ADV15U You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELEGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta a sentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea a visado que si usted no se defiende, la corte toma ra medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisions de esta demanda. Usted puede perder dinero o sus propiedades o otros de rechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO VAYA EN PERSONA O TELEFONA A LA OFICINA ESCRITA ABAJO. ESTA OFICINA LE PUEDE PROVEER INFORMACION SOBRE COMO CONTRATAR A UN ABOGADO. SI USTED NO TIENE EL DINERO SUFICIENTE PARA CONTRATAR A UN ABOGADO, LE PODEMOS DAR INFORMACION SOBRE AGENCIES QUE PROVEEN SERVICIO LEGAL A PERSONAS ELEGIBLE PARA SERVICIOS A COSTO REDUCIDO O GRATUITO. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 -- 800-990-9108 THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15. U.S.C. §1692, et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANYT PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY(30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REUQEST WILL BE MADE-TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECFEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE ALIEN ON REAL ESTATE. MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel 649 South Avenue, Unit 7 PO BOX 307 SECANE, PA 19018 (610) 328-2887 Attorney ID # 52634 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION, : COURT OF COMMON PLEAS AS TRUSTEE FOR THE SPECIALTY : CUMBERLAND COUNTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES SERIES 2007-BC2 Case No: 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005 Plaintiff VS. DEBORAH FORD 116 Lee Ann Court Enola, PA 17025 Defendant CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE 1. Plaintiff is U.S. Bank National Association, as Trustee for the Specialty Underwriting and Residential Finance Trust Mortgage Loan Asset-Backed Certificates Series 2007-BC2, a bank organized and existing under state law, with offices for the conduct of business at 14523 SW Millikan Way, Suite 200, Beaverton, OR 97005. 2. Defendant, Deborah Ford is the mortgagor and real owner of premises 116 Lee Ann Court, Enola, PA 17025, hereinafter described, whose last known address is listed in the caption. 3. Plaintiff brings this action in mortgage foreclosure against defendant, mortgagor and real owner, to foreclose a certain indenture of mortgage made, executed and delivered by the above named defendant, mortgagor and real owner to Mortgage Electronic Registration Systems, Inc. as Nominee for Wilmington Finance, Inc. on December 22, 2006, which mortgage was recorded on December 29, 2006 in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1977, and Page 3931, secured on premises 116 Lee Ann Court, Enola, PA 17025 a true and correct description of which is attached hereto as Exhibit I. 4. The mortgage has since been assigned to the Plaintiff herein. 5. Plaintiff alleges each and every term, condition and covenant in the aforesaid mortgage, and hereby incorporates them herein by reference thereto. 6. The aforesaid mortgage is in default in that monthly installments of principal and interest have not been made conformity with the terms of the mortgage, from April, 2008 and each month thereafter, up to and including the present time. 7. Under the terms of the aforesaid mortgage, upon default of payments set forth in the mortgage documents, the entire principal balance and all interest due thereon are collectible forthwith. 8. The following is an itemized statement of the amount due plaintiff under the terms of the aforesaid mortgage: Principal Balance $ 171,585.88 Interest from 3/1/2008to 12/12/2008 At $8.25 per diem $ 11,129.86 Accrued late charges $ 455.42 Corporate Advances $ 298.00 Attorney's fee (5% of unpaid Principal Balance) $ 8,579.29 Title Information Certificate $ 515.00 Suspense $ 538.06) TOTAL $192,025.39 9. The attorney's 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 Sheriff's sale. If the mortgage is reinstated prior to the Sheriff's sale, reasonable attorney's fees will be charged based on work actually performed. 10. Plaintiff sent to defendant, mortgagor and real owner a combined Notice and Warning of Intention to Foreclose and Notices of Homeowners' Emergency Mortgage Assistance Act of 1983 advising of rights available under the statutes. To date payments have not been received and Act 91 assistance has not been granted although the applicable time periods provided by statute have expired (Exhibit II). WHEREFORE, plaintiff demands judgment for foreclosure and sale of the mortgaged premises in the amount of $192,025.39, plus per diem interest at $38.78 from December 13, 2008 to the date of judgment plus costs thereon. Martha E. Von Rosenstiel Attorney for Plaintiff VERIFICATION MARTHA E. VON ROSENSTIEL, ESQUIRE, of full age, verifies that she is the attorney for the plaintiff in the foregoing action; that she is authorized to make this verification on behalf of plaintiff; and that the statements made in the foregoing Complaint in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. This verification is being executed by the attorney for plaintiff in accordance with Pa R.C.P. 1024( c ) as a signed verification could not be obtained by plaintiff within the time allowed for filing of the pleading. I understand that false statements herein are made subject to penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. Martha E. Von Rosenstiel LEGAL DESCRIPTION ALL that certain tract of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit; BEGINNING at the point of intersection between the southerly dedicated right-of-way line of Lee Am Court (A 50 foot Right-of-way) and the line ofadjoiner between Lots 0-2 and 0-3 on the hereinafter mentioned plan of lots; thence South 41 degrees 27 minutes 51 seconds East by said line of adjoiner and through a_party wall of townhouses erected on Lots 0-2 and 0-3 a distance of 110.010 feet to a point; thence South 48 degrees 32 minutes 09 seconds West a distance of22.00 feet to a point; thence North 41 degrees 27 minutes 51 seconds West by the line ofadjoiner between lots 0-3 and 0-4 and through a party wall of townhouses erected on lots 0-3 and 0-4 on the hereinafter mentioned plan of lots a distance of 110.00 feet to a point on the southerly dedicated right-of waiy line of Lee Ann. Court; thence North 48 degrees 32 minutes 09 seconds East by said Southerly dedicated Right-of-way line of Lee Ann Court, the point and place of BEGINNING. SUBJECT to a 10 feet access easement, restrictions and other matters as set forth on said plan of lots. SUBJECT to the easements, restrictions and burdens set forth in the declaration for the final subdivision plan for Sherwood court phase' on, dated April 19,1993, and recorded in the Cumberland County Recorder of Deeds Office in Plan Book 68, Page 11 as revised by the above said plan, said declaration being dated March 23, 1995 and recorded May 15, 1995 in the Cumberland County Recordees Office in Miscellaneous Book 496, Page 79, which are assumed and agreed ti by the Grantee(s) herein. BEING the same premises which Ronald R. Sgrigaoli, by Deed dated 08/03/2006 and recorded 08109/2006 in the Office of the Recorder ofDeeds in and for Cumberland County, in Deed Book 276 Page 494, granted and conveyed unto Michael J. Ford and Deborah Ford, his wife, in fee. BEING Parcel No. 09-15-1288-240 y EXHIBIT ?-Wilshire=° October 01, 2008 FORD,DEBORAH 116 LEE ANN CT ENOLA, PA 17025 Wilshire Credit Corporation Payments P.O. Box 7195, Pasadena, CA 91109-7195 Correspondence P.O. Box 8517, Portland, OR 97207-8517 L178F ACT 91/6 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Phone 888.917.1052 Fax 503.952.7476 Web Site www.wcc.ml.com This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM HEMAP may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with you when you meet with the Counseling Agency. The name address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll-free at 1.800.342.2397. (Persons with impaired hearing can call 717.780.1869.) This notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA (Continued) YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE http://www.ago.state.co.us/cadc/cadcmain.cfm. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan Way, Beaverton, OR. Wilshire's office hours are Monday - Friday 6:00 am to 5:00 pm Pacific time, holidays excluded. L178F FORD,DEBORAH Loan No.:4519266 Page 2 October 01, 2008 PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNERS' NAME PROPERTY ADDRESS LOAN ACCT. NO. ORIGINAL LENDER CURRENT SERVICER FORD, DEBORAH 116 LEE ANN CT ENOLA, PA 1.70251939 4519266 WILMINGTON FINANCE Wilshire Credit Corporation HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face -to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT UM DAYS, IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty(30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. (Continued) YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE http://www.ago.state.co.us/cadc/cadcinain.cfm. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan Way, Beaverton, OR. Wilshire's office hours are Monday - Friday 6:00 am to 5:00 pm Pacific time, holidays excluded. L l 78F FORD,DEBORAH Loan No.:4519266 Page 3 October 01, 2008 APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after they receive your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date.) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 116 LEE ANN CT ENOLA, PA 170251939 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY PAYMENTS and the following amounts are past due: Delinquency $9,108.54 Late Charges $0.00 Other Charges $287.00 Suspense Amount -$538.06 TOTAL $8,857.48 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $8,857.48 PLUS (Continued) YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE http://www.ago.state.co.us/cadc/cadcmain.cfin. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan Way, Beaverton, OR. Wilshire's office hours are Monday - Friday 6:00 am to 5:00 pm Pacific time, holidays excluded. L178F FORD, DEBORAH Loan No.:4519266 Page 4 October 01, 2008 ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be We either by cashier's check certified check or money order made payable and sent to: Wilshire Credit Corporation, P.O. Box 7195, Pasadena, CA 91109-7195. IF YOU DO NOT CURE -THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the ender intends to exercise it's rights to accelerate the mortgage debt. This means that the entire outstanding balance of the debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct it's attorneys to start legal action toforeclose upon .r mortgagedd,nro erty yo IF THE MORTGAGE IS FORE LO ED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to it's attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to actually incurred by the lender even if they exceed $50.00. The attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY ,(30) DAY period You will not be required to gay 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 DEFeUL T PRIOR T : 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,_paying the total amount then past due an late or other charges then due reasonable attorney's fees an costs connected with the foreclosure sale an other costs connected with the Sheriffs Sale as s ecified in writin 1, 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. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment of action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender : Wilshire Credit Corporation Address Payments: P.O. Box 7195, Pasadena, CA 91109-7195 Correspondence: P.O. Box 8517, Portland, OR 97207-8517 Phone Toll-Free: 888.917.1052 Fax Number 503.952.7476 YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. AueNdY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE http://www.ago.state.co.us/cadc/cadcmain.cfm. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan Way, Beaverton, OR. Wilshire's office hours are Monday - Friday 6:00 am to 5:00 pm Pacific time, holidays excluded. L178F FORD,DEBORAH Loan No.:4519266 Page 5 October 01, 2008 Contact : Loan Servicing EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may or may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THE MORTGAGE DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE 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. ATTACHED IS THE CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY If you have any questions, please contact us at our toll-free number above. Sincerely, Loan Servicing Enclosures: PA CCCS List, How to Avoid Foreclosure YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE http://www.ago.state.co.us/cadc/cadcmain.cfin. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan Way, Beaverton, OR. Wilshire's office hours are Monday - Friday 6:00 am to 5:00 pm Pacific time, holidays excluded. L! 78F 93 QQQ6ppp` .? a n q ?? S a _ co F, ?? CASE NO: 2008-07364 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND U S BANK NATIONAL ASSOCIATION VS FORD DEBORAH NOAH CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon FORD DEBORAH the DEFENDANT at 1530:00 HOURS, on the 6th day of January , 2009 at 116 LEE ANN COURT ENOLA, PA 17025 by handing to DEBORAH FORD a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscibed to before me this of So Answers: 18.00 12.60 .00 10.00 R. Thomas Kline .00 40.60 01/07/2009 MARTHA VON ROSENSTIEL By. ? i day Deputy Sheriff A. D. "Cl `= H Him m rn e ul `m -< cr, SHERIFF'S RETURN - REGULAR CASE NO: 2008-07364 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND U S BANK NATIONAL ASSOCIATION VS FORD DEBORAH MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE FORD DEBORAH the DEFENDANT , at 1944:00 HOURS, on the 22nd day of December-, 2008 at 52 ERFORD ROAD APT C CAMP HILL, PA 17011 by handing to MICHAEL FORD, EX-HUSBAND, ADULT IN CHARGE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing Service 6.00 13.50 ?_o 00010aole!?? Affidavit .00 ? Surcharge 10.00 R. Thomas Kline .00 29.50 01/07/2009 MARTHA VON ROSENSTIEL Sworn and Subscibed to By: t before me this day Deputy Sheriff was served upon of A. D. c- z c a ! °Wp y + Cn 01 #23 890CFJ-DN fN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES SERIES 2007-BC2 Plaintiff V. DEBORAH FORD Defendant(s) : NO. 08-7364 PRAECIPE FOR DEFAULT JUDGMENT To the Prothonotary: (XX) Enter judgment in favor of Plaintiff and against: Deborah Ford for want of an answer. (X) Assess Damages as Follows Debt $ 192,025.39 Interest from 12/13/08 to 3/5/09 At $38.78 per diem $ 3,218.74 Total $ 195,244.13 I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this Praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, afte ccurred and at least (10) days prior to the date of the filing of this Praecipe. A copy,?ftk?' otic " c ed. R.C.P. 237.1 Attorney for Plaintiff Martha E. Von Rosenstiel Attorney I.D. #52634 Print/Type Name and ID Number Phone: (610) 328-2887 This day of , 2009 judgment is entered in favor of the Plaintiff and against Defendant(s), Deborah Ford by default for want of an answer and damages assessed at the sum of $195,244.13 as per the above certification. Pro onotary, CGm_b6lAnd unty IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: Deborah L. Ford CHAPTER7 Debtor BANKRUPTCY NO. 1-09-bk-00746 U.S. Bank National Association, as Trustee for the Specialty Underwriting and Residential Finance Trust Mortgage Loan Asset-Backed Certificates Series 2007-BC2 represented herein by Wilshire Credit Corporation as Servicing agent Movant, v. . 11 U.S.C.§362 Deborah L. Ford Respondent Leon P. Haller, Esquire, Trustee Additional Respondent ORDER AND NOW, after notice and hearing, it is ORDERED that the Automatic Stay is hereby modified under Section 362(d)(2). AND THAT Rule 4001(a)(3) is hereby waived and movant is permitted to proceed with the action in foreclosure action against premises 116 Lee Ann Court Enola PA 17025. By the Cowt, 1 7 1 1 4:j:? .B jadV (JG) Ais document is electronically signed and ,fled on the same date. Dated: February 26, 2009 Case 1:09-bk-00746-MDF Doc 15 Filed 02/26/09 Entered 02/26/09 12:19:04 Desc Main Document Page 1 of 1 Martha E. Von Rosenstiel, P.C. Attorney for Plaintiff Martha E. Von Rosenstiel 649 South Avenue Secane, PA 19018 (610) 328-2887 Attorney I.D.# 52634 U.S. BANK NATIONAL ASSOCIATION, AS COURT OF COMMON PLEAS TRUSTEE FOR THE SPECIALTY CUMBERLAND COUNTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-: BACKED CERTIFICATES SERIES 2007-BC2 14523 SW Millikan Way, Suite 200 Case No: 08-7364 Beaverton, OR 97005 Plaintiff VS. DEBORAH FORD 116 Lee Ann Court Enola, PA 17025 Defendant TO: Deborah Ford 116 Lee Ann Court Enola, PA 17025 IMPORTANT NOTICE #23890CTD - DD 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 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, 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 717-249-316 Martha E. Von Rosenstiel Attorney for Plaintiff Dated: January 27, 2009 Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887 Attorney I.D.# 52634 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE : TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES SERIES 2007-BC2 Plaintiff VS. DEBORAH FORD Defendant(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 08-7364 NON MILITARY AFFIDAVIT Martha E. Von Rosenstiel, Esquire hereby certifies that: #23890CFJ-DN 1. I am the attorney for the plaintiff herein. 2. The individual involved in this action is the owner of the premises described in the mortgage underlying this action. 3. The procedures of the Law Office of Martha E. Von Rosenstiel, P.C. are designed to discover facts concerning the military status of the mortgagor(s) and/or real owner(s). 4. Said procedures were followed in connection with the instant foreclosure proceeding. 5. Inquiry made with the Department of Defense, has confirmed that the defendant(s) is/are not in the military. 6. On information and belief, named mortgagor(s) and real owner(s) is/are not incompetent nor a service member in military service as defined by the Servicemembers Civil Relief Act, 50 U.S.C. Appx. Section 501 et seq. This verification is made subject to the penalties of 18 Pa.C.S. §4904 relating to authorities. Martha E. Von Ro'sen Attorney for Plaintiff to Dated: March 05, 2009 rv .la Cl> •rn 1. 4 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, 1 Courthouse Square, Carlisle, PA 17013 Deborah Ford 116 Lee Ann Court Enola, PA17025 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES SERIES 2007-BC2 PLAINTIFF VS. DEBORAH FORD DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 08-7364 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 indi ed he amount of $195,244.13 on March 05, 2009. Curt L Prothonotary Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Curt Long, Prothonotary ? Judgment on Award of Arbitration F7 Judgment on Court Findings If you have any questions concerning this notice, please call: Attorney Martha E. Von Rosenstiel, Esquire at this telephone number: 610-328-2887. 23890CWE-DN f f Commonwealth of Pennsylvania COUNTY OF CUMBERLAND U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR COURT OF COMMON PLEAS THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES SERIES 2007-BC2 V. DOCKET NO. 08-7364 DEBORAH FORD ATTORNEY I.D. #52634 Praecipe for Writ of Execution TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: AMOUNT DUE $ 195,244.13 INTEREST from 3/6/2009 to 9/2/2009 At 6 % $ 5,808.29 TOTAL* $ 201,052.42 *Plus costs to be endorsed Martha E. Von Rosenstiel Attorney for Plaintiff 649 South Avenue, Unit #6 Secane, PA 19018 (610) 328-2887 PREM: 116 Lee Ann Court, Enola, PA 17025 C7 O CA "? M N dN', td ZAH +?' N o°oo a o ?A zo d?c o 75 4rpS Qd ? V dWg ? '" ? o ? ??? d V? ? ? nn N O O p p o0 wW ,..?aw? e o ?? ?o°lS-o O °' o O d.., d ?n .I,+ W p > o 4 d Ea,, d o4 ? ?? W O ? Q ? ,? o ? M 00 00? Z?grW?d y, H ? o o? j 7S C) o ?1AQW °dOa t joh- Q N Q O p 0 'D V d 9 C) l r, r? "= c? r #23890-DN Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887 Attorney I.D.# 52634 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES SERIES 2007-BC2 Plaintiff VS. DEBORAH FORD Defendant(s) Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY : NO: 08-7364 LEGAL DESCRIPTION ALL that certain tract of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at the point of intersection between the Southerly dedicated right-of-way line of Lee Ann Court (A 50 foot Right-of-way) and the line of adjoiner between Lots 0-2 and 0-3 on the hereinafter mentioned plan of lots; thence South 41 degrees 27 minutes 51 seconds East by said line of adjoiner and through a party wall of townhouses erected on Lots 0-2 and 0-3 a distance of 110.00 feet to a point; thence South 48 degrees 32 minutes 09 seconds West a distance of 22.00 feet to a point; thence North 41 degrees 27 minutes 51 seconds West by the line of adjoiner between lots 0-3 and 0-4 and through a party wall of townhouses erected on lots 0- 3 and 0-4 on the hereinafter mentioned plan of lots a distance of 110.00 feet to a point on the Southerly dedicated right-of-way line of Lee Ann Court; thence North 48 degrees 32 minutes 09 seconds East by said Southerly dedicated Right-of-way line of Lee Ann Court, the point and place of beginning. SUBJECT to a 10 feet access easement, restrictions and other matters as set forth on said plan of lots. SUBJECT to the easements, restrictions and burdens set forth in the declaration for the final subdivision plan for Sherwood Court phase on, dated April 19, 1993, and recorded in the Cumberland County Recorder of Deeds Office in Plan Book 68, Page 11 as revised by the above said plan, said declaration being dated March 23, 1995 and recorded May 15, 1995 in the Cumberland County Recorder's Office in Miscellaneous Book 496, Page 79, which are assumed and agreed it by the Grantee(s) herein. IMPROVEMENTS: Residential dwelling Tax Parcel # 09-15-1288-240 TITLE TO SAID PREMISES IS VESTED IN Deborah Ford by Deed from Michael J. Ford and Deborah Ford, dated 12/22/2006 and recorded 12/29/2006 in Deed Book 278, Page 901. Martha E. Vft Rosenstiel, P.C. MarthwE. Von Rosenstiel, Esquire 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887 Attorney I.D.# 52634 #23890CAM - DN Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION, COURT OF COMMON PLEAS AS TRUSTEE FOR THE SPECIALTY CUMBERLAND COUNTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES SERIES 2007-BC2 Plaintiff VS. DEBORAH FORD : NO: 08-7364 Defendant(s) AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 MARTHA E. VON ROSENSTIEL, ESQUIRE, attorney for the 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 116 Lee Ann Court, Enola, PA 17025: 1. Name and address of owners(s) or reputed owner(s) Deborah Ford 116 Lee Ann Court Enola, PA 17025 2. Name and address of defendant(s) in the judgment: Deborah Ford 116 Lee Ann Court Enola, PA 17025 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: East Pennsboro Township 98 S. Enola Drive Enola, PA 17025 4. Name and address of the last recorded holder of every mortgage of record: NONE 5. Name and address of every other person who has any record lien on the property: NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Sherwood Court Homeowners Association c/o Westpoint Management 37 McMurray Road, Ste 2102 Upper St. Clair, PA 15241 7. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Cumberland County Tax Claim 1 Courthouse Square Carlisle, PA 17013 Cumberland Register of Wills County Courthouse Carlisle, PA 17013 Attorney General of the U.S. C/O Assistant Attorney General Tax Division U.S. Department of Justice P.O. Box 227 Washington, DC 20044 PA Dept of Revenue Inheritance Tax Bureau Strawberry Square, 11 th Floor Harrisburg, PA 17128 Family Court/Domestic Relations 1 Courthouse Square Carlisle, PA 17013 PA. Department of Revenue Bureau of Compliance Attn: Sheriff Sale Section P.O. Box 218230 Harrisburg, PA. 17128-1230 Dept of Public Welfare P.O. Box 2675 Harrisburg, PA 17105 Pennsylvania Department of Revenue Bureau of Individual Taxes .PO Box 280603 Harrisburg, PA 17128-0603 Occupant 116 Lee Ann Court Enola, PA 17025 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 ade subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to au ' sr_. Martha E. VohR-osen Attorney for Plaintiff Dated: March 06, 2009 z ._ °v? ? '"°' ?:, ; ?. ?; ? .?? .z-: r ` ? ; ?' ?-? ; ? .y ? ?--i ? ?? Y t,-+ 'w ?? #23890-CWE-DN Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit 6 Secane, PA 19018 Phone: 610-328-2887 Attorney I.D. #52634 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES SERIES 2007-BC2 Plaintiff Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY : No: 08-7364 VS. DEBORAH FORD Defendant(s) CERTIFICATE TO THE SHERIFF I hereby certify that I am the attorney of record for the plaintiff in this action again real property and further certify that this property is: FHA - Tenant Occupied or Vacant Commercial As a result of a Complaint in Assumpsit FW That the plaintiff has complied in all respects with Section 403 of the Mortgage Assistance Act including, but not limited to: (a) Service of the Notice on the Defendants (b) Expiration of the 30 days since Service of the Notice (c) Defendants' failure to request or appear at meeting with mortgagee or Consumer Credit Counseling Agency (d) Defendants' Failure to file application with the Homeowners Emergency Assistance Program I further agree to indemnify and hold harmless the Sheriff for any false stat ent given herein. Martha E. Von Rosenstiel Attorney for Plaintiff C? : Fri ., mt C 3 m Q l..) F7 iV "? Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 649 South Avenue, Unit 6 P.O. Box 822 Secane, PA 19018 610 328-2887 Attorney 1.131 52634 Attorney for Plaintiff U.S. Bank National Association, as Trustee for the Specialty Underwriting and Residential Finance Trust Mortgage Loan Asset-Backed Certificates Series 2007-BC2 14523 SW Millikan Way, Suite 200 Beaverton OR 97005 Plaintiff VS. Deborah Ford 116 Lee Ann Court Enola, PA 17025 Defendants COURT OF COMMON PLEAS CUMBERLANDCOUNTY No: 08-7364 AFFIDAVIT OF LAST KNOWN ADDRESS COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF DELAWARE MARTHA E. VON ROSENSTIEL, attorney for the 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 last known addresses of the defendants are: 1. Name and address of owners(s) or reputed owner(s) and/or defendant(s) in the judgment: Deborah Ford 116 Lee Ann Court Enola, PA 17025 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 unw=Rosenstiel Martha . Attorney for Plaintiff 0 fla t? tv ,?? 23 890CAM-DN Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887 Attorney I.D.# 52634 U.S. BANK NATIONAL Attorney for Plaintiff : COURT OF COMMON PLEAS ASSOCIATION, AS TRUSTEE FOR CUMBERLAND COUNTY THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET- : BACKED CERTIFICATES SERIES : No: 08-7364 2007-BC2 Plaintiff VS. DEBORAH FORD Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO ALL PARTIES IN INTEREST AND CLAIMANTS: The real estate and improvements, if any, located at and known as 116 Lee Ann Court Enola, PA 17025 will be sold by the Sheriff of Cumberland County on Date of Sale: September 02, 2009 Time of Sale: 10:00 a.m. Place of Sale: Cumberland County Court House, 1 Courthouse Square, Carlisle, PA 17013. This sale is being held on a Judgment in Mortgage Foreclosure filed under Docket No. 08-7364 in the Court of Common Pleas of Cumberland County by U.S. Bank National Association, as Trustee for the Specialty Underwriting and Residential Finance Trust Mortgage Loan Asset- Backed Certificates Series 2007-BC2, Plaintiff against Deborah Ford, Defendant(s). Judgment was entered on March 05, 2009 in the amount of $195,244.13. The property was seized and taken in execution as the property of Deborah Ford. The property to be sold at Sheriff's Sale is described as follows: ALT,, that certain tract of land situate in East Pennsboro Township, Cumberland County, Penpgylvania, more particularly bounded and described as follows, to wit: BEGINNING at the point of intersection between the Southerly dedicated right-of-way line of Lee Ann Court (A 50 foot Right-of-way) and the line of adjoiner between Lots 0-2 and 0-3 on the hereinafter mentioned plan of lots; thence South 41 degrees 27 minutes 51 seconds East by said line of adjoiner and through a party wall of townhouses erected on Lots 0-2 and 0-3 a distance of 110.00 feet to a point; thence South 48 degrees 32 minutes 09 seconds West a distance of 22.00 feet to a point; thence North 41 degrees 27 minutes 51 seconds West by the line of adjoiner between lots 0-3 and 0-4 and through a party wall of townhouses erected on lots 0-3 and 0-4 on the hereinafter mentioned plan of lots a distance of 110.00 feet to a point on the Southerly dedicated right-of-way line of Lee Ann Court; thence North 48 degrees 32 minutes 09 seconds East by said Southerly dedicated Right-of-way line of Lee Ann Court, the point and place of beginning. SUBJECT to a 10 feet access easement, restrictions and other matters as set forth on said plan of lots. SUBJECT to the easements, restrictions and burdens set forth in the declaration for the final subdivision plan for Sherwood Court phase on, dated April 19, 1993, and recorded in the Cumberland County Recorder of Deeds Office in Plan Book 68, Page 11 as revised by the above said plan, said declaration being dated March 23, 1995 and recorded May 15, 1995 in the Cumberland County Recorder's Office in Miscellaneous Book 496, Page 79, which are assumed and agreed it by the Grantee(s) herein. Tax ID #09-15-1288-240 IMPROVEMENTS: Residential Dwelling A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. Judgment was recovered in the Court of Common Pleas of Cumberland County Civil Action No. 08-7364. You should check with the Sheriff's Office by calling (717) 240-6390 to determine the actual date of the filing of the schedule. No further notice of the filing of the Schedule of Distribution will be given. R. Thomas Kline, Sheriff of Cumberland County ATTORNEY FOR PLAINTIFF: MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire Attorney for Plaintiff 649 South Avenue, Unit #6 Secane, PA 19018 Phone: (610) 328-2887 Fax: (610) 328-2875 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-7364 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due U.S. BANK NATIONAL ASSOCIATION, as Trustee for THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES SERIES 2007-BC2, Plaintiff (s) From DEBORAH FORD (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 $195,244.13 L.L. $.50 Interest from 3/06/09 to 9/02/09 at 6% - $5,808.29 Atty's Comm % Due Prothy $2.00 Atty Paid $189.10 Other Costs Plaintiff Paid Date: 3/10/09 Curtis R. L g, Proti4arry (Seal) By: Deputy REQUESTING PARTY: Name: MARTHA E. VON ROSENSTIEL, ESQUIRE Address: 649 SOUTH AVENUE, UNIT #6 SECANE, PA 19018 Attorney for: PLAINTIFF Telephone: 610-328-2887 Supreme Court ID No. 52634 Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887 Attorney I.D.# 52634 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES SERIES 2007-BC2 Plaintiff vs. #23890CAM - DN Attorney for Plaintiff 9 COURT OF COMMON PLEAS CUMBERLAND COUNTY : NO: 08-7364 DEBORAH FORD Defendant(s) AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1 MARTHA E. VON ROSENSTIEL, ESQUIRE, attorney for the Plaintiff in the above action, hereby verifies that on March 23, 2009 , true and correct copies of the Notice of Sheriff's Sale were served upon recorded lienholders and any known interested parties by regular first class mail, postage prepaid with Certificate of Mailing evidencing said service attached hereto as Exhibit I. 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 falsificati s. Martha E. Von Rosenstiel Attorney for Plaintiff Dated: March 06, 2009 For Accountable Mail Q d _r N ? m 0 O OD -4 tT a W # SS g go -nZ(n5'v Tc -?nD n 0 n 0 C.) oZi ym a? m 43D? Otnx Oo oc c c?c z o_o w o w (D O -, O? CD -- o_•3. m CO ppD3 w o Q w c Q -4? CO ?w DTID O W y O C7 CA G N T3 O O (?D (D (D N (D 'o s cmO C? c mo? xov,?'K n m o=7 O O y (D O p) -OO O A. N O $tG)3 Dc o U. ONOs c c m D a v, a y 0> D mw C) ?? '' MoD o Dm c-0 cn -fm - -4 ?M 7 ?? n Om -V -4 7 ff 0i `c M. O "U C VO (D O, D N Cn (D D 1] N 7 O N D -40 o c D?<'? n? D wm 3=-NO c x n @ o c (O o-0 c m C NO C ?' O Way ?C C ?00?.0 0. vN WO"N O O O W N WN y ??p DQO O= N -" -4 Cr W N N NON p L m (p W 0 y N N :E CO pNp N C?J1 oD O G (D n ft CD 5a N_. fD 0' X fl. (.+ S. (D m CD U) % :3 :1 M 0 (A ? A fD N O O -^ W C O p (CD 7 CA N CA W CD o c? N 3 - N) CA 06 I I I I 'I I I s m (D 'C n = D) CL L} ' 3S Nd7 O ( n < y N G ? N ? C N W a =;; V C O-? -M. • l D O N -n W- ?j co -o w ?o O w 3 p N_ ? 3 0 9 ? m m W R' m N CO N O O 1 O oo LO O y ? 0CC W CO c ,e. S z N p O ?p W -c+ O G N_ y ID N fON c d d a MA vm N ? n ;--!R r P13 ^ ; AFFIDAVIT OF SERVICE PLAINTIFF: U.S. Bank National Association, as Trustee for the Specialty Underwriting and Residential Finance Trust Mortgage Loan Asset-Backed Certificates Series 2007-BC2 COURT OF COMMON PLEAS DEFENDANT Cumberland COUNTY Deborah Ford COURT NO. 08-7364 SERVE UPON: Deborah Ford TYPEOFACTION 116 Lee Ann Court XX WRIT OF EXECUTION and Notice of Sheriffs Sale Enols, PA 17026 23690-DN X Defendant persoaalig served. Adult family member with whams Defendant resides. Manager/Clerk of place of lodging in which Defendant resides. Relationship is Adult is charge of Defendant's residence who Agent or person in charge of Defendant's office or usual place of business. refused to give name/relationship. Other Description: Age,& ._ Height_f Weight /Z.S Race _4,/ Sex /` Other 1, A911 144ek- a competent adult, being duly sworn according to law, depose and state that I personally handed to .G a true and correct copy of the WRI OF EXECUTION and Notice of Sheriff's Sale issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed Kenneth W, Baker before me this yI S' day 19 Bisbee Drive Notary /h200- f--THEODARE J. HARRIS Buriillgtont i 08016 NOT SERVE NOTAIRY?iC 609-52? 231 STATE O,NEW,?IERSEY o'clock ` M_, Defendant NOT FOUND because, On the day of ? 2"I M MIZ01 012 Moved Unknown No Answer Vacant Date of Attempt: before me this day of 200- Notary: fay ATTORNEY Martha E. Von Rosenstiel, P.C. 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887 )C' 5 (z SPECIAL INSTRUCTIONS: please serve defendant personally or adult In charge of premises OF THE PPS ° HONOTARY 2009 APR 14 AM 10: 51 P61N "vSYLVN1A.. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor U S Bank National Association, vs. Deborah Ford 211CFF3 16, P'1 47 Case Number 2008-7364 SHERIFF'S RETURN OF SERVICE 06/20/2009 07:45 AM - Steven Bender, Deputy Sheriff, who being duly sworn according to law, states that on June 29 2009 at 1155 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 Deborah Ford, located at, 116 Lee Ann Court, Cumberland County, Pennsylvania according to law. 08/31/2009 Property sale postponed to 11/4/2009. 11/03/2009 Property sale postponed to 1/6/2010. 01/0612010 Property sold to Kaushik K. Patel for $ 135,001.00 on 1/6/10. 02/09/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on January 6, 2010 at 10:00 o'clock A.M. He sold the same for the sum of $135,001.00 to Kaushik K. Patel, on behalf of Kaushik K. Patel and Jaimini K. Patel, 30 White Oak Boulevard, being the buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of $ 140,962.48 SHERIFF COST: $4,063.74 February 09, 2010 SHERIFF'S OFFICE OF CUMBERLAND COUNTY F11_ "J L fly SO AN,,WERS,,s, ?,o R4R' ANDERSON, SHERIFF Ie L _q3 c?? ??? Wag rn? SCHEDULE OF DISTRIBUTION Date Filed: 1/27/10 Writ No. 2008-7364 Civil Term U.S. Bank National Association, As Trustee for the Specialty Underwriting and Residential Finance Trust Mortgage Loan Asset-Backed Certificates Series 2007-BC2 Vs Deborah Ford Sale Date: January 6, 2010 Buyer: Kaushik K. Patel Bid Price: $ 135,001.00 Real Debt: $ 195,244.13 Interest: 5,808.29 Attorney Writ Costs: 189.10 Total: $ 201,241.52 DISTRIBUTION: Receipts: Cash on Account (04/20/2009): $ 1,500.00 Cash on Account (01/06/2010): 14,000.00 Cash on Account (01/22/2010): 126,962.48 Total Receipts: $ 142,462.48 Disbursements: Sheriffs Costs Legal Search Transfer Tax State Transfer Tax Local Debra Lupold, East Pennsboro Tax Collector East Pennsboro Townshp (Sewer & Refuse) Attorney Martha E. Von Rosenstiel U.S. Bank National Association Total Disbursements: Balance for distribution: So Answers: onny R. Anderson Sheriff 3763.74 300.00 1,479.74 1,479.74 442.58 2,036.00 1,500.00 131,460.68 ($ 142,462.48) 00.00 SNELBAKER & BRENNEMAN, P. C. ATTORNEY AT LAW 44 W. Main Street Mechanicsburg, PA 17055 TITLE REPORT TO: Sheriff of Cumberland County RE: Sheriffs Sale No. 36, Writ No. 2008-7364 held January 6, 2010 EFFECTIVE DATE: January 6, 2010 PREMISES: 116 Lee Ann Court, East Pennsboro Township, Enola, Cumberland County, Pennsylvania, Tax Parcel No. 09-15-1288-240 (the "Premises") RECITAL: Being the same premises which Michael J. Ford and Deborah Ford by their Deed dated December 22, 2006 and recorded December 29, 2006 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Deed Book 27S. Page 901, granted and conveyed unto Deborah Ford. The Premises identified above and as more fully described in the legal description attached hereto and incorporated by reference herein as "Exhibit A" is subject to the below items and exceptions. All recording and docket locations identified are in the Office of the Recorder of Deeds of Cumberland County and/or the Court of Common Pleas of Cumberland County. EXCEPTIONS: 1. Claims and charges for improvements and repairs to the Premises or delivery of materials thereto for which payment has not been made. 2. Possible unfiled Mechanics Liens and municipal claims, charges and assessments. 3. The rights or claims of any tenants or other parties in possession. 4. Support arrearages of any owner or previous owner of the Premises pursuant to Act 58 of 1997, as amended. 5. Any environmental liens or claims filed or on record in the Federal District Court. 6. Payment of state and local real estate transfer tax, if applicable. 7. Any secured transactions with respect to the Premises. 8. The area of the Premises is not certified. 9. Those matters which a view or inspection of the Premises would reveal. 10. The accuracy of the measurements and dimensions of the Premises or the rights or title of or through any person or persons in possession of same, conflicts with adjoining property, encroachments, projections or any other matter disclosed by an accurate survey of the Premises. 11. The right of use as may be determined by any applicable municipal zoning ordinance or regulation. 12. Any matter not of record at the Court House as of the effective date of this Title Report and subsequent to the date hereof. 13. Any tax increase based on additional assessment made by reason of new construction or major improvements. 14. The absence or failure of proper and required notice being given to all owners and holders of liens and encumbrances intended to be divested by the Sheriffs sale and procedural defects by any judgment creditor or lienholder executing on the Premises giving rise to the Sheriffs sale noted above. 15. Identity and legal competency of all parties at any closing or conveyance of the Premises should be established. 16. Access to the Premises by public road or street is not certified. 17. Suitability or existence of sewer and water facilities on or available to the Premises is not certified. 18. Real Estate taxes on the Premises due and payable but not turned over for collection to the Tax Ch-,im Bureau. 19. All Real Estate taxes on the Premises assessed but not billed as well as those Real Estate taxes accruing on and after January 1, 2010. 20. Subject to the spousal rights, if any, of any spouse of Deborah Ford. 21 Mortgage in the amount of $164,700.00 from Deborah Ford to Wilmington Finance, Inc. dated December 22, 2006 and recorded December 29, 2006 in Mortgage Book 1977, Page 3931, assigned January 8, 2009 in Instrument No. 200900605 to Specialty Underwriting and Residential Finance Trust. -2- 22. Judgment against Deborah Ford in the amount of $195,244.13 in favor of U S Bank National Association entered March 9, 2009 to No. 2008-7364. 23. Judgment in the form of a municipal lien against Deborah Ford in favor of East Pennsboro Township in the amount of $536.00 entered April 7, 2009 to No. 2009-2173. 24. Judgment in the form of a municipal lien against Deborah Ford in favor of East Pennsboro Township in the amount of $1,295.00 entered December 3, 2008 to No. 2008- 7082. 25. Judgment in the form of a municipal lien against Deborah Ford in favor of East Pennsboro 'Township in the amount of $1,042.00 entered July 10, 2008 to No. 2008-4097. 26. Judgment against Michael J. Ford in favor of JMMMPC Company in the amount of $2,125.65 entered September 19, 2006 to No. 2006-5485. 27. Subject to the Declaration in Misc. Book 496, Page 79, the Declaration in Misc. Book 626, Page 383, amended in Misc. Book 638, Page 826, amended in Misc. Book 653, Page 51, amended in Misc. Book 673, Page 457, amended in Misc. Book 683, Page 4503, amended in Misc. Book 688, Page 1294, amended in Misc. Book 697, Page 2933, amended in Misc. Book 706, Page 4946 and amended in Misc. Book 716, Page 3150. 28. Subject to all building setback lines, easements, notes, conditions, restrictions and all other matters appearing on the Plan of Sherwood Court recorded in Plan Book 68, Page 11 and revised in Plan Book 72, Page 68. 30. Subject to the rights granted Bell Atlantic-Pennsylvania, Inc. and PP&L in Misc. Book 662, Page 284 and Misc. Book 668, Page 849. 31. Subject to the rights granted PPL Electric Utilities Corp. and Verizon in Miscellaneous Book 715, Page 2347. 32. Subject to the rights granted Bell or Bell of PA in Misc. Book 144, Page 374 and in Misc. Book 154, Page 337. 33. Subject to the rights of others in and to any common elements or limited common elements. 34. Subject to a 10-foot access easement. 35. Subject to the rights of others in and to any portion of the Premises within or adjoining Lee Ann Court. 36. Subject to the easement of any party wall or common walls, structures and support. -3- The undersigned shall not be bound by this Title Report to any person, firm or entity other than the Sheriff of Cumberland County. Snelbaker & Brenneman, P. C. By: Keith O. Brenneman -4- REAL ESTATE SALE NO. 36 Writ No. 2008-7364 Civil U S Bank National Association, as Trustee for The Specialty Underwriting and Residential Finance Trust Mortgage Loan Asset-Backed Certificates, Series 2007-BC2 vs. Deborah Ford Atty.: Martha Von Rosensteil LEGAL DESCRIPTION ALL that certain tract of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and de- scribed as follows, to wit: BEGINNING at the point of in- tersection between the Southerly dedicated right-of-way line of Lee Ann Court (A 50 foot Right-of-way) and the line of adjoiner between Lots 0-2 and 0-3 on the hereinafter mentioned plan of lots; thence South 41 degrees 27 minutes 51 seconds East by said line of adjoiner and through a party wall of townhouses erected on Lots 0-2 and 0-3 a distance of 110.00 feet to a point; thence South 48 degrees 32 minutes 09 seconds West a dis- tance of 22.00 feet to a point; thence North 41 degrees 27 minutes 51 seconds West by the line of adjoiner between lots 0-3 and 0-4 and through a party wall of townhouses erected on lots 0-3 and 0-4 on the hereinafter mentioned plan of lots a distance of 110.00 feet to a point on the South- erly dedicated right-of-way line of Lee Ann Court; thence North 48 degrees 32 minutes 09 seconds East by said Southerly dedicated Right-of-way line of Lee Ann Court, the point and place of beginning. SUBJECT to a 10 feet access easement, restrictions and other matters as set forth on said plan of lots. SUBJECT to the easements, restrictions and burdens set forth in the declaration for the final sub- division plan for Sherwood Court phase on, dated April 19, 1993, and recorded in the Cumberland County Recorder of Deeds Office in Plan Book 68, Page 11 as revised by the above said plan, said declaration being dated March 23, 1995 and recorded May 15, 1995 in the Cumberland County Recorder's Office in Miscel- laneous Book 496, Page 79, which are assumed and agreed it by the Grantee(s) herein. IMPROVEMENTS: Residential dwelling. Tax Parcel # 09-15-1288-240. TITLE TO SAID PREMISES IS VESTED IN Deborah Ford by Deed from Michael J. Ford and Deborah Ford, dated 12/22/2006 and re- corded 12/29/2006 in Deed Book 278, Page 901. PROPERTY ADDRESS: 116 Lee Ann Court, Enola, PA 17025. EXHIBIT A Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887 Attorney I.D.# 52634 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES SERIES 2007-BC2 Plaintiff VS. DEBORAH FORD Defendant(s) 423890CAM - DN Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 08-7364 AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 MARTHA E. VON ROSENSTIEL, ESQUIRE, attorney for the 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 116 Lee Ann Court, Enola, PA 17025: 1. Name and address of owners(s) or reputed owner(s) Deborah Ford 116 Lee Ann Court Enola, PA 17025 2. Name and address of defendant(s) in the judgment: Deborah Ford 116 Lee Ann Court Enola, PA 17025 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: East Pennsboro Township 98 S. Enola Drive Enola, PA 17025 4. Name and address of the last recorded holder of every mortgage of record: NONE 5. Name and address of every other person who has any record lien on the property: NONV 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: Sherwood Court Homeowners Association c/o Westpoint Management 37 McMurray Road, Ste 2102 Upper St. Clair, PA 15241 7. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Cumberland County Tax Claim 1 Courthouse Square Carlisle, PA 17013 Cumberland Register of Wills County Courthouse Carlisle, PA 17013 Attorney General of the U.S. C/O Assistant Attorney General Tax Division U.S. Department of Justice P.O. Box 227 Washington, DC 20044 PA Dept of Revenue Inheritance Tax Bureau Strawberry Square, 11th Floor Harrisburg, PA 17128 Family Court/Domestic Relations 1 Courthouse Square Carlisle, PA 17013 PA. Department of Revenue Bureau of Compliance Attn: Sheriff Sale Section P.O. Box 218230 Harrisburg, PA. 17128-1230 Dept of Public Welfare P.O. Box 2675 Harrisburg, PA 17105 Pennsylvania Department of Revenue Bureau of Individual Taxes PO Box 280603 Harrisburg, PA 17128-0603 Occupant 116 Lee Ann Court Enola, PA 17025 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.----. Martha E. W sengtiel - ' Attorney for Plaintiff Dated: March 06, 2009 11 23890CAM-DN i Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887 Attorney I.D.# 52634 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET- BACKED CERTIFICATES SERIES 2007-BC2 Plaintiff vs. DEBORAHFORD Defendant(s) Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 08-7364 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO ALL PARTIES IN INTEREST AND CLAIMANTS: The real estate and improvements, if any, located at and known as 116 Lee Ann Court Enola, PA 17025 will be sold by the Sheriff of Cumberland County on Date of Sale: September 02, 2009 Time of Sale: 10:00 a.m. Place of Sale: Cumberland County Court House, 1 Courthouse Square, Carlisle, PA 17013. This sale is being held on a Judgment in Mortgage Foreclosure filed under Docket No. 08-7364 in the Court of Common Pleas of Cumberland County by U.S. Bank National Association, as Trustee for the Specialty Underwriting and Residential Finance Trust Mortgage Loan Asset- Backed Certificates Series 2007-BC2, Plaintiff against Deborah Ford, Defendant(s). Judgment was entered on March 05, 2009 in the amount of $195,244.13. The property was seized and taken in execution as the property of Deborah Ford. The property to be sold at Sheriff's Sale is described as follows: ALL thaw certain tract of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, snore particularly bounded and'described as follows, to wit: BEGINNING at the point of intersection between the Southerly dedicated right-of-way line of Lee Ann Court (A 50 foot Right-of-way) and the line of adjoiner between Lots 0-2 and 0-3 on the hereinafter mentioned plan of lots; thence South 41 degrees 27 minutes 51 seconds East by said line of adjoiner and through a party wall of townhouses erected on Lots 0-2 and 0-3 a distance of 110.00 feet to a point; thence South 48 degrees 32 minutes 09 seconds West a distance of 22.00 feet to a point; thence North 41 degrees 27 minutes 51 seconds West by the line of adjoiner between lots 0-3 and 0-4 and through a party wall of townhouses erected on lots 0-3 and 0-4 on the hereinafter mentioned plan of lots a distance of 110.00 feet to a point on the Southerly dedicated right-of-way line of Lee Ann Court; thence North 48 degrees 32 minutes 09 seconds East by said Southerly dedicated Right-of-way line of Lee Ann Court, the point and place of beginning. SUBJECT to a 10 feet access easement, restrictions and other matters as set forth on said plan of lots. SUBJECT to the easements, restrictions and burdens set forth in the declaration for the final subdivision plan for Sherwood Court phase on, dated April 19, 1993, and recorded in the Cumberland County Recorder of Deeds Office in Plan Book 68, Page 11 as revised by the above said plan, said declaration being dated March 23, 1995 and recorded May 15, 1995 in the Cumberland County Recorder's Office in Miscellaneous Book 496, Page 79, which are assumed and agreed it by the Grantee(s) herein. Tax ID #09-15-1288-240 IMPROVEMENTS: Residential Dwelling A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. Judgment was recovered in the Court of Common Pleas of Cumberland County Civil Action No. 08-7364. You should check with the Sheriff's Office by calling (717) 240-6390 to determine the actual date of the filing of the schedule. No further notice of the filing of the Schedule of Distribution will be given. R. Thomas Kline, Sheriff of Cumberland County ATTORNEY FOR PLAINTIFF: MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire Attorney for Plaintiff 649 South Avenue, Unit #6 Secane, PA 19018 Phone: (610) 328-2887 Fax: (610) 328-2875 Martha E. Von Rosenstiel, P.C. Attorney for Plaintiff Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887 Attorney I.D.# 52634 U.S. BANK NATIONAL ASSOCIATION, COURT OF COMMON PLEAS AS TRUSTEE FOR THE SPECIALTY CUMBERLAND COUNTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES SERIES 2007-BC2 Plaintiff VS. DEBORAH FORD Defendant(s) : NO: 08-7364 LEGAL DESCRIPTION #23890-DN ALL that certain tract of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at the point of intersection between the Southerly dedicated right-of-way line of Lee Ann Court (A 50 foot Right-of-way) and the line of adjoiner between Lots 0-2 and 0-3 on the hereinafter mentioned plan of lots; thence South 41 degrees 27 minutes 51 seconds East by said line of adjoiner and through a party wall of townhouses erected on Lots 0-2 and 0-3 a distance of 110.00 feet to a point; thence South 48 degrees 32 minutes 09 seconds West a distance of 22.00 feet to a point; thence North 41 degrees 27 minutes 51 seconds West by the line of adjoiner between lots 0-3 and 0-4 and through a party wall of townhouses erected on lots 0- 3 and 0-4 on the hereinafter mentioned plan of lots a distance of 110.00 feet to a point on the Southerly dedicated right-of-way line of Lee Ann Court; thence North 48 degrees 32 minutes 09 seconds East by said Southerly dedicated Right-of-way line of Lee Ann Court, the point and place of beginning. SUBJECT to a 10 feet access easement, restrictions and other matters as set forth on said plan of lots. SUBJECT to the easements, restrictions and burdens set forth in the declaration for the final subdivision plan for Sherwood Court phase on, dated April 19, 1993, and recorded in the Cumberland County Recorder of Deeds Office in Plan Book 68, Page 11 as revised by the above said plan, said declaration being dated March 23, 1995 and recorded May 15, 1995 in the Cumberland County Recorder's Office in Miscellaneous Book 496, Page 79, which are assumed and agreed it by the Grantee(s) herein. IMPROVEMENTS: Residential dwelling Tax Parcel # 09-15-1288-240 TITLE TO SAID PREMISES IS VESTED IN Deborah Ford by Deed from Michael J. Ford and Deborah Ford, dated 12/22/2006 and recorded 12/29/2006 in Deed Book 278, Page 901. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA)' NO 08-7364 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due U.S. BANK NATIONAL ASSOCIATION, as Trustee for THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST MORTGAGE LOAN ASSET-BACKED CERTIFICATES SERIES 2007-BC2, Plaintiff (s) From DEBORAH FORD (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 $195,244.13 L.L. $.50 Interest from 3/06/09 to 9/02/09 at 6% -- $5,808.29 Atty's Comm % Due Prothy $2.00 Atty Paid $189.10 Other Costs Plaintiff Paid i Date: 3/10/09 (Seal) urtis R. Long, rothonotar By: Deputy REQUESTING PARTY: Name: MARTHA E. VON ROSENSTIEL, ESQUIRE Address: 649 SOUTH AVENUE, UNIT #6 SECANE, PA 19018 Attorney for: PLAINTIFF Telephone: 610-328-2887 Supreme Court ID No. 52634 Real Estate Sale # On May 5, 2009 the Sheriff levied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, PA Known and numbered as, 116 Lee Ann Court, Enola, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 5, 2009 By: Real Estate Coordinator 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: July 24, July 31 and August 7, 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. REAL ESTATE SALE NO. 36 Writ No. 2008-7364 Civil U S Bank National Association, as Trustee for The Specialty Underwriting and Residential Finance Trust Mortgage Loan Asset-Backed Certificates, Series 2007-BC2 vs. Deborah Ford Atty.: Martha Von Rosensteil LEGAL DESCRIPTION ALL that certain tract of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and de- scribed as follows, to wit: BEGINNING at the point of in- tersection between the Southerly dedicated right-of--way line of Lee Ann Court (A 50 foot Right-of-way) and the line of adjoiner between Lots 0-2 Marie Coyne, SWORN TO AND SUBSCRIBED before me this da of August, 2009 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 The Patriot-News Co. . 812,Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 the 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 Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 07/24/09 07/31/09 08/07/09 4 WV6 ................ ,Sworn to a s>Gbscribed before mo thi 14 y f ? ugust, 2009 A.D. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L Kisner, Notary Public City Of Harrisburg; Dauphin County My Convniesion E)ires Nov. 26, 2011 Member, Pennsylvania Association of Notaries Sale No. 86 Writ No. 2dW7W CIvU Term U 8 Sw* Nedonsl Associstion, ss Trt is We for The Spsolelty, (indsrwrltlnp, end Rssidamtlal PlnanceTlrust Mortgage Loin Asset-Busked Certificates, Series 2607-BC2 vs. Deborah Pord Atty: Marthe Von Rosenstell LEGAL DESCRIPTION ALL that certain tract of land situate in East Pennsbvro Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGIlV 41NG at the point of intersection between the Southerly dedicated right-of-way line of Lee Ann Court (A 50 foot Right-of-way) and the line of adjoiner between Lots 0-2 and 0-3 on the hereinafter mentioned plan.of lots;:thence South 41 degrees 27 minutes 51 seconds East by said line of adjoiner and through a,party wall of townhouses erected on Lots 0.2 and 0.3 a,distance of 110.00 feet to a point; thence South 48 degrees 32 minutes 09, seconds Walt a distance of 22.00 feet to a point; thence North 41 degrees 27 minutes 51 seconds West by the line of adjoiner between lots 0-3 and D4 and through` a party wall of townhouses erected on lots 0.3 and 0.4 on the hereinafter mentioned plan of, lots a distance of 110.00 feet to a point on the Southerly dedicated right-of-way line of Lee Ann Court; thence Nort)r 48 degrees 32 minutes 09 seconds East by said Southerly dedicated Riot-of-way line of Lee Ann Court, the point and place of begiamng. SUBJECT' to a 10 -feet access easement, restrictions and other matters as set forth on said plan of lots. SUBJECT to the easements, restrictions and burdens, set forth in the declaration for the final subdivision plan for Sherwood Court phase on, dated April 19,1993, and recorded in the Cumberland County Recorder of Deeds Office in Plan Book 68, Page 11 as revised by the above said pica said declaration being dated Mach 23, 1995 and recorded May 15, 1995 in the Cumberland County Recorder's Office in, Miscellaneous Book 496, Page 79, which are assumed and agreed it by , the Grantee(s) herein. Ilv1PROVEMENTS: Residential dwelling Tax Parcel '# 09-15-1288-240 TITLE TO SAID PREMISES IS VESTED IN Deborah Ford by Deed from Michael J. Ford and Deborah Ford, dated 1211y2006 and wordod 12129/2006 in Deed , Book: 278, Page - 901'. PROPERTY ADDRESS: 116 Let Arne Court EWk PA 17025 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which DEBORAH FORD is the grantee the same having been sold to said grantee on the 6TH day of JAN A.D., 202010, under and by virtue of a writ Execution issued on the 10TH day of MARCH, A.D., 2009, out of the Court of Common Pleas of said County as of Civil Term, 2008 Number 7364, at the suit of SPECIALTY UNDERWRITING & RESIDENTIAL FIN TRUST MTG LOAN TR against DEBORAH FORD is duly recorded as Instrument Number 201003869. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ,A.D.?, ojD day of - U 0 Recorder of Deeds Pan* M?L?nN?Mnd?? R?t? I?IIn1?jr?f?,M i?l? ??S?M?11?b?" 11iMiLb?lirMiM#Mi1rA a?a;?s?,t? ti'.'