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HomeMy WebLinkAbout09-1042!1 GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEYER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2006-EQ1 4708 Mercantile Drive North Fort Worth, TX 76137 Plaintiff vs. MORRIS STANLEY JR. Mortgagor and Record Owner 7000 Wertzville Road Mechanicsburg, PA 17050 Defendant Term ('r wi 41- jGGf? CIVIL ACTIO14: MORTGA?=°??LCL0lURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 9400 or 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243- 2). 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website httn://www.nhfa.ort/consumers/homeowners/real aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: hitp://www.Dhiladelphiafed.orWforeclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(a goldbecklaw com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is Courtenay Dunn who can be reached at 215-825-6311 or Fax: 215-825-6411. Please reference our Attorney File Number of 76419FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2006-EQ1, 4708 Mercantile Drive North, Fort Worth, TX 76137. 2. The names and addresses of the Defendant is MORRIS STANLEY JR., 7000 Wertzville Road, Mechanicsburg, PA 17050, who is the mortgagor and record owner of the mortgaged premises hereinafter described. Original mortgagor KELLY F. STANLEY is hereby released of record. 3. On June 02, 2006 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS NOMINEE FOR EQUIFIRST CORPORATION, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1953, Page 4519. The mortgage has been assigned to: DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2006-EQ1 by assignment of Mortgage. Plaintiff is the real party in interest pursuant to a purchase or transfer of the mortgage obligation from the last record holder and an Assignment of Mortgage to Plaintiff has been and/or will be lodged for recording with the Recorder of Deeds in the ordinary course of business. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for October 01, 2008 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ..................................................................................$217,031.80 Interest from 9/01/2008 to 12/31/2008 @ 9.125% ..................................................$6,619.72 1/1/2009 to 2/28/2009 @ 8.95% ........................................................$3,139.98 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph .................$10,851.59 Late Charges from 10/01/2008 to 02/28/2009 ..........................................$1,968.39 Monthly late charge amount at $89.65 Costs of suit and Title Search ......................................................................$900.00 Escrow ........................................................................................................ ($740.73) Fees ................................................................................................................$90.50 Monthly Escrow amount $304.38 $239,861.25 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in persona m" judgment) against the Defendant in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant has received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendant have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $239,861.25, together with interest at the rate of $53.21, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. BY. GOLDBE K McC FERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION Lonna Cross as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unworn falsification to authorities. Date: J" U[.k, 1.2? -2?W S Lonna rose Assistant Vice President #76419FC MORRIS STANLEY JR. and KELLY F. STANLEY 7000 Wertzville Road Mechanicsburg, PA 17050 Ey,ki6itA t?ixt` Amedew T ale Insur *e. Company CaaOmih M NM PA06M"2140 sc?ou.e c Vpl D?alptlon ALL TRIM CWTAII4lab, paiosi, w t=o s of land Waft a Whw Tows ty CwWWdaad CbvW; Psaaglraaia. baaaded and dssa 11 as fbUwvM Lii?.la ac a paint is the oeolediae of die Salle 8iatway, RoabNa 9x14 (aba known a, watavilie Rand), wltidt said point is at file ioleise p an of dw et. I'm Am of a Pima t r POV.Pow (4? fbet wider tLe.ae alaaP said ereeeu line of the af}><amaatioaed prHa?s ri?laf?wetp?Needt One (1) de?ss 1leeaq?Plve (?? miaabs Wad a dbbaae of One A.edeed Seree* to and Uae 7W&(175.1) 64 b a paint; flteaoe aioa *s lice of Laub am of &me* of Ray A. Gww at nit and R.A. 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Earl One Nand 9w r*-R a (175) fsrt, mas or Ma. b a point Mt the orrMsr d Mte SMe 110mrar, Douse 944, ileeritertiortst% gtstros " ft cwdwWa of Stale Nbhomy. Rouse 944 SMM (86) dsw+ Wed oft (90) feat b #0 point and pNoe.of Mw aft PA-3 8K 1953PG453 Exhibit (B ACT 91 NOTICE DATE OF NOTICE: 12/30/2008 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. This is an official notice that the mortgage on 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 Dhone 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 any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca._ Prepared by: GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 Fax (215) 627-7734 Date: 12/30/2008 Homeowners Name: MORRIS STANLEY JR. and KELLY F. STANLEY Property Address: 7000 Wertzville Road, Mechanicsburg, PA 17050 Loan Account No.: 2000186853 Original Lender: SAXON MORTGAGE SERVICES INC. Current Lender/Servicer: SAXON MORTGAGE SERVICES INC. HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of 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 fact-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. 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 fled 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: 7000 Wertzville Road, Mechanicsburg, PA 17050 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payment from 10/01/2008 thru 12/30/2008 (3 mos. at $2,080.66/month) $6,241.98 (b) Late charges from 10/01/2008 thrul2/30/2008 (3 mos. at $89.65/month) $268.95 (c) Other charges; Escrow, Inspec., NSF Checks (d) Other provisions of the mortgage obligation, if any (e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $6,510.93 HOW. TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $6,510.93, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check, certified check or money order made payable and sent to: SAXON MORTGAGE SERVICES INC. 4708 Mercantile Drive North Fort Worth, TX 76137 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (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 brings legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale You may do so by paying the total amount then past due plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and anv other costs connected with the Sheriff s Sale as specified in writing by the lender and by yerforming 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 four (4) to six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: SAXON MORTGAGE SERVICES INC. Address: 4708 Mercantile Drive North Fort Worth, TX 76137 Phone Number: 888-325-3502 Contact Person: Loss Mitigation Department EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Contact: Loss Mitigation Department Phone Number: 888-325-3502 PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES CUMBERLAND COUNTY CCCS OF WESTERN PENNSYLVANIA INC. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 URBAN LEAGUE OF METROPOLITAN HARRISBURG 2107 N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 COMMUNITY ACTION COMM OF THE CAPITAL REGION 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX 234-2227 FINANCIAL COUNSELING SERVICES OF FRANKLIN 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 YWCA OF CARLISLE 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX (717) 731-9589 ADAMS COUNTY HOUSING AUTHORITY 139-143 Carlisle Street Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 r -TI V" ? w w SHERIFF'S RETURN - REGULAR CASE NO: 2009-01042 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS STANLEY MORRIS JR STEVE BENDER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon STANEEY MORRIS JR the DEFENDANT , at 0019:25 HOURS, on the 26th day of February-, 2009 at 7000 WERTZVILLE ROAD MECHANICSBURG, PA 17050 MORRIS STANLEY JR by handing to DEFENDANT a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscibed to before me this So Answers: 18.00 4.50 .00 10.00 R. Thomas Kline .00 32.50 02/27/2009 GOLDBECK MCCAFFERTY & MCKEEVER By. day Deputy Sheriff of A. D. " ter: co In the Court of Common Pleas of Cumberland County DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2006- EQ1 4708 Mercantile Drive North Fort Worth, TX 76137 Plaintiff vs. MORRIS STANLEY JR. (Mortgagor(s) and Record Owner(s)) 7000 Wertzville Road Mechanicsburg, PA 17050 Defendant(s) PRAECIPE FOR JUDGMENT No. CIVIL 09-1042 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING T COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against MORRIS STANLEY JR. by default for want of an Answer. Assess damages as follows: Debt Interest from 04/01/09 to Date of Sale per diem at $53.21 Total (Assessment of Damages attached) $240,255.96 I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 Michael T. McKeever Attorney for Plaintiff I.D. #56129 AND NOW Apra aoo , Judgme t is entered in favor of DEUTSCHE BANK NATION TRUST COMPANY, AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2006- EQ1 and against MORRIS STANLEY JR. by default for want of an Answer and damages assessed in the sum of $240,255.96 as per the above certification. _ A VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the (Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to uns*orn falsification to authorities. 1. That the above named Defendant, MORRIS STANLEY JR., is about unknown years of age, that Defendant's last known residence is 7000 Wertzville Road, Mechanicsburg, PA 17050, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Cilvil Relief Action of Congress of 1940 and its Amendments. Date: 313110q 76419FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING T COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: March 19, 2009 TO: MORRIS STANLEY JR. STANLEY JR., MORRIS 7000 Wertzville Road Mechanicsburg, PA 17050 In the Court of DEUTSCHE BANK NATIONAL TRUST COMPANY, AS ?ommon Pleas TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2006-EQ1 of Cumberland County 4708 Mercantile Drive North Fort Worth, TX 76137 CIVIL ACTION - LAW Plaint vs. Action of MORRIS STANLEY JR. Mortgage Foreclosure (Mortgagor(s) and Record Owner(s)) 7000 Wertzville Road Term Mechanicsburg, PA 17050 No{ CIVIL 09-1042 Defendant(s) TO: MORRIS STANLEY JR. 7000 Wertzville Road Mechanicsburg, PA 17050 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN. OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJE, FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE Yi IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCI LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAN ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 GOLDBECK McCAFF BY: Michael T. McKeev Attorney for Plaintiff Suite 5000 - 701 Market Philadelphia, PA 19106 .PPEARANCE PERSONALLY BONS TO THE CLAIMS SET CHIS NOTICE, A JUDGMENT UR PROPERTY OR OTHER IF YOU DO NOT HAVE A CAN PROVIDE YOU WITH YER, THIS OFFICE MAY BE iAL SERVICES TO ELIGIBLE Esq. & McKEEVER 15-825-6318 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2006-EQ1 4708 Mercantile Drive North Fort Worth, TX 76137 Plaintiff vs. MORRIS STANLEY JR. (Mortgagor(s) and Record owner(s)) 7000 Wertzville Road Mechanicsburg, PA 17050 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. CIVIL 09-1042 ORDER FOR JUDGMENT Please enter Judgment in favor of DEUTSCHE BANK NATIONAL TRUST OMPANY, AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2006-EQ1, and against MO S STANLEY JR. for failure to file an Answer in the above action within (20) days (or sixty (60) days if def dart is the United States of America) from the date of service of the Complaint, in the sum of $240,255.96. 1k."" TA-'-?L Michael T. McKeever Attorney for Plaintiff I hereby certify that the above names are correct and that the precise residence ddress of the judgment creditor is DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2006-EQ1 4708 Mercantile Drive North Fort Worth, TX 76137 and tha the name(s) and last known address(es) of the Defendant(s) is/are MORRIS STANLEY JR., 7000 Wertzvill Road Mechanicsburg, PA 17050; - qL'?4/k-A-11 GOLDBECK MCCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff ' A ASSESSMENT OF DAMAGES TO THE PROTHONOTARY. Kindly assess the damages in this case to be as follows: Principal Balance INTEREST FROM 09/01/2008 -12/31/08 INTEREST FROM 1/1/09 - 2/28/09 INTERST FROM 3/1/09 - 3/31/09 $217,031.80 $6619.72 $3139.98 $1596.52 Reasonable Attorney's Fee Late Charges Costs of Suit and Title Search Escrow Payments Due 1 X $304.38 Escrow Fees $10,851'.59 $537.90 $900.00 $304.38 ($740.73) $90.50 $240,255.96 4&1?? '-/" GOLDBECK McCAFFERTY & cKEEVER BY: Michael T. McKeever Attorney for Plaintiff AND NOW, this a"d day of APrI ( , 2009 damages are assessed as above. i 4 zqp tr?! ?59 ?" Pr Prothy I OF THE P06THNTARY 2009 APR -2 PM 1* 04 ?1? q?p? C t PENNSYLVANIA 4 W oo p o AYN ce 3q4,38to RTC .23tya No*QA*. d Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2006- EQ1 4708 Mercantile Drive North Fort Worth, TX 76137 Plaintiff No. CIVIL 09-J042 VS. MORRIS STANLEY JR. (Mortgagors and Record Owner(s)) 7000 Wertzville Road Mechanicsburg, PA 17050 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WE(L BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned er d against you. Lon Prothonotary By: Deputy If you have any questions concerning the above, please contact: Michael T. McKeever Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2006-EQ1 4708 Mercantile Drive North Fort Worth, TX 76137 Plaintiff VS. MORRIS STANLEY JR. Mortgagor(s) and Record Owner(s) 7000 Wertzville Road Mechanicsburg, PA 17050 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. CIVIL 09-1042 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 04/01/09 to Date of Sale per diem at $53.21 (Costs to be added) $240,255.96 GOLDBECK McCAFFERTY & BY: Michael T. McKeever Attorney for Plaintiff CA co Na 0 -° N ? ? ? QO o. n< m 4 I? H 7- R D A l O A D O O oil o am til ? O z P-q C? ?n O? a Sy O ?-3 ?O y N O x t?1 A oz r Oo la k z r N oood'o° C3 .c- _:_0 0 07 T1 a Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2006- EQ1 4708 Mercantile Drive North Fort Worth, TX 76137 Plaintiff VS. MORRIS STANLEY JR. Mortgagor(s) and Record Owner(s) 7000 Wertzville Road Mechanicsburg, PA 17050 Defendant(s) IN?THE COURT OF C MMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGA E FORECLOSURE NO. CIVIL 09-1042 CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Michael T. McKeever, Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the Act. Michael T. McKeever Attorney for plaintiff cum of 1110 ro%r?rr 209 APR -2 PM 1: 04 PENNSYLVANIA Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2006-EQ1 4708 Mercantile Drive North Fort Worth, TX 76137 Plaintiff vs. MORRIS STANLEY JR. (Mortgagor(s) and Record Owner(s)) 7000 Wertzville Road Mechanicsburg, PA 17050 Defendant(s) IN THE COURT O? COMMON PLEAS i of Cumberland County CIVIL AC ION -LAW ACTION OF MORTGAGE FORECLOSURE No. CI* 09-1042 AFFIDAVIT PURSUANT TO RULE 3129 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR SOUND VIEW HOME LOAN TRUST 2006-EQ1, Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real proper located at: 7000 Wertzville Road Mechanicsburg, PA 17050 1.Name and address of Owner(s) or Reputed Owner(s): MORRIS STANLEY JR. 7000 Wertzville Road Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: MORRIS STANLEY JR. 7000 Wertzville Road Mechanicsburg, PA 17050 3. Name and last known address of every judgment creditor whose judgment is a record lien on to property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 DEUTSCHE BANK NATIONAL TRUST C/O Hallinan Francis S. 1617 JFK Blvd Ste 1400 PHILADELPHIA, PA 19103 IDEARC MEDIA CORP C/O ANDREW I ROSEMAN ESQ C/O Roseman Andrew 1 1831 Chestnut St Ste 802 PHILADELPHIA, PA 19103 YELLOW BOOK SALES AND DISTRIBUTION COMPANY C/O Davis Justin N. 107 N Commerce Way BETHLEHEM, PA 18017 TROAIN MARY L. 856 Magaro Road Enola, PA 17025 TROAIN MARY L. C/O Pecht Wayne M. AWAITING FOR ATTORNEY ADDRESS PHAM LOAN H. 580 Lucinda Lane Mechanicsburg, PA 17055 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child SuOort Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 SECCO INC. 1111 Primose Avenue Camp Hill, PA 17011 DEUTSCHE BANK NATIONAL TRUST 505 South Main Street Suite 100 Orange, CA 92868 MELLON CERTIFIED RESTORATION 419 Church Lane Yeadon, PA 19050 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any re ord interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any may be affected by the sale. KELLY F. STANLEY 7000 WERTZVILLE ROAD MECHANICSBURG, PA 17050 in the property which TENANTS/OCCUPANTS 7000 Wertzville Road Mechanicsburg, PA 17050 . (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties) of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: March 31, 2009 GOLDBECK McCAFFERTY & cKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff i R%M ?, OF 72409 WR -2 PM 1: Q 4 CUMaS=?... - L:OM W LVANIA v CIVIL 09-1042 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2006-EQ 1 4708 Mercantile Drive North Fort Worth, TX 76137 Plaintiff vs. MORRIS STANLEY JR. Mortgagor(s) and Record Owner(s) 7000 Wertzville Road Mechanicsburg, PA 17050 Defendant(s) Term No. CIVIL 09-042 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPT *G TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEM TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WIL L BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: STANLEY 1R., MORRIS MORRIS STANLEY JR. 7000 Wertzville Road Mechanicsburg, PA 17050 Your house at 7000 Wertzville Road, Mechanicsburg, PA 17050 is scheduled to Sheriffs Sale on Wednesday, September 02, 2009, at 10:00 AM, in Commissioners Heari Courthouse to enforce the court judgment of $240,255.96 obtained by DEUTSCHE BAN TRUST COMPANY, AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2006-1 NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS of Cumberland CIVIL ACTION I- LAW ACTION OF MORTGAGE sold at Rm 2nd FL NATIONAL ?I against you. To prevent this Sheriffs Sale you must take immediate action: r? CIVIL 09-1042 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2006-EQ1, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our o ce at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale f good cause. i 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidd?r. You may find out the price bid price by calling the Sheriff of 717-240-6390. i 2. You may be able to petition the Court to set aside the sale if the bid price was gr?ssly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the c}wner of the property as if the sale never happened. I 5. You have a right to remain in the property until the full amount due is paid to t Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to 6. You may be entitled to a share of the money which was paid for your house. A s distribution of the money bid for your house will be filed by the Sheriff within thirty (30) date of the Sheriffs Sale. This schedule will state who will be receiving that money. The : paid out in accordance with this schedule unless exceptions (reasons why the proposed di wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is 7. You may also have other rights and defenses, or ways of getting your house immediately after the sale. You may contact the Foreclosure Resource Center: YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE I FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Sheriff and the ict you. fle of from the y will be tion is if you act HAVE A D BELOW TO CIVIL 09-1042 CIVIL 09-1042 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Foreclosure against you, you still may be able to SAVE YOUR HOME FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call eitherlof the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-22 7 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan r may assist homeowners in default. Please See the PHFA website http://www.phfa.orWconsumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the aci or payoff the mortgage or request a Loan Workout / Home Retention Pack toll free number at 1-866-413-2311 or via email at homeretentionAgoldbec Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or packal requested will be mailed to the address that you request or faxed if you lea with that information. The attorney in charge of our firm's Homeowner Ri Department is Courtenay Dunn who can be reached at 215-825-6311 or F? 6411. Please reference our Attorney File Number of 7641917C. Para informacion en espanol puede communicarse con Loretta a12 Facing the ograms that bout Loss ount current, ge. Call our law.com. e you e a message tention 7 215-825- ?5-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-1042 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY, As Trustee for SOUNDVIEW HOME LOAN TRUST 2006-EQ1, Plaintiff (s) From MORRIS STANLEY, JR. (1) You are directed to levy upon the property of the defendant (s)and to sell SEt 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 $240,255.96 L.L. $.50 Interest from 4/01/09 to Date of Sale per diem at $53.21 Atty's Comm % Due Prothy $2.00 Atty Paid $151.50 Other Costs to be added Plaintiff Paid Date: 4/02/09 urtis R. ®rotho4noy (Seal) By: REQUESTING PARTY: Name: MICHAEL T. McKEEVER, ESQUIRE Address: GOLDBECK McCAFFERTY & McKEEVER SUITE 5000-MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 Deputy Sheriff s Office of Cumberland County rv ~ ~ ° ~'`R- ~ ~~ ~ ~ z ~ R Thomas Kline ~"' '~~,- - Sheriff ~~,~Lcv o~t ~uar,~;~r~, ~ ~~ _ . , q ~ --~ m _,~ Cs ~ ~ Ronny R Anderson ~ ~ '~ ~~ ~ ' ~~ - } ~ Chief Deputy }' ~ -; ~ Jod Smrt Y - ' t Civil Process Sergeant "~` .._ ~`x"~ ~``~"4~ ~ -' Edward L Schorpp Solicitor Deutsche Bank National Trust Company Case Number vs. 2009-1042 Morris Stanley, Jr SHERIFF'S RETURN OF SERVICE 07/07/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED, per letter of intstruction from Attorney Michael McKeever. SHERIFF COST: $104.55 SO ANS '~ July 07, 2009 R THOMAS KLINE, SHERIFF #a`~ *I°~1~4 q3 ~~, aa~ ~ ~. ... Real Estate Sale # On May 5, 2009 the Sheriff levied upon the defendant's interest in the real property situated in Silver Spring Township, Cumberland County, PA Known and numbered as, 7000 Wertzville Road, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 5, 2009 By: ~~~~ ,e~../ Real Estate Coordinator "g"irt .,,~ ~ 1, ~~~w ~----, ~, _ ~ D ~~. -~~~