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Home My WebLink About09-237024458CFC-DD Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit #7 Secane, PA 19018 (610) 328-2887 Attorney I.D. #52634 BANK OF AMERICA, NATIONAL ASSOCIATION, AS SUCCESSOR BY MERGER TO LASALLE BANK, N.A. AS TRUSTEE FOR THE MLMI TRUST SERIES 2006-HE6 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005 Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff V. NO. CQ - 02370 Givit term KETIA LEVINE 12 Kingswood Drive Mechanicsburg, PA 17055 Defendant CIVIL ACTION - MORTGAGE FORECLOSURE 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 cone. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dial de plazo at partir de la fecha de la demanda y la notification. 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 notification. 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 AGENCIAS 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 A LIEN ON REAL ESTATE. Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit #7 Secane, PA 19018 (610) 328-2887 Attorney I.D. #52634 BANK OF AMERICA, NATIONAL ASSOCIATION, AS SUCCESSOR BY MERGER TO LASALLE BANK, N.A. AS TRUSTEE FOR THE MLMI TRUST SERIES 2006-HE6 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005 KETIA LEVINE V. 12 Kingswood Drive Mechanicsburg, PA 17055 24458CFC-DD Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff NO. 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 Bank of America, National Association, as successor by merger to LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE6, 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, Ketia Levine is the mortgagor and real owner of premises 12 Kingswood Drive, Mechanicsburg, PA 17055, 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 Elecronic Registration Systems, Inc. as Nominee for The CIT Group/Consumer on July 31, 2006, which mortgage is recorded on August 23, 2006 in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1963, Page 1543 secured on premises 12 Kingswood Drive, Mechanicsburg, PA 17055 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 in conformity with the terms of the mortgage, from November, 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 $ 167,836.74 Interest from 10/1/2008 to 4/13/2009 at $45.29 per diem $ 8,831.55 Accrued late charges $ 600.00 Accrued Escrow deficit t $ 2,339.59 Corporate Advances $ 309.00 Attorney's Fee (5% of unpaid Principal balance) $ 8,391.84 Title Information Certificate $ 515.00 Total $ 188,823.72 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 Sheriffs 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 $188,823.72, plus per diem interest at $45.29 from April 14, 2009 to the date of judgment plus costs thereon. Martha E. Von kois-ff. 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 Von Rosenstiel Attorney for Plaintiff-- LEGAL DESCRIPTION ALL THAT CERTAIN tract of land located in the Borough of Mechanicsburg, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at the point of intersection of the eastern line of Kingswood Drive and the lane of adjoiner between lots Nos. 13 and 14 on the hereinafter mentioned plan of lets; thence South 61 degrees, 37 minutes East by said tine of adjoiner a distance of 123.27 feet to a point; thence South 21 degrees, 43 minutes, 40 seconds West along the western line of Lots Nos. 20 and 21 respectively on said plan, a distance of 100.24 feet to a point; thence North 44 degrees, 37 minutes, 38 seconds West along the adjoiner between Lots Nos. 12 and 13 on said plan a distance of 149.13 feet to a point on the western line of Kingswood Drive aforesaid; thence along said western line measured in a northeasterly direction on a curve to the left having a radius of 175 feet; an arc distance of 51,89 feet to a point on same; thence continuing along said western line, North 28 degrees. 23 minutes East, a distance of 4.86 feet to a point, the place of BEGINNING. BEING Lot No. 13, Block H on the final plan of Wynnewood Park, Part of Blocks B, C, D, G, H, as recorded in Plan Book 30, Page 116, HAYING therm erected a residential family dwelling house known and numbered 1.2 Kingswood Drive. BEING THE SAME PREMISES which Susanne C. Crider, by Deed of even date, produced herewith and intending to be recorded, granted and conveyed unto Ketia Uvine, a single person, Mortgagor herein. UNDER AND SUBJECT nevcrthcless, to building setback lines, conditions and restrictions as shown on said plan and of prior record. DEBIT ? Wilshire- January 29, 2009 CERTIFIED RETURN RECEIPT AND REGULAR FIRST CLASS MAIL L178G LEVINE, KETIA 12 KINGSWOOD DR MECHANICSBURG, PA 17055 RE: Loan No.: 2771828 ACT 91 NOTICE Phone 888.502.0100 Fax 503.952.7476 Website hftps://www.woc.ml.com TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE (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. L178G Wilshire Credit Corporation Payments P.O. BOX 105344; Atlanta, GA 30348-5344 or P.O. Box 7195; Pasadena, CA 91109-7195 Correspondence P.O. Box 8517; Portland, OR 97207-8517 LEVINE, KETIA Loan No.: 2771828 Page 2 January 29, 2009 LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNERS' NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: LEVINE, KETIA 12 KINGSWOOD DR MECHANICSBURG, PA 170552760 2771828 The CIT Group/Consumer Finance, Inc. Wilshire Credit Corporation PROG ORAM ER'S EMERGENCY MORTGAGE ASSISTANCE 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 (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/cade/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 L178G 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. LEVINE, KETIA Loan No.: 2771828 Page 3 January 29, 2009 • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY TAY 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 (plus three (3) days for mailing). 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 WITH TI?T TLiiDTV TIXTjWjM r ? XTn ?rm....... ?? ?? PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE You must have a face-to-face meeting with one of the designated consumer credit counseling agencies within thirty-three (33) calendar days. CONSUMER . F.DIT 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 decimated consumer credit counseling agencies for the county in which the 12rol2rM 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 ASSI T N - 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.) 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 Mortgage 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. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty(30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOONAS POS ML IF YOU HA VE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE am FILE AN APPLICATION WITHPHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILYPREVENTED FROMSTARTINGA FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARYSTAY OF FORCLOSURE ". YOU HAVE THE RIGHT TO FILE A HEMAP APPL I ATION VEN BEYOND THESE TIME PERIODS. ALA TE APPLICATION WILL NOT PREVENT THE LENDER FROMSTARTINGA FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALL YAPPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INF (Continued) ORMATION 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. L178G LEVINE, KETIA Loan No.: 2771828 Page 4 January 29, 2009 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 un to date.) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 12 KINGSWOOD DR MECHANICSBURG, PA 170552760 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Your loan is delinquent for the following months: November 2008, December 2008, January 2009 Past Due Installments: Totals Principal $228.00 Interest 4,651.44 Escrow Installment 215.73 $5,095.17 Other Open Charges: Prior Servicer Charge Late Charges $0.00 Escrow Advance Interes- 0.00 Property Inspections 0.00 Valuations 0.00 WCC Chars?es $600.00 $600.00 118.57 118.57 44.00 44.00 239.94 239.94 $1,002.51 Less Suspense (Balance) $0.00 (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/cade/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 L 178G LEVINE, KETIA Loan No.: 2771828 Page 5 January 29, 2009 TOTAL $6,097.68 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 $6,097.68, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, 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 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 groRerty, IF THE MORTGAGE IS FORECLOSED PON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $ 50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period. you will not be required to 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 LE - 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 my un to one hour before the Sheriffs Sale You may do so by paying the total amount then past due, plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender, and by performing any other requirements under the mortgage Curing your default in the manner set forth in this notice will restore your mortgage to the same position as 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 eight (8) 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 (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. L! 78G LEVINE, KETIA Loan No.: 2771828 Page 6 January 29, 2009 the required payment or action will be by contacting the lender/servicer. HOW TO CONTACT THE. LENDS / RVi R• Name of Lender/Servicer: Address: Phone Number: Fax Number: Contact Person(s): E-Mail Address: Wilshire Credit Corporation P.O. Box 8517 Portland, OR 97207-8517 888.917.1050 503.946.3848 Holli Jennings or David Solomon loanworkoutgeneral@wcc.ml.com EFFECT OF SHERIFF'S fiAi.E, - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _ may or X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO AVE 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 (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/cade/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. L178G LEWNE, KETIA Loan No.: 2771828 Page 7 January 29, 2009 BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Enclosed is a list of Consumer Credit Counseling Agencies serving your county. Sincerely, Wilshire Credit Corporation Enclosures: PHFA list of HEMAP-approved agencies,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/eadc/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. L178G u FILED-C F AP's AN 11: 4 4 "'y } *-t8,so Im Ailr1 C4c:P 34395 eTt- Sheriffs Office of Cumberland County R Thomas Kline ti%r Q1 ?aruLrrfi+ Edward L Schorpp Sheriff` Solicitor Ronny R Anderson Jody S Smith Chief Deputy" Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/17/2009 06:45 PM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Ketia Levine, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Ketia Levine. The Mechanicsburg Postmaster states the ?nQil is delivered to the address given. The neighbors state the defendant Ketia Levine has not lived at 12 Kingswood Drive Mechanicsburg, Cumberland County, Pennsylvania 17055 has not lived there since Christmas time. An exact address is not available. SHERIFF COST: $42.00 May 01, 2009 2009-2370 Bank of America NA VS Ketia Levine SO ANSWERS, R THOMAS KLINE, SHERIFF cm `=1 r^ f 33,. y T cn C ' ..: 51 <.., -t C) .C- r? #24458CPG-TM (praecipe to sub plaintiff) Martha E. Von Rosenstiel Attorney for Plaintiff/Movant 649 South Avenue Secane, PA 19018 (610) 328-2887 Attorney I.D. #52634 Bank of America, National Association, as COURT OF COMMON PLEAS successor by merger to LaSalle Bank, N.A. as CUMBERLAND COUNTY Trustee for the MLMI Trust Series 2006-HE6 Plaintiff vs. : 09-2370 Ketia Levine Defendant VOLUNTARY SUBSTITUTION OF U.S Bank National Association, as Successor Trustee to Bank of America, National Association, as successor by merger to LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE6 PURSUANT TO Pa. R.C.P. 2352(a) TO THE PROTHONOTARY: 1. U.S Bank National Association, as Successor Trustee to Bank of America, National Association, as successor by merger to LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE6 is the assignee of Bank of America, National Association, as successor by merger to Lasalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE6 and wishes to substitute itself for plaintiff. 2. The material facts on which the right of succession and substitution is based as as follows: a) Bank of America, National Association, as successor by merger to Lasalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE6, foreclosing plaintiff, assigned its right, title and interest in premises 12 Kingswood Drive, Mechanicsburg, PA 17055 to U.S Bank National Association, as Successor Trustee to Bank of America, National Association, as successor by merger to LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE6 by virtue of an assignment dated December 14, 2006 and recorded May 18, 2009. 3. U.S Bank National Association, as Successor Trustee to Bank of America, National Association, as successor by merger to LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE6 does voluntarily substitute itself as plaintiff herein. E. Von Rosenstiel v for Plaintiff Dated: May 21, 2009 4,8.oc Pn ATTf Ck-' 3m)'4(v US 10 S 235 SOUTH 13TH STREET PHILADELPHIA, PA 18107 PHONE: (215) 546-7400 =AB"&R] FAX: (215) 985-0169 Nations/ Association of Pfftda/pfNe Ass.bon Professional Process Servers of Professional Process servers Bank of America, et al COURT Court of Common Pleas of Pennsylvania -VS- ' COUNTY Cumberland County Ketia Levine CASE NUMBER 09-2370 Civil Term Luk(45f AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA: B&R Control # CS063668 -1 COUNTY OF PHILADELPHIA: Reference Number SERVICE INFORMATION On 8 day of May, 2009 we received the Mortgage Foreclosure for service upon Ketia Levine at 1003 Sun Valley Way, Apt.61 Florham Park, NJ 07932 ?r??•a• •••oYYYYV11a Q Served Date Time Accepted By: In the manner described below. ? Personally served. ? Adult family member. Relationship is ? Adult in charge of residence who refused to give name and/or relationship. ? Manager/Clerk of place of residence lodging ? Agent or person in charge of office or usual place of business ? Other Description of Person Age Height Weight Race Sex Other Not Served Date oZ oq Time 8 '(y) Not Served Information ---? ' T Moved ? Unknown ? No Answer ? Vacant Other QL? (? Le ?I Ic The Process Serve P, being duly swom, Swom to and subscribed before me this deposes and says that the facts set forth herein are true and correct to the bet their 5 knowledge, information and belief. J day of rocess Serv rISIC Notary Publi Law Firm Phone (610)328-2887 Fo Martha E. Von Rosenstiel, Esquire Martha E. Von Rosenstiel, Esquire 649 South Avenue Secane, PA 19018 NOSY PUBLIC OF NEW ERS ServeBy Date 5/30/20"y Commission Expires Ilion-1f la Filed Date 4/15/2009 ORIGINAL 128VC ?(i ? f! RL.I 2999. ca J -2 AF11 n: 11 'U" , J 235 SOUTH 13TH STREET PHILADELPHIA, PA 19107 ~ S PHONE: (215) 546-7400 ° Ror Profewfoads Iac. FAX: (215) 985-0169 National Association of Philadelphia Association Professional Process Servers of Professional Process Servers Bank of America, et al COURT Court of Common Pleas of Pennsylvania -vs- COUNTY Cumberland County /-6 Ketia Levine CASE NUMBER 09-2370 Civil Term AFFIDAVIT OF SERVICE T, COMMONWEALTH OF PENNSYLVANIA: B&R Control # CS063668 - 2 COUNTY OF PHILADELPHIA: Reference Number SERVICE INFORMATION On 8 day of May, 2009 we received the Mortgage Foreclosure Complaint for service upon Ketia Levine at 367 West 4th Ave. Roselle, NJ 07203 i *** Special Instructions *** Served Date 0 Time S: i p P(YlAccepted By: P (, a.y ?fy- In the manner described below. Personally served. Adult family member. Relationship is Adult in charge of residence who refused to give name and/or relationship. Manager/Clerk of place of residence lodging Agent or person in charge of office or usual place of business Other Description of Person Age ? Height `,V Weight k 4O Race ?l? • Sex Other 0 Not Served Date Time Not Served Information r-] Moved r--] Unknown 0 No Answer F-] Vacant F-] Other The Process Server, being duly sworn, deposes and says that the facts set forth herein are true and correct to the best of their knowledge, information and bell Sworn tlo?and subscribed before me this C?,A ' day Pr 1 a,.,, ocess Serve Serve /fP?y//" Notary Public T I _ _?? Law Firm Phone (610 328-2887 Fo Martha E. Von Rosenstiel, Esquire ServeBy Date 5/30/20 Martha E. Von Rosenstiel, Esquire Filed Date 4/15/2009 649 South Avenue Secane, PA 19018 DO?JEAN ARCIUOLOARCIU0L0 Commission Expires Expires ( la ORIGINAL 128VC -0!'i `ik t +LED OF THE PROTIHONW)TARY 2009 JUN --8 Phi 4, 19 CU{Y1 /L.F ri i O.J?JiVE PEi!! i`, r(LVAINII A #24458CFJ-DN v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. BANK NATIONAL ASSOCIATION, AS SUCCESSOR TRUSTEE TO BANK OF AMERICA, NATIONAL ASSOCIATION, AS SUCCESSOR BY MERGER TO LASALLE BANK, N.A. AS TRUSTEE FOR THE MLMI TRUST SERIES 2006-HE6 Substituted Party Plaintiff V. NO. 09-2370 KETIA LEVINE Defendant(s) PRAECIPE FOR DEFAULT JUDGMENT To the Prothonotary: (XX) Enter judgment in favor of the Substituted Party Plaintiff and against: Ketia Levine for want of an answer. (X) Assess Damages as Follows Debt Interest from 4/14/09 to 6/17/09 At $45.29 per diem Total $ 188,823.72 $ 2,943.85 $ 191,767.57 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, after the default occurred and at least (10) days prior to the date of the filing of this Praecipe. A copy of the Notice is attached. R.C.P. 237.1 Attorney for Substituted Party Plaintiff Martha E. Von Rosenstiel Attorney I.D. #52634 Print/Type Name and ID Number Phone: (610) 328-2887 This AAay of J,tkne , 2009 judgment is entered in favor of the Substituted Party Plaintiff and against Defendant(s), Ketia Levine by default for want of an answer and damages assessed at the sum of $191,767.57 as per the above certification. 1610 , Q • D r thonotary, Cumberl d County t Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 649 South Avenue Secane, PA 19018 (610) 328-2887 Attorney I.D.# 52634 BANK OF AMERICA, NATIONAL ASSOCIATION, AS SUCCESSOR BY MERGER TO LASALLE BANK, N.A. AS TRUSTEE FOR THE MLMI TRUST SERIES 2006-HE6 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005 V. KETIA LEVINE 12 Kingswood Drive Mechanicsburg, PA 17055 Plaintiff Defendant TO: Ketia Levine 12 Kingswood Drive Mechanicsburg, PA 17055 #24458CTD - DD Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Case No: 09-2370 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN 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 717-249-3166 800-990-9108 - By 5 Martha E. Von Itosenaiel, sq. Attorney for Plaintiff Dated: June 4, 2009 Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 649 South Avenue Secane, PA 19018 (610) 328-2887 Attorney I.D.# 52634 BANK OF AMERICA, NATIONAL ASSOCIATION, AS SUCCESSOR BY MERGER TO LASALLE BANK, N.A. AS TRUSTEE FOR THE MLMI TRUST SERIES 2006-HE6 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005 Plaintiff V. KETIA LEVINE 12 Kingswood Drive Mechanicsburg, PA 17055 Defendant TO: Ketia Levine 367 West 4th Ave Roselle, PA 07203 #24458CTD - DD Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Case No: 09-2370 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN .APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN 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 717-249-3166 800-990-9108 .rx ^ i t _._ Martha E. Von RosenstIel, Esq. Anomey for Plaintiff Dated: June 4, 2009 FUD- f7-- THE p!, I c: 2609 JUH 22 Pi I : 2 ., OV-* 35504 aaloo3 I?ki?. kk?Ld N + OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, 1 Courthouse Square, Carlisle, PA 17013 Curt Long, Prothonotary Ketia Levine 12 Kingswood Drive Mechanicsburg, PA17055 U.S. BANK NATIONAL ASSOCIATION, AS SUCCESSOR TRUSTEE TO BANK OF AMERICA, NATIONAL ASSOCIATION, AS SUCCESSOR BY MERGER TO LASALLE BANK, N.A. AS TRUSTEE FOR THE MLMI TRUST SERIES 2006-HE6 SUBSTITUTED PARTY PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 09-2370 VS. KETIA LEVINE DEFENDANT(S) 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 indicated below in the amount of $191,767.57 on June 17, 2009. Curt Long Prothonotary ?X Judgment by Default Money Judgment Judgment in Replevin ? Judgment for Possession F1 Judgment on Award of Arbitration ? Judgment on Court Findings r? C t JIC4 P. ay? o-KB b?a?o9 If you have any questions concerning this notice, please call: Attorney Martha E. Von Rosenstiel, Esquire at this telephone number: 610-328-2887. ak OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, 1 Courthouse Square, Carlisle, PA. 17013 Curt Long, Prothonotary Ketia Levine 367 West 4th Ave Roselle, NJ 07203 U.S. BANK NATIONAL ASSOCIATION, AS SUCCESSOR TRUSTEE TO BANK OF AMERICA, NATIONAL ASSOCIATION, AS SUCCESSOR BY MERGER TO LASALLE BANK, N.A. AS TRUSTEE FOR THE MLMI TRUST SERIES 2006-HE6 SUBSTITUTED PARTY PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 09-2370 VS. KETIA LEVINE DEFENDANT 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 indicated below in the amount of $191,767.57 on June 17, 2009. Curt Long Prothonotary 0 Judgment by Default Money Judgment ? Judgment in Replevin Judgment for Possession ? Judgment on Award of Arbitration ? Judgment on Court Findings "- P_ &,Ora 6/aa/o y If you have any questions concerning this notice, please call: Attorney Martha E. Von Rosenstiel, Esquire at this telephone number: 610-328-2887. 24458CWE-DN 10 Commonwealth of Pennsylvania COUNTY OF CUMBERLAND U.S. BANK NATIONAL ASSOCIATION, AS SUCCESSOR COURT OF COMMON PLEAS TRUSTEE TO BANK OF AMERICA, NATIONAL ASSOCIATION, AS SUCCESSOR BY MERGER TO LASALLE BANK, N.A. AS TRUSTEE FOR THE MLMI TRUST SERIES 2006-HE6 V. DOCKET NO. 09-2370 KETIA LEVINE ATTORNl3Y I.D. #52634 19, V'M - L?ood or meehanfcsburg, PA !'loss Praecipe for Writ of Execution TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: AMOUNT DUE INTEREST from 6/18/2009 to 12/9/2009 At6% TOTAL* *Plus costs to be endorsed $ 191,767.57 $ 5,516.00 $ 197,283.57 Martha E. Von Rosenstiel Attorney for Substituted Party Plaintiff 649 South Avenue„ Unit #6 Secane, PA 19018 (610) 328-2887 PREM: 12 Kingswood Drive, Mechanicsburg, PA 17055 0 a•. _P coo? a zu Q od U Q ? U Oho n M N o? 0 zz rt . - ?9 N W U GU F" v,?W C) H ?d•o ¢°om? a WF"w? D ¢Hoa? ¢wzWx ?3 a op00 00 0°`n W W a d O O W? o O ? cn c? v e? a r M 4 9? ? o 0 a 63 0- Q 0 ? o W) kn N kr)? fag 69 C) b 0 N W C, N Q ° ? ? ° o * o a cd "C o ? ? o0 o cn ooo 00 ??pddN W 0; L 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 SUCCESSOR TRUSTEE TO BANK OF AMERICA, NATIONAL ASSOCIATION, AS SUCCESSOR BY MERGER TO LASALLE BANK, N.A. AS TRUSTEE FOR THE MLMI TRUST SERIES 2006-HE6 Substituted Party Plaintiff vs. #24458CAM - DN Attorney for Substituted Party Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 09-2370 KETIA LEVINE Defendant(s) AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 MARTHA E. VON ROSENSTIEL, ESQUIRE, attorney for the Substituted Party 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 12 Kingswood Drive, Mechanicsburg, PA 17055: 1. Name and address of owners(s) or reputed owner(s) Ketia Levine 12 Kingswood Drive Mechanicsburg, PA 17055 2. Name and address of defendant(s) in the judgment: Ketia Levine 12 Kingswood Drive Mechanicsburg, PA 17055 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Borough of Mechanicsburg c/o David J. Spotts, Esquire 36 West Allen Street, Mechanicsburg, PA 17055 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: NONE 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 ,12 Kingswood Drive Mechanicsburg, PA 17055 I verify that the statements made in this affidavit are true and correct to the st of my personal knowledge or information and belief. I understand that false ss-13?e made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsificatio h ' 'es. E. Von Rosenstiel Attorney for Plaintiff Dated: June 18, 2009 Dr- Ti : r c? C? k? #24458-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 Attorney for Substituted Party Plaintiff U.S. BANK NATIONAL ASSOCIATION, AS SUCCESSOR TRUSTEE TO BANK OF AMERICA, NATIONAL ASSOCIATION, AS SUCCESSOR BY MERGER TO LASALLE BANK, N.A. AS TRUSTEE FOR THE MLMI TRUST SERIES 2006-HE6 Substituted Party Plaintiff VS. KETIA LEVINE Defendant(s) COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 09-2370 CERTIFICATE TO THE SHERIFF I hereby certify that I am the attorney of record for the Substituted Party 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 XX 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 statement given herein. Martha E. Von Rosenstiel Attorney for Substituted Party Plaintiff OF ?'- r' ,rY 2009 JIJ 2-2 P I LuPv.?-_ ?Jit' Martha E. Von Rosenstiel, P.C. Attorney for Substituted Party Plaintiff Martha E. Von Rosenstiel 649 South Avenue, Unit 6 P.O. Box 822 Secane, PA 19018 610 328-2887 Attorney I.D.# 52634 U.S. Bank National Association, as successor COURT OF COMMON PLEAS Trustee to Bank of America, National Association, : CUMBERLANDCOUNTY as successor by merger to Lasalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE6 14523 SW Millikan Way, Suite 200 Beaverton OR 97005 No: 09-2370 Substituted Party Plaintiff VS. Ketia Levine 12 Kingswood Drive Mechanicsburg, PA 17055 Defendants AFFIDAVIT OF LAST KNOWN ADDRESS COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF DELAWARE MARTHA E. VON ROSENSTIEL, attorney for the Substituted Party 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: Ketia Levine 12 Kingswood Drive Mechanicsburg, PA 17055 And Ketia Levine 367 West 4th Ave Roselle, NJ 07203 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 ties. of 18 Pa. C.S. Section 4904 relating to =Rosenstiel Attorney for Substi tuted Party Plaintiff CF RY 200'3 JU]A 22 Fill s i-I tat.,, 24458CAM-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 Attorney for Substituted Party Plaintiff U.S. BANK NATIONAL ASSOCIATION, AS SUCCESSOR TRUSTEE TO BANK OF AMERICA, NATIONAL ASSOCIATION, AS SUCCESSOR BY MERGER TO LASALLE BANK, N.A. AS TRUSTEE : FOR THE MLMI TRUST SERIES 2006-HE6 Substituted Party Plaintiff VS. KETIA LEVINE Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 09-2370 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 12 Kingswood Drive Mechanicsburg, PA 17055 will be sold by the Sheriff of Cumberland County on Date of Sale: December 09, 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. 09-2370 in the Court of Common Pleas of Cumberland County by U.S. Bank National Association, as successor Trustee to Bank of America, National Association, as successor by merger to Lasalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE6, Substituted Party Plaintiff against Ketia Levine, Defendant(s). Judgment was entered on June 17, 2009 in the amount of $191,767.57. The property was seized and taken in execution as the property of Ketia Levine. The property to be sold at Sheriff's Sale is described as follows: ALL THAT CERTAIN, tract or parcel of land and premises, situate, lying and being in the Borough of Mechanicsburg, County of Cumberland, and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at the point of intersection of the Eastern line of Kingswood Drive and the line of adjoiner between Lots Nos. 13 and 14 on the hereinafter mentioned plan of lots; thence South 61 degrees 37 minutes East by said line of adjoiner a distance of 123.27 feet to a point; thence South 21 degrees 43 minutes 40 seconds West along the Western line of Lots Nos. 20 and 21 respectively on said plan, a distance of 100.24 feet to a point; thence North 44 degrees 37 minutes 38 seconds West, along the line of adjoiner between Lots Nos. 12 and 13 on said plan a distance of 149.13 feet to a point on the Western line of Kingswood Drive aforesaid; thence along said Western line measured in a Northeasterly direction on a curve to the left having a radius of 175 feet; an arc distance of 51.89 feet to a point on same; thence continuing along said Western line, North 28 degrees 23 minutes East, a distance of 4.86 feet to a point, the place of beginning. BEING Lot No. 13, Block H on the final plan of Wynnewood Park, Part of Blocks B, C, D, G, H as recorded in Plan Book 30, Page 116. HAVING THEREON ERECTED a residential family dwelling house known and numbered as 12 Kingswood Drive. AX PARCEL NUMBER: 18-22-0519-280; CONTROL NUMBER: 18000405 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. 09-2370. 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 Substituted Party Plaintiff 649 South Avenue, Unit 46 Secane, PA 19018 Phone: (610) 328-2887 Fax: (610) 328-2875 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-2370 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due U.S. BANK NATIONAL ASSOCIATION, As Successor Trustee to BANK OF AMERICA, NATIONAL ASSOCIATION, As successor by merger to LASALLE BANK, N.A., as Trustee for THE MLMI TRUST SERIES 2006-HE6, Plaintiff (s) From KETIA LEVINE (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 $191,767.57 L.L. $.50 Interest from 6/18/09 to 12/09/09 at 6% -- $5,516.00 Atty's Comm % Due Prothy $2.00 Atty Paid $169.00 Other Costs Plaintiff Paid Date: 6/22/09 ?0. U ' Long, Prothonota ry Cl l S / B )0 V ) ( ea y: AA - 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. 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, AS SUCCESSOR TRUSTEE TO BANK OF AMERICA, NATIONAL ASSOCIATION, AS SUCCESSOR BY MERGER TO LASALLE BANK, N.A. AS TRUSTEE FOR THE MLMI TRUST SERIES 2006-HE6 Substituted Party Plaintiff VS. KETIA LEVINE Defendant(s) COURT OF COMMON PLEAS CUMBERLAND COUNTY : NO: 09-2370 i9?' AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1 MARTHA E. VON ROSENSTIEL, ESQUIRE, attorney for the Substituted Party Plaintiff in the above action, hereby verifies that on July 6, 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 falsification to authorities. Dated: June 18, 2009 #24458CAM - DN Attorney for Substituted Party Martha E. Von Rosenstiel Attorney for Substituted Party Plaintiff E -I v, 0 gi a z < c 3 mN ?D 7 -? CL m °, CD m y ?Z c 3 Q CD 0 For Accountable Mail ???? O (O Oo D) cn A W N a N CO 0 o n=i ?cD? 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