HomeMy WebLinkAbout09-1410J/
GOLDBECK MCCAFFERTY & McKEEVER
BY: MICHAEL T. MCKEEVER
ATTORNEY I.D. #56129
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
(866) 413-2311
W W W.GOLDBECKLAW.COP
ATTORNEY FOR PLA
BANK OF AMERICA, I
SUCCESSOR BY MER(
NATIONAL ASSOCIA]
CERTIFICATE HOLDE
BACKED SECURITIES
CERTIFICATES, SERIF
PO Box 293150
Lewisville, TX 75029
,r
kTIONAL ASSOCIATION AS
:R TO LASALLE BANK
ON, AS TRUSTEE FOR
S OF BEAR STEARNS ASSET
LLC ASSET BACKED
2005-AQI
vs.
MICHAEL D. BLUMEIHAL
Mortgagor and Record Owner
315 South Pitt Street
Carlisle, PA 17013
Plaintiff
Term CiVi-I
No. 6q - It/10
CIVIL ACTION: MORTGAGE
PORFCI
Defendant
You have been
you must take action wit
appearance personally of
claims set forth against y
judgment may be enterer
of for any other claim or
important to you.
YOU SHOULD '
LAWYER OR CANNO'
THIS OFFICE CAN PRI
IF YOU CANNC
YOU WITH INFORMA'
PERSONS AT A REDU
NOTICE
ed in court. If you wish to defend against the claims set forth in the following pages,
iin twenty (20) days after the Complaint and notice are served, by entering a written
by attorney and filing in writing with the court your defenses or objections to the
3u. You are warned that if you fail to do so the case may proceed without you and a
against you by the Court without further notice for any money claim in the Complaint
relief requested by the Plaintiff. You may lose money or property or other rights
AKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
)VIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
t AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE
'ION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
;ED 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
AVISO
LE HAN DEMANOADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS
QUEJAS PERESENTAD S, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO
DE 20 DIAS DESPUES E SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES
NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
VUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA
DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL
PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A
FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES
DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER
DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES.
USTED DEBE ILLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN
ABOGADO, VAYA LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA
PUEDE PROVEERE ON INFORMACION DE COMO CONSEUIR UN ABOGADO.
SI USTED O PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE
INFORMACION A ERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS
ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though yo lender (and our client) has filed an Action of Mortgage Foreclosure against you, you
still may be able to SAVE YOUR HOME FROM FORECLOSURE.
1). Call an altorn?, y. For referrals to a qualified attorne call either of the follow
243-9400. y mg numbers: or 717-
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling.
3). Visit HUD' S ebsite 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 org/consumers/homeowners/real asnx.
5). Call the Plain iff(your lender) at 877-362-6631 and ask to speak to someone about Loss Mitigation
or Home Retention optio is.
6). Foreclosure R source Center: httn://www philadelphiafed org/foreclosure/
7). Call or contac 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 oldb cklaw.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 215-82176311 or Fax: 215-825-6411. Please reference our Attorney File Number of 78597FC.
Para informacion espanol puede communicarse con Loretta al 215-825-6344.
This Action of Mortgage Foreclosure will continue unless you take action to stop it.
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is BANK OF AMERICA, NATIONAL ASSOCIATION AS SUCCESSOR BY MERGER TO
LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATE HOLDERS OF
BEAR STEARNS ASSET BACKED SECURITIES I LLC ASSET BACKED CERTIFICATES,
SERIES 2005-AQ1, PO Box 293150, Lewisville, TX 75029.
2. The names and' ddresses of the Defendant is MICHAEL D. BLUMENTHAL, 315 South Pitt Street,
Carlisle, PA 17;13, who is the mortgagor and record owner of the mortgaged premises hereinafter
described.
3. On January 12,
described to AR
the Recorder of
assigned to: LA
HOLDERS OF
CERTIFICATE'
2246. The Mort
reference in accc
Plaintiff from its
record.
4. The Property
"A" ("Prover
vwi mortgagors made, executed and delivered a mortgage upon the Property hereinafter
SENT MORTGAGE COMPANY, LLC, which mortgage is recorded in the Office of
)eeds of Cumberland County as Book 1895 Page 2322. The mortgage has been
3ALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATE
1EAR STEARNS ASSET BACKED SECURITIES I LLC ASSET BACKED
SERIES 2005-AQ1 by assignment of Mortgage January 11, 2007 as Book 0733, Page
;age and assignment(s) are matters of public record and are incorporated by this
rdance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the
obligation to attach documents to pleadings if those documents are matters of public
ect to the Mortgage is more fully described in the legal description set forth as Exhibit
5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid
for October 01, 008 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 ................................ .$121,565.36
.................................................
Interest from 9/01/2008 through 02/28/2009 at 8.1000% .......................$4,881.56
Per Diem interest rate at $26.97
Reasonable Attorney's Fee at 5% of Principal Balance
as more filly explained in the next numbered paragraph ...................$6,078.27
Late Charges from 10/01/2008 to 02/28/2009 .............................................$279.54
Monthly late charge amount at $55.91
Costs of suit and Title Search ......................................................................$900.00
Suspense.....- ............................................................................................. ($273.46)
Escrow .......................................................................................................... $644.06
Monthly scrow amount $206.91
$134,075.33
7. If the Mortgage is reinstated prior to a Sheriffs 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 Zion.
e complexity of the action requires additional fees in excess of the amount
demanded in the
8. Plaintiff is not seeking a judgment of personal liability (or an "judgment) against the
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 lajw.
9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has
been sent to De endant 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 Exhibit "B". The Defendant have not had the required face-to-face meeting within
the required ti and Plaintiff has no knowledge of any such meeting being requested by the Defendant
through the Plai tiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit
Counseling Ag cy.
WHEREFORE, Plaintiff demands a de terris judgment' in mortgage foreclosure in the sum of $134,075.33,
together with interest at the rate of $26.97, 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.
j By:
GOL ECK McC FFERTY & MCKEEVER
BY: MICHAEL T. M EVER, ESQUIRE
ATTORNEY FOR PLAINTIFF
VERIFICATION
Michajel T. McKeever, Esquire, hereby states that he is
attorney for PLAINTIFF in this matter, that Plaintiff is outside
the jurisdiction of the Court and/or the Verification c de
obtained w?.thin the time allowed for the filing of could not be
g f the pleading
that he is authorized to make this verification
Pa.R.C.P 104(c) pursuant to
and that the statements made in the foregoing
pleading in the Civil Action in Mortgage Foreclosure
are based
upon the ?nformation supplied by Plaintiff and are true and
correct to the best of his knowledge, information and belief.
Furthermore it is the undersigned's intention to substitute a
I
verification- from Plaintiff as soon as it is received
by counsel.
subject to the penalties of 18 Pa.C.S. Sec.
unsworn falsification to authorities.
Date:
The undersigned understands that this statement is made
4904 relating to
michael T. McKeever, Esquire
PA I.D. #56129
E..x..hibitA
Stewart Titre
Commitment Number: 2004120033AM*
SCHEDULE C
PROPERTY DESCRIPTION
The land referred to In this Commitment is described as follows-
ALL I hot certain tract of land together with the Improvements theraon ereOK located In the Third Ward of the
Oh of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows:
BEGI NING at a point on South Pitt S119K at the South-western comer of lot now or formerly of.lrs E. Zeigler,
them I In an Easterly direction along said lot now or tormady of Ira E Zeigler, 110 jest, rrars or sm. to a 9 foot
e11y: thence In a Southerly direction along the said 9 foot Miley, 30 feel b a pair* therhoe in a Was" direction
a tend formerly of W MW Stuart and Jacob H. Foramen, now or fohmhedy of J. Hervey HaM, 110 bat, more
or IeSP, to South Pitt Street, thence in a Northerhr d1tec0on along sold South Pitt Street, to a point, the Pecs of
BEGINNING-
CONTAINING 30 feet in front on South Pit Street, and extending back an even width 110 feet, more or less, to a
9 foot allev.
G thereon erected a 2-112 story brick dwelling house known as 315 South Pitt Street, Certisis,
ylvanis 17013.
i Lot No. 1.
* 0421-0320-M
ALTA Cei
SdWKMO
(MI120033AALPI'D2 11Z0033AM)
B( i 895PG2338
?hifiit (B
EMC Mortgage Corporation
PO Box 293150
Lewisville, TX 75029-3150
7104 5400 2100 1868 9240
October 30, 2008
11PPPPP2=4 31"o 1
Michael D Blumenthal
315 S Pitt St
Carlisle, PA 17013-3817
EMC Re: Loan No: 0010192680
Mortgage Property Address: 315 S Pitt St
Corporation Carlisle, PA 17013-3817
9 N I
T 04 A UR
E PR p RE
This is an official notice th at the mortgage on your home is in default, and the lender intends to foreclose. Specific information about
the nature of the default is rovided in the attached pages.
IMPORTANT INFO ATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE FOUR
The Homeowners' Emerge icy Mortgage Assistance Program (HEMAP) may be able to help to save your home. This notice explains
how the program works.
OF THE DATE OF THIS NOTICE. Take this Notice with you when + you mleet with the counseling agency. WITHIN 30 DAYS
The name address and one number of Consumer Credit Counseling Agencies serving our county are listed at the end of this
Notice. If you have an u stions you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (persons with
impaired hearing can call 7 17-780-1869).
This Notice contains impo ant legal information. If you have any questions, representatives at the Consumer Credit Counseling
Agency may be able to hel 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 Notificaion en adjunto s de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el
contenido de esta notificion obtenga una traduccion immediatamente llamando esta agencia (Pennsylvania Housing Finance Agency)
sin cargos al numero menci nado arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowners' Emergency
Mortgage Assistance Program" al cual puede salvar su casa de la perdida del derecho a redimir su hipoteca.
HOMEOWNER'S NAME(S): Michael D Blumenthal
PROPERTY ADDRESS: 315 S Pitt St
Carlisle, PA 17013-3817
LOAN CCOUNT NUMBER: 0010192680
CURRE?I IT SERVICER EMC Mortgage Corporation
Page two
0010192680
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
------ ---- ?-•- ...._ ._.,..,? 11?,,, lvlcciusure ana net ou make future mort a e
payments if you comply ith the provision of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may
be eligible for emergency mortgage assistance:
If your default has been mused 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 F FORECLOSURE - Under the Act, you are entitled to a temporary stay of the 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 cred t counseling agencies listed at the end of this Notice. This meeting must occur within the neat thirty (30)
days. IF YOU DO NO APPLY FOR FMFRr pmrv AAnn-rr_Ar1II A0010 1-
T"
??./i.Ull l?llrA %,n-ai.n i UUNJCLINU 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 umbers of designated consumer credit counseling agencies for the coup in which our property is located
are set forth at the end o this Notice. It is only necessary to schedule one face-to-face meeting. Advise this lender immediately of
your intentions.
?= 1 L1VA 11V1V rVK M Ki CJAtit ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see
following pages for speci is information about the nature of your default). If you have tried and are unable to resolve this problem
with the lender, you have he right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Program.
To do so, you must fill o it, sign and file a completed Homeowners' Emergency Assistance Program Application with one of the
designated consumer cre it counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have
applications for the prog am 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 YOU APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE
OTHER TIME PERIO S SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME
IMMEDIATELY AND OUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
AGENCY ACTION - Av ilable funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency
under the eligibilityty criteri established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision
after it receives your appli ation. During that time, no foreclosure proceedings will be pursued against you if you have met the time
requirements set forth ab ve. 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 F THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE
CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for
Emergency Mortgage Assistance)
NATURE OF THE DEFA LT - The MORTGAGE debt held by the above lender on your property located at 315 S Pitt St Carlisle,
PA 17013-3817 IS SERIO SLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now
past due:
(a) Monthly payments from 08/01/2008:
(b) Late charge( : $3,416.34
$0.00
(c) Other charge s): NSF and Advances $7.95
(d) Less: Credit Balance
(e) Total amount required as of 10/29/2008: $70.19
$3,354.10
YOU HAVE FAILED TO AKE THE FOLLOWING ACTION (if applicable):
nu w V V UKt I HE DE AULT - You may cure this default within THIRTY (30) DAYS from the date of this Notice BY
PAYING THE TOTAL A OUNT PAST DUE TO LENDER, WHICH IS $3,354.10, PLUS ANY MORTGAGE PAYMENTS
AND LATE CHARGES (a d other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must
be made either by cash, ca hier's check, certified check, or money order made payable to EMC Mortgage Corporation at Po Box
660753 Dallas, TX 75266-(753.
Page three
0010192680
Al L V0 uU A U I UUK?, IHE-DEFAULT - If you do not cure the default within THIRTY (30) DAYS of date of this Notice, the
lender intends to exerci a its right to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will
be considered due imme iately'and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total
amount past due is not ade within THIRTY (30) DAYS, EMC Mortgage Corporation also intends to instruct their attorneys to start
a legal action to foreclos upon your mortgaged property
IF THE MORTGAGE I FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt.
If the lender refers your ase to its attorneys, but you cure the delinquency before they begin legal proceedings against you, you will
still be required to pay a 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 are over $50.00.
Any attorney's fees will added to the amount you owe the lender, which may also include other reasonable costs. If you cure the
default within the THI TV (30) DAY period, you will not be required to pay attorneys' fees.
V nnK LtNVtK KEM 'DIES - The lender may also sue you personally for the unpaid principal balance, and all other sums due
under the mortgage.
V v V 1W L 11L;. 1-Ft%UL I rKIUK 1 U JHEKIFF'S SALE - If you have not cured the default within the THIRTY (30) day
period and foreclosure pr ceedings 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 ale. You may do so by paying the total amount then past due plus any late or other charges, charges then
due, reasonable attorneys' fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as
specified in writing byte lender and by performing any other requirements under the mortgage. Curing your default in the
manner set forth in thi notice will restore your mortgage to the same position as if you had never defaulted.
EARLIEST POSSIBLE HERIFF'S SALE DATE - It is estimated that the earliest date that such Sheriffs Sale of the mortgaged
proprty could be held would be approximately five (5) months from the date of this Notice. A notice of the actual date of the
Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait.
You may find out at any time exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER
Name of Lender: EMC Mortgage Corporation
Addre Po Box 660753 Dallas, TX 75266-0753
Teleph ne Number: 1-800-723-3004
nrrm-i ur SHERIFF'S ALE - 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 furniture and
other belongings could be tarted by the lender at any time.
ASSUMPTION OF MORTGAGE - You may not sell or transfer your home to a buyer or transferee who will assume the mortgage
debt, provided that all the utstanding payments, charges and attorneys' fees and costs are paid prior to or at the sale and that the other
requirements of the mortga a are satisfied.
YOU MAY ALSO HAVI
-- To sell the property
off this debt.
-- To have this default
-- To have the mortgal
your default more tt
-- To assert the none)
documents.
-- To assert any other c
-- To seek protection u
THE RIGHT
obtain money to pay off the mortgage debt, or to borrow money from another lending institution to pay
by any third party acting on your behalf.
restored to the same position as if no default had occurred. (However, you do not have this right to cure
i three times in any calendar year).
tence of a default in any foreclosure proceeding or any other lawsuit instituted under the mortgage
you believe you may have to such action by the lender.
the federal bankruptcy law.
Page four
001019268C
EMC Mortgage Corporation is attempting to collect a debt, and any information obtained will be used for that purpose.
Federal law gives you t irty days after you receive this letter to dispute the validity of this debt or any part of it. Unless you
dispute the debt within that 30 day period, we will assume that it is valid. If you notify us in writing at the address below or
verbally within the thi day period that the debt, or any portion thereof, is disputed, we will:
1) Provide to you v rification of the debt or a copy of any judgment entered against you.
2) Provide to you a name and address of your original creditor, if the original creditor is different from the current
creditor.
Sincerely,
EMC Mortgage
Mortgage Corporation Po Box 660753 Dallas, TX 75266-0753, 1-800-723-3004
Appendix B
Consumer Credit Counseling Agency
Notification To:
Name of mortgagee:
i
Address:
In accordance with the P nslyvania Homeowner's Emergency Mortgage Assistance Program (Act 91 of 1983)
we have been
approached for mortgage ,
counseling assistance by:
Name of Applicant
Address
Telephone Number
Mortgage Loan Number
Address of property on which mortgage is in default,
If different from above.
The counseling agency et with the above named applicant on
Date
Who have indicated that
foreclosure from: they are more than sixty (60) days delinquent on their mortgage payments and have received notification to
Name and Address of Mortgage
In accordan a with the Homeowner's Emergency Mortgage Assistance Program, this is to inform you that:
1. If the delinquen
listed above m cy cannot be resolved with in the 30 day forbearance period as provided by the Servicer, the applicant
apply to the Pennsylvania Housin
Finance A
f
H
'
g
gency
or
omeowner
s Emergency Mortgage Assistance.
2. By a copy of thi s Notice, we are notifying all other mortgagees, if any, which the applicant has indicated as also havin
mortgage on th g a
property identified above.
3. It is our underst ding that the 30 day forbearance period in which we are now in ends on
4. No legal action
met by the hom ?o enforce the mortgage may occur during this forbearance period, unless procedural time limits were not
owner.
* Indicates Counties Serviced
Acorn Housing Corporation
846 North Broad Street Americon Financial Counseling Services Bucks County Housing Group
Philadelphia, PA 19130 1 Abington Plaza, Suite 403
Old York Road and Township Line 470 Old Dublin Pike
Doylestown
PA 18901
(215) 765-1221
*Bucks, Chester, Delaware, !
Montgomery,
Jenkintown, PA 19046
(800) 490-3039 ,
(866) 866-0280
*
Philadelphia
'Delaware, Montgomery Bucks
Action Housing Inc
American Financial Counseling Services Bucks County Housing Group
515 West End Blvd
425 6th Avenue, Suite 950
Pittsburgh
PA 15219 175 Strafford Avenue, Suite One Quakertown, PA 18951
,
(412) 281-2102 Wayne, PA 19087
800) 490-3039
?-0280
*
'
*Allegheny, Beaver, Butler, F ayette, Greene, *Bucks, Chester, Delaware, Mongomery Bucks
Bucks
Washington, Westmoreland ,
Philadelphia Budget Counseling Center
Adams County Interfaith Hou sing Authority American Financial Counseling Services 247 North Fifth
9601 Street
Reading
40 E High Street
Gettysburg
PA 17325
906 Penn Avenue ,
(610) 375-7866
,
(717) 334-1518 Wyomissing, PA 19610
(610) 780-0680 *Berks, Chester, Schuylkill
*Adams, Cumberland, Franld n, York *Becks Carroll Park Community Council, Inc.
Advocates for Financial Inde ndence American Red Cross - Hanover Chapter
5218 Maste Street
P
hiladelph ar PA 19131
1806 S Broad Street, Suite 11
Philadelphia
PA 19145 3 529 Carlisle Street (215) 877-1157
,
(215) 389-2810 Hanover, PA 17331
(717) 637-3768 *Chester, Delaware, Philadelphia
*Philadelphia 'Adams, Franklin, York CCCS of Delaware Valley
Allegheny County Acorn
American Red Cross of Chester 1230 New Rodgers Road, Suite F1
Bristol
PA 19007
5907 Penn Avenue, Suite 30
Pittsburgh
PA 15206 1729 Edgemont Avenue ,
(215) 563-5665
,
(412) 441-6551 Chester, PA 19013
(610) PA 84
'Bucks
'Allegheny *Chester, Delaware CCCS of Delaware Valley
American Credit Counseling I stitute APM 1515 Market Street, Suite 1325
21 S Church Street
2147 Norht Sixth Street Philadelphia, PA 19107
(215) 563-5665
West Chester, PA 19380
(888) 212-6741 Philadelphia, PA 19122
'Bucks, Delaware, Montgomery, Philadelphia
*Chester (215) 235-6788
*
Chester, Delaware, Philadelphia CCCS of Delaware Valley
American Credit Counseling I stitute Armstrong CO Community Action Agency
1777 Sentry P
A 19422y W, Suite 200
B
lue Bell
300 North Pottstown Pike, Su'
Exton
PA 19341 a 210 124 Armsdale Road, Suite 211 ,
(215) 563-5665
,
(888) 212-6741 Kittanning, PA 16201
(724) 548-3405 'Montgomery
*Berks, Bucks, Montgomery *Armstrong CCCS of Delaware Valley
American Credit Couselin In
9 'lute
Blair County Community Action Agency 280 North Providence Road
Media
PA 19063
528 Dekalb Street
Norristown
PA 19401 2100 6th Avenue, Suite 102 ,
(215) 563-5665
,
(610) 971-2210 P.O. Box 1833
Altoona, PA 16602
'Delaware
*Montgomery (814) 946-3651 CCCS of Delaware Valley
American Credit Counseling In titute 'Blairl Marshal Building
530 W Street Road, Suite 201
Warminster
PA 18974
Booker T. Washington Center 790 E Market St, Suite 170
West Chester, PA 19382
,
(215) 444-9429 1720 Holland Street
Erie
PA 16503
(215) 5 *
*Bucks, Montgomery, Philadelp
hia. ,
(814) 453-5744 Chester, DelaDelia
ware
American Credit Counseling Ins titute 'Crawford, Erie, Warren CCCS of Delaware Valley
845 Coates Street
Bucks County Housing Group Catholic Social Services Building
7340 Jackson Stre
t
Coatesville, PA 19320
(888) 212-6741 200 West Bridge Street e
Philadelphia, PA 19136
'Bucks, Chester, Montgomery, hiladel hia Morrisville, PA 19067
(866) 866-0280 (215) 563-5665
'Bucks Bucks, Phila4
delphia
American Credit Counseling In titute
937 North Hanover Street
Pottstown
PA 19460
Bucks County Housing Group CCCS Delaware Valley
One Cherry Hill, Suite 215
,
(888) 212-0741 2324 Second Street Pike, Suite 17 Cherry Hill, PA 08002
*Berks, Bucks, Montgomery Wrightstown, PA 18940
(866) 866-0280 (215) 563-5665
'
*Bucks Philadelphia
Bucks County Housing Group CCCS of Lehigh Valley
3671 Crescent Court East
349 Durham Road Whitehall, PA 18052
Penndel, PA 19047 (610) 821-4011
(866) 866-0280
* 'Becks, Bucks, Carbon, Lancaster, Lehigh
I
Bucks ,
Northhampton, Schuylkill
* Indicates Counties Serviced
CCCS of Northeastern PA
1400 Abington Exec. Park, Suite 1
Clarks Summitt, PA 18411
(570) 587-9163
*Carbon, Columbia, Lackaw nna Lycoming,
Monroe, Montour, Northum rland, Pike,
Sullivan, Tioga, Union, Way , Wyoming
CCCS of Northeastern PA
201 Basin Street, Suite 6
Williamsport, PA 17701
(570) 323-0627
*Centre, Clinton, Lycoming,
Union
CCCS of Northeastern PA
202 W Hamilton Avenue
State College, PA 16801
(814) 238-3668
*Blair, Centre, Clearfield, C
Juniata, Mifflin
CCCS of Northeastern PA
401 Laurel Street
Pittston, PA 18640
(570) 602-2227
*Bradford, Carbon, Columbia
Lycoming, Monroe, Montour,
Pike, Sullivan, Tioga, Union,
CCCS of Northeastern PA
411 Main Street, Suite 104
Stroudsburg, PA 18360
(570) 420-8980
*Bradford, Carbon, Monroe, F
CCCS of Western PA
1 North Gate Square #2
Garden Center Dr
Greensburg, PA 15601
(888) 511-2227
*Fayette, Greene, Indiana, Sc
Washington, Westmoreland
CCCS of Western PA
2000 Linglestown Road
Harrisburg, PA 17102
(888) 511-2227
*Adams, Cumberland, E
Synder, York
CCCS of Western PA
219-A College Park Plaza
Johnstown, PA 15904
(888) 511-2227
*Cambria, Clearfield, Indiana,
CCCS of Western PA
312 Chestnut Street, Suite 227
Meadville, PA 16335
(888) 511-2227
*Lawrence
CCCS of Western PA
41 East Chestnut Street
Washington, PA 15301
(888) 511-2227
*Washington
CCCS of Western PA
4402 Peach Street
Erie, PA 16509
(888) 511-2227
*Crawford, Erie, Warren
CCCS of Western PA
524 Franklin Avenue
Aliquippa, PA 15001
(888) 511-2227
*Cameron
CCCS of Western PA
917 A Logan Boulevard
Altoona; PA 16602
(888) 511-2227
*Armstrong, Bedford, Blair, Cambria, Centre,
Clearfield, Huntingdon, Juniata, Mifflin, Union
CCCS of Western PA
971 Third Street
Beaver, PA 15009
(888) 511-2227
*Beaver
Ion, Huntingdon, CCCS of Western PA
Colonial Shopping Center
970 S George Street
York, PA 17403
(888) 511-2227
*Franklin, Fulton, Lancaster, York
Lackawanna, CCCS of Western PA
Jorthumberland, Pullman Commerce Center
Jayne, Wyoming 112 Hollywood Dr
Butler, PA 16001
(888) 511-2227
*Butler, Clarion, Jefferson, Mercer, Venango
CCCS of Western PA
ke, Wayne River Park Commons
2403 Sidney Street
Pittsburgh, PA 15203
(888) 511-2227
*Allegheny
Chester Community Improvement Project
erset, 412 Avenue of the States
P.O. Box 541
Chester, PA 19016
(610) 876-8663
*Chester, Delaware, Montgomery, Philadelphia
Comm. On Econ Opportunity of Luzeme Co.
Franklin, Perry, 163 Amber Lane
Wilkes-Bane, PA 18702
(570) 826-0510
*Carbon, Luzeme, Schuylkill, Wyoming
Community Action Commission of Capital
merset Region
1514 Derry Street
Harrisburg, PA 17094
*Cumberland, Dauphin, Franklin, Perry, Synder
Community Action Committee of the Lehigh
Valley
1337 East Fifth Street
Bethlehem, PA 18015
(610) 691-5620
*Berks, Carbon, Lehigh, Monroe, Northhampton
Community Action Development Comm -
CADCOM
113 E Main Street
Norristown, PA 19401
(610) 277-6363
*Montgomery
Community Action Southwest
150 W Beau Street, Suite 304
Washington, PA 15301
(724) 225-9550
*Washington
Community Action Southwest
58 E Greene Street
Waynesburg, PA 15370
(724) 852-2893
*Allegheny, Fayette, Greene, Washington,
Westmoreland
Congreso
216 West Somerset Street
Philadelphia, PA 19133
(215) 763-8870
*Philadelphia
Council of Spanish Speaking Organization
705-09 North Franklin St
Philadelphia, PA 19123
(215) 627-3100
*Philadelphia
Diversified Community Service
Dixon House
1920 South 20th Street
Philadelphia, PA 19145
(215) 336-3511
*Bucks, Chester, Delaware, Philadelphia
Fair Housing Partnership of Greater Pittsburgh,
Inc.
2840 Liberity Ave., Suite 205
Pittsburgh, PA 15222
(412) 391-2535
*Allegheny
Fayette Co. Community Action Agency Inc
137 North Beeson Avenue
Uniontown, PA 15401
(724) 437-6050
*Fayette, Somerset
FOB CDC
1201 West Only Avenue
Philadelphia, PA 19141
(215) 549-8755
*Bucks, Chester, Delaware, Philadelphia
Frankford CDC
4625 Frankford Avenue, 2nd Floor
Philadelphia, PA 19124
(215) 743-9201
*Philadelphia
Garfield Jubilee Associates
5138 Penn Avenue
Pittsburgh, PA 15224
(412) 665-5200
*Allegheny
Germandtown Settlement
5538 Wayne Avenue Bldg C
Philadelphia, PA 19144
(215) 849-3104
*Bucks, Chester, Delaware, Montgomery,
Philadelphia
Greater Erie Commun. Action Committee
18 West 9th Street
Erie, PA 16501
(814) 459-4581
*Crawford, Erie, Venango, V arren
HACE
167 W Allegheny Ave., 2nd Floor
Philadelphia, PA 19140
(215) 426-8025
*Bucks, Chester, Delaware, ila
Housing Alliance of York
35 South Duke Street
York, PA 17401
(717) 854-1541
*York
Housing Assoc. of Delaware
1500 Walnut Street, Suite 60
Philadelphia, PA 19102
(215) 545-6010
*Philadelphia
Housing Assoc. of Delawre
658 North Watts Street
Philadelphia, PA 19123
(215) 978-0224
*Philadelphia
Housing Opportunities of B,
320 College Avenue, Unit 1
Beaver, PA 15009
(724) 728-7511
'Beaver, Lawrence
Housing Partnership of Che
41 West Lancaster Avenue
Downingtown, PA 19335
(610) 518-1522
'Chester, Delaware, Montp
Huntingdon County Housing
Weatherization, Inc.
917 Mifflin Street
Huntingdon, PA 16652
(814) 643-2342
*Bedford, Blair, Fulton, Hunfi
Mifflin, Perry
Indiana Co. Community Action Prog.
827 Water Street Box 187
Indiana, PA 15701
(724) 465-2657 I
*Armstrong, Cambria, CleafielQl, Indiana,
Jefferson, Westmoreland
Intercultural Family Services In .
4225 Chestnut Street
Philadelphia, PA 19104
(215) 386-1298
*Philadelphia
Keystone Economic Develop. C rp.
1954 Mary Grace Lane
Johnstown, PA 15901
(814) 535-6556 I
*Bedford, Blair, Cambria, Clearf(eId, Indiana,
Somerset, Westmoreland
* Indicates Counties Serviced
Co.
Koren Comm. Develop. Services Center
6055 Norht 5th Street
Philadelphia, PA 19120
(215)276-8830
*Philadelphia
Lawrence County Social Services, Inc.
241 West Grant Street
P.O. Box 189
New Castle, PA 16103
(724) 658-7258
*Lawrence
Liberty Resources
714 Market Street, Suite 100
Philadelphia, PA 19106
(215) 634-2000
*Philadelphia
Loveship, Inc.
2320 North 5th Street
Harrisburg, PA 1711
(717) 232-2207
*Cumberland, Dauphin, Perry
Lycom-Clntn Co Comm fo Comm Action
2138 Lincoln Street
P.O. Box 3568
Williamsport, PA 17703
(570) 326-0587
*Centre, Clinton, Lycoming, Union
New Life Comm. Housing Devel Corp.
712 Hawkins Avenue
Braddock, PA 15104
(412) 351-4077
*Allegheny, Washington, Westmoreland
Northern Tier Community Action Corp.
135 West 4th Street
P.O. Box 389
Emporium, PA 15834
(814) 4861161
*Cameron, Elk, Mckean, Potter
Northwest Counseling Service
5001 North Broad Street
Philadelphia, PA 19141
(215) 324-7500
*Bucks, Chester, Delaware, Montgomery,
Philadelphia
Nueva Esperanza
4261 North 5th Street
Philadelphia, PA 19140
(215) 324-0746
*Philadelphia
Pennsylvania Housing Finance Agency
2275 Swallow Hill Rd., Bldg 200
Pittsburgh, PA 15220
(412) 429-2842
*Allegheny
Maranatha PHFA
43 Philadelphia Avenue 211 North Front Street
Waynesboro, PA 17268 Harrisburg, PA 17110
County (717) 762-3285 (800-) 342-2397
*Adams, Cumberland, Franklin, Fulton, Perry 'Cumberland, Dauphin
Media Fellowship House
302 South Jackson Street
Media, PA 19063
(610) 565-0434
n9 *Chester, Delaware
Mon Valley Unemployment Committee
1800 West St., 3rd Floor
Homestead, PA 15120
Juniata, (412) 462-9962
*Allegheny; Washington, Westmoreland
Mt. Airy, USA
6703 Germantown Ave., Suite 200
Philadelphia, PA 19119
(215) 844-6021
*Philadelphia
Nazareth Housing Services
285 Bellevue Road
Pittsburgh, PA 15229
(412) 931-3510
*Allegheny
Neighborhood Housing Services Inc.
213 N 5th St., Suite 1030
Reading, PA 19601
(610) 372-8433
*Barks
Neighborhood Housing Services
710 5th Avenue, Suite 1000
Pittsburgh, PA 15219
(412) 281-9773
*Allegheny
Philadelphia Council for Comm. Advmnt.
100 N 17th St, Suite 600
Philadelphia, PA 19103
(215) 567-7803
*Chester, Delaware, Montgomery, Philadelphia
Philadelphia Senior Center
509 South Broad Street
Philadelphia, PA 19147
(215) 546-5879
*Philadelphia
Schuylkill Community Action
225 N. Centre Street
Pottsville, PA 17901
(570) 622-1995
Barks, Carbon, Lebanon, Lehigh, Luzeme,
Northumberland, Schuylkill
Shenango Valley Urban League, Inc.
601 Indiana Avenue
Farrell, PA 16121
(724) 981-5310
*Crawford, Lawrence, Mercer
South Philadelphia H.O.M.E.S.
1444 Point Breeze Avenue
Philadelphia, PA 19146
(215) 334-4430
*Philadelphia
Southwest Community Development Corp.
6368 Paschall Avenue
Philadelphia, PA 19142
(215) 729-0800
*Philadelphia
St. Martin Center
1701 Parade Street
Erie, PA 16503
(814) 452-6113
*Crawford, Erie, Venango, V arren
Tableland Services Inc.
535 East Main Street
Somerset, PA 15501
(814) 445-9628
*Cambria, Fayette, Somers, Wes
Tabor Community Services
308 E King Street, Suite 1
Lancaster, PA 17602
(717) 397-5182
*Chester, Lancaster, Lebanon
The NORCAM Group
4200 Crawford Avenue, Suit 200
Northern Cambria, PA 1571
(814) 948-4444
*Cambria, Clearfield
The Trehab Center of Northe stem
10 Public Avenue
P.O. Box 366
Montrose, PA 18801
(570) 278-3338
*Susquehanna
" Indicates Counties Serviced
The Trehab Center of Northeastern PA
115 SR 92S
Tuckhannock, PA 18657
(570) 836-6840
*Wyoming
The Trehab Center of of Northeastern PA
1225 Main Street
Honesdale, PA 18431
(570) 253-8941
tmoreland *Bradford, Sullivan, Susquehanna, Tioga,
Wayne, Wyoming
The Trehab Center of Northeastern PA
144 E East Avenue
Wellsboro, PA 16901
(570) 724-5252
*Tioga
The Trehab Center of Northeastern PA
German Street
P.O. Box 389
Dushore, PA 18614
(570) 928-9667
PA *Sullivan
The Trehab Center of Northeastern PA
The Enterprise Center
703 S. Elmer Ave., Suite M-6
Sayre, PA 18840
(570) 888-0412
*Bradford
United Communties Southeast Philadelphia
2029 South 8th Street
Philadelphia, PA 19148
(215) 467-8700
*Philadelphia
Urban League of Philadelphia
1818 Market Street
Philadelphia, PA 19103
(215) 561-6070
*Bucks, Delaware, Philadelphia
Urban League of Pittsburgh
Building for Equal Opportunity
One Smithfield St.
Pttsburgh, PA 15222
(412) 227-4802
*Allegheny
Voices for Independence
3711 West 12th Street
Erie, PA 16505
(800) 838-9890
*Erie
Warren-Forest Counties Economic Opportunity
Council
1209 Pennsylvania Ave W.
P.O. Box 547
Warren, PA 16365
(814) 726-2400
*Forest, Waren
r ,W,
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t ?
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(I )
' GOLDBECK McCAFFERTY & McKEEVER
Professional Corporation
By: Michael T. McKeever
Attorney I.D. #56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6303
BANK OF AMERICA, NATIONAL
ASSOCIATION AS SUCCESSOR BY
MERGER TO LASALLE BANK NATIONAL
ASSOCIATION, AS TRUSTEE FOR
CERTIFICATE HOLDERS OF BEAR
STEARNS ASSET BACKED SECURITIES I
LLC ASSET BACKED CERTIFICATES,
SERIES 2005-AQ1
PO Box 293150
Lewisville, TX 75029
VS.
MICHAEL D. BLUMENTHAL
Mortgagor(s) and Record Owner(s)
315 South Pitt Street
Carlisle, PA 17013
ATTORNEY FOR PLAINTIFF
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
Term
No. 09-1410
PRAECIPE TO SUBSTITUTE VERIFICATION
TO THE PROTHONOTARY:
Kindly substitute the attached Verification to Plaintiff's Complaint filed on March 06,
2009 in the above captioned matter.
GOLDBECK McCAFFERTY & McKEEVER
BY:
Michael T. McKeever
Attorney for Plaintiff
r
GOLDBECK McCAFFERTY & McKEEVER
Professional Corporation
By: Michael T. McKeever
Attorney I.D. #56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6303
ATTORNEY FOR PLAINTIFF
BANK OF AMERICA, NATIONAL
ASSOCIATION AS SUCCESSOR BY
MERGER TO LASALLE BANK NATIONAL
ASSOCIATION, AS TRUSTEE FOR
CERTIFICATE HOLDERS OF BEAR
STEARNS ASSET BACKED SECURITIES I
LLC ASSET BACKED CERTIFICATES,
SERIES 2005-AQI
PO Box 293150
Lewisville, TX 75029
VS.
MICHAEL D. BLUMENTHAL
Mortgagor(s) and Record Owner(s)
315 South Pitt Street
Carlisle, PA 17013
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
Term
No. 09-1410
CERTIFICATION OF SERVICE
I certify that a true and correct copy of Plaintiff's Praecipe to Substitute Verification to
Plaintiffs Complaint was served on Defendant(s) via first class mail on March 12, 2009 as
follows:
MICHAEL D. BLUMENTHAL
315 South Pitt Street
Carlisle, PA 17013
GOLDBECK McCAFFERTY & McKEEVER
Michael T. McKeever
Attorney for Plaintiff
•
VERIFICATION
1,y•-*_ , as the representative of the servicing agent for the
Plaintiff corporation within named do hereby verify that I am authorized to and do make this
verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint
are true and correct to the best of my knowledge, information and belief. I understand that false
statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn
falsification to authorities.
Date:- ?(a5! ?
4TI1 A, NATIONAL
O AS SUC CESSOR BY
MERGER TO LASALLE BANK NATIONAL
ASSOCIATION, AS TRUSTEE FOR
CERTIFICATE HOLDERS OF BEAR
STEARNS ASSET BACKED SECURITIES I
LLC ASSET BACKED CERTIFICATES,
SERIES 2005-AQ1, BY EMC MORTGAGE
CORPORATION, AS ATTORNEY IN FACT
#78597FC MICHAEL D. BLUMENTHAL
315 South Pitt Street Carlisle, PA 17013
CS
a-,
"
` GJ t
:) fT
i71 -+C
Sheriffs Office of Cumberland County
R Thomas Kline ? titn of chin br ?$7 Edward L Schorpp
Sheriff Solicitor
Ronny R Anderson Jody S Smith
Chief Deputy OFF CE '-?rrrrE r-::RIFF Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
03/12/2009 09:45 AM - Timothy Black, Deputy Sheriff, who being duly swom according to law, states that on March
12, 2009 at 0945 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Michael D. Blumenthal, by making known unto Zach Blumenthal, son of defendant, at
315 South Pitt Street, Carlisle, Cumberland County, Pennsylvania its contents and at the same time
handing to him personally the said true and correct copy of the same.
SHERIFF COST: $32.50 (PAID)
March 13, 2009
S"OO ANS7,WEERRS,
R THOMAS KLINE, SHERIFF
St-re ?Tff
Docket No. 2009-1410
Bank of America NA v Michael D. Blumenthal
f CO
a h
GOLDBECK McCAFFERTY & McKEEVER
ATTORNEY FOR PLAINTIFF
BY: Michael T. McKeever
Attorney I.D. #56129
Suite 5000 -Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6321
Plaintiff
BANK OF AMERICA, NATIONAL
ASSOCIATION AS SUCCESSOR BY
MERGER TO LASALLE BANK NATIONAL
ASSOCIATION, AS TRUSTEE FOR
CERTIFICATE HOLDERS OF BEAR
STEARNS ASSET BACKED SECURITIES I
LLC ASSET BACKED CERTIFICATES,
SERIES 2005-AQ1
PO Box 293150
Lewisville, TX 75029
vs.
~' ~~ ~.~-l~~~f~~
~3~ T~~~ ~ - ~ ~~1~1~P~t1TA~~~~'
~o~aoc~ -~ ~~~ ~~ 2~
CLi~iE3~C~~~~~eCOU~dT'~
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
No. 09-1410
MICHAEL D. BLUMENTHAL
315 South Pitt Street
Carlisle, PA 17013
Defendant(s)
PRAECIPE TO DISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly mark the above case Discontinued and Ended upon payment of your costs only.
ichael T. McKeever, Esquire
Attorney for Plaintiff