Loading...
HomeMy WebLinkAbout09-5421U? Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 ?Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 212126 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR MORGAN STANLEY IXIS REAL ESTATE CAPITAL TRUST, 2006-1 3476 STATEVIEW BLVD FORT MILL, SC 29715 Plaintiff v DANIEL L. CORRIGAN LESLIE A. CORRIGAN 623 3RD STREET NEW CUMBERLAND, PA 17070-2018 Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM PI-k-11 NO. 104- seal CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File k: 212126 NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, 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. Lawyer Referral Service: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 File #: 212126 Plaintiff is DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR MORGAN STANLEY IXIS REAL ESTATE CAPITAL TRUST, 2006-1 3476 STATEVIEW BLVD FORT MILL, SC 29715 2. The name(s) and last known address(es) of the Defendant(s) are: DANIEL L. CORRIGAN LESLIE A. CORRIGAN 623 3RD STREET NEW CUMBERLAND, PA 17070-2018 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 02/07/2006 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS A NOMINEE FOR MERITAGE MORTGAGE which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1940, Page 4212. The PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 04/01/2009 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 212126 6. 7. 8. The following amounts are due on the mortgage: Principal Balance $115,728.72 Interest $3,501.06 03/01/2009 through 07/31/2009 Attorney's Fees $1,300.00 Cumulative Late Charges $130.95 01/09/2009 to 07/31/2009 Property Inspections $33.75 Cost of Suit and Title Search $750.00 Subtotal $121,444.48 Escrow Credit $0.00 Deficit $2,315.92 Subtotal $2,315.92 TOTAL $123,760.40 If the mortgage is reinstated prior to a Sheriffs Sale, the attorney's fee 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 reserves its right to collect attorney's fees up to 5% of the remaining principal balance in the event the property is sold to a third party purchaser at Sheriffs Sale, or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. File #: 212126 9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. 10. This action does not come under Act 91 of 1983 because the mortgage premises is not the principal residence of Defendant(s). WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $123,760.40, together with interest from 07/31/2009 at the rate of $25.37 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELAN HALIANAN & SCHMIEG, LLP By: U L ren e T. Phel .0, Id. No. 32227 rancis Ha n, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 Z Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Attorneys for Plaintiff File #1: 212126 LEGAL DESCRIPTION ALL THAT CERTAIN tract or Parcel of land and premises, situate, lying and being in the Borough of New Cumberland in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the south side of Fourth Street 30 feet East from the Southeast corner of Fourth Street and Geary Avenue; thence eastwardly along said Fourth Street 30 feet to line of property now or formerly of Lake Prowell; thence Southwardly along said line of property now or formerly of Lake Prowell, 140 feet to Ruby Avenue; thence Westwardly along said Ruby Avenue 10 feet to line of property now or formerly of Delance Lenhart; thence Northwardly along said line of property now or formerly of Delance Lenhart 40 feet to a point; thence Westwardly along said property of Delance Lenhart 20 feet to line of property now or formerly of Thomas Singleton; thence Northwardly along said line of property now or formerly of Thomas Singleton, 100 feet to Fourth Street, the Place of BEGINNING. HAVING thereon erected a single two and one-half story frame dwelling house and garage, known as No. 424 Fourth Street, New Cumberland, Pa. PARCEL NO. 25-25-0006-050 PROPERTY BEING: 424 4T" STREET File #: 212126 VERIFICATION The undersigned attorney hereby states that I am the attorney for the Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of my knowledge, information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsifications to authorities. A X l??-/'? /Laa nc . Phelan, No. 3 2227 s S Hallinan, q., Id. No. 62695 l G. 5 'him , Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Attorney for Plaintiff DATE: 3f 0 File #: 212126 FI" .J i` 2vl7 r ' J ii, t 1 ?'t #- *7,c - 0 k4? Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor Deutsche Bank National Trust Co. vs. Daniel L. Corrigan yiltt, ,' Dui f; t ztG ? Case Number 2009-5421 SHERIFF'S RETURN OF SERVICE 08/11/2009 08:19 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 11, 2009 at 2019 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Daniel L. Corrigan, by making known unto Georgeann Selander, Tenant ai 424 4th Street New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to her personally the said true and correct copy of the same. 08/11/2009 08:19 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 11, 2009 at 2019 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Leslie A. Corrgian, by making known unto Georgeann Selander, Tenant at 424 4th Street New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $59.30 August 12, 2009 FILEL +'-` +CE _ 0 THE F ARY 2009 AUG 1' 7 Ali 9. ! i CU. )L SO ANSWERS, R THOMAS KLINE, SHERIFF Deputy Sher_Lf f s' Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Ju ith T. Romano, Esq., Id. No. 58745 leetal R. Shah-Jani, Esq., Id. No. 81760 Jenme R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 715-56'3-7000 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR MORGAN STANLEY IRIS REAL ESTATE CAPITAL TRUST, 2006-1 Plaintiff vs. DANIEL L. CORRIGAN LESLIE A. CORRIGAN ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION : CUMBERLAND COUNTY No. CIVIL-09-5421 Defendants TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. PHELAN HALL & SCHMIEG, LLP By: Lawrence T. Phelan, squ e Francis S. Hallinan, E ' e Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire ,,-Sne-etal R. Shah-Jani, Esquire Jenine R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Joshua I. Goldman, Esquire Courtenay R. Dunn, Esquire Andrew C. Bramblett, Esquire Attorneys for Plaintiff Date: Ai ist .4r200/jrm, Svc Dept. File# 212126 ( _> RLEL 4,-FJCE OF THE F'p 2009 AUG 25 PM 2: 16 rry 4110. W PO Arr4 Clc o 84 3804 u# aa*-7-73 Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR MORGAN STANLEY IXIS REAL ESTATE CAPITAL TRUST, 2006-1 Plaintiff VS. DANIEL L. CORRIGAN LESLIE A. CORRIGAN Defendant(s) ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION : NO. CIVIL-09-5421 : CUMBERLAND COUNTY PHS #: 212126 PRAECIPE TO SUBSTITUTE VERIFICATION TO CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly substitute the attached verification for the verification originally filed with the complaint in the instant matter. Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff By: G ? La ence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Date: 08/24/2009 PHS #: 212126 VERIFICATION Xee Moua hereby states that he/she is Vice President Loan Documentation of AMERICA'S SERVICING COMPANY, servicing agent for Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Name: Xee Moua DATE: n a/ n a/ n 4 Title: Vice President Loan Documentation Company: AMERICA'S SERVICING COMPANY File #: 212126 Corrigan Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR MORGAN STANLEY IRIS REAL ESTATE CAPITAL TRUST, 2006-1 Plaintiff VS. DANIEL L. CORRIGAN LESLIE A. CORRIGAN Defendant(s) ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION : NO. CIVIL-09-5421 : CUMBERLAND COUNTY CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of Plaintiff's Praecipe to attach Verification of Complaint was sent via first class mail to the following on the date listed below: DANIEL L. CORRIGAN 623 3RD STREET NEW CUMBERLND, PA 17070-2018 I- LESLIE A. CORRIGAN 623 3RD STREET NEW CUMBERLAND, PA 17070-2018 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff By: (G ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Date: 08/24/2009 Fit OF TNT P <MTAPY 2009 AUG 27 Ph %: 43 t( v Vu ,gS , it Sheriffs Office of Cumberland County R Thomas Kline Sheri Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant ???rxto ©t ure?t?brr??? OFFICE OF TK SHERIFF FI.0rFKC;t cry 11 !"TtM OF THE Edward L Schorpp Solicitor 2009 AUG 31 N1. 3: 3 5) 't4 N Gr ??,'I IA; Deutsche Bank National Trust Co. vs. Case Number Lesiie A. Corrigan 2009-5421 SHERIFF'S RETURN OF SERVICE 08/27/2009 04:37 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 27, 2009 at 1637 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Leslie A. Corrigan, by making known unto Daniel L. Corrigan, husband of defendant at 623 3rd Street New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to him personally the said true and correct copy of the same. 08127/2009 04:37 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 27, 2009 at 1637 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Daniel L. Corrigan, by making known unto himself personally, at 623 3rd Street New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $59.30 August 28, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF y F2tf 4. _?- Deputy Sheriff Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 C rtenay R. Dunn, Esq., Id. No. 206779 drew C. Bramblett, Esq., Id. No. 208375 16 7 JFK Boulevard, Suite 1400 Attorney for Plaintiff One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR MORGAN STANLEY IXIS REAL ESTATE CAPITAL TRUST, 2006-1 : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION VS. DANIEL L. CORRIGAN LESLIE A. CORRIGAN : No. CIVIL-09-5421 PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against DANIEL L. CORRIGAN, and LESLIE A. CORRIGAN, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $123,760.40 Interest - 08/01/2009 to 10/07/2009 TOTAL $1,725.16 $125,485.56 I hereby certify that (1) the Defendants' last known address is 623 3RD STREET, NEW CUMBERLND, PA 17070-2018, and (2) that notice has been given in accordance with Rule 237.1, copy attached. Lawrence T. Phelan, Esquire Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jenine R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Joshua I. Goldman, Esquire Courtenay R. Dunn, Esquire Andrew C. Bramblett, Esquire Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: io 8 o9 PHS # 212126 PROTHONOTARY Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenne R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST : CUMBERLAND COUNTY COMPANY, AS TRUSTEE FOR MORGAN STANLEY IXIS REAL ESTATE CAPITAL TRUST, 2006-1 : COURT OF COMMON PLEAS : CIVIL DIVISION VS. DANIEL L. CORRIGAN LESLIE A. CORRIGAN : No. CIVIL-09-5421 VERIFICATION OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or it Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant DANIEL L. CORRIGAN is over 18 years of age and resides at 623 3RD STREET, NEW CUMBERLND, PA 17070-2018. (c) that defendant LESLIE A. CORRIGAN is over 18 years of age and resides at 623 3RD STREET, NEW CUMBERLAND, PA 17070-2018. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 0111, ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? urtenay R. Dunn, Esq., Id. No. 206779 0 Andrew C. Bramblett, Esq., Id. No. 208375 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR MORGAN STANLEY IXIS REAL ESTATE CAPITAL TRUST, 2006-1 Plaintiff DANIEL L. CORRIGAN LESLIE A. CORRIGAN Defendant(s) TO: LESLIE A. CORRIGAN 623 3RD STREET NEW CUMBERLAND, PA 17070-2018 DATE OF NOTICE: September 17, 2009 COURT OF COMMON PLEAS CIVIL DIVISON NO. CIVIL-09-5421 CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE 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 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. PHS # 212126 IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE T PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. 4 Office of the Prothonotary Cumberland County Bar Association 40 Cumberland County Courthouse 32 South Bedford Street 1 Courthouse Square Carlisle, PA 17013 Carlisle, PA 17013 ^ (717) 249-3166 (717) 240-6195 N By: Lance T. Phelan, Esq.jId. No. 32227 Fra is S. Hallinan, Esq., d. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 817 Jenine R. Davey, Esq., Id. No. 87077 11 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza. Philadelphia, PA 19103 PHS # 212126 flLf COPY DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR MORGAN STANLEY IXIS REAL ESTATE CAPITAL TRUST, 2006-1 Plaintiff v DANIEL L. CORRIGAN LESLIE A. CORRIGAN Defendant(s) TO: DANIEL L. CORRIGAN 623 3RD STREET NEW CUMBERLND, PA 17070-2018 DATE OF NOTICE: September 17, 2009 COURT OF COMMON PLEAS CIVIL DIVISON NO. CIVIL-09-5421 CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE 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 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. PHS # 212126 IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 By: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 La ence T. Phelan, Esq., P. No. 32227 Fr cis S. Hallinan, Esq., Id No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 813 60 Jenine R. Davey, Esq., Id. No. 8707 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 212126 FjlF. eAll DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR MORGAN STANLEY IXIS REAL ESTATE CAPITAL TRUST, 2006-1 Plaintiff v DANIEL L. CORRIGAN LESLIE A. CORRIGAN Defendant(s) TO: DANIEL L. CORRIGAN 424 4TH STREET NEW CUMBERLAND, PA 17070-1801 DATE OF NOTICE: September 17, 2009 COURT OF COMMON PLEAS CIVIL DIVISON NO. CIVIL-09-5421 CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE 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 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. PHS # 212126 IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABL PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVI TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. 444 Office of the Prothonotary Cumberland County Bar Association e0o ry Cumberland County Courthouse 32 South Bedford Street 1 Courthouse Square Carlisle, PA 17013 Carlisle, PA 17013 (717) 249-3166 (717) 240-6195 n By: L ence T. Phelan, Esq., Id. No. 32227 F is S. Hallinan, Esq., 18. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 8170 Jenine R. Davey, Esq., Id. No. 87077, Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 212126 FILf COPY DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR MORGAN STANLEY IXIS REAL ESTATE CAPITAL TRUST, 2006-1 Plaintiff v DANIEL L. CORRIGAN LESLIE A. CORRIGAN Defendant(s) TO: LESLIE A. CORRIGAN 424 4TH STREET NEW CUMBERLAND, PA 17070-1801 DATE OF NOTICE: September 17, 2009 COURT OF COMMON PLEAS CIVIL DIVISON NO. CIVIL-09-5421 CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE 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 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. PHS # 212126 IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE E TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER L R TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. 4 1j'h Office of the Prothonotary Cumberland County Courthouse I Courthouse Square Carlisle, PA 17013 (717) 240-6195 By: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Lawr e T. Phelan, Esq., Id po. 32227 Fran S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 817 Jenine R. Davey, Esq., Id. No. 8707 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS 4 212126 FILED-),-* ,CE ? O' ; :?'TARY 26H GC i -8 AM 4 ! : 3G TV *l¢,00 po Ar" Sul 110 ail Ut8 {Johee ?? (Rule of Civil Procedure No. 236) - Revised DEUTSCHE BANK NATIONAL TRUST CUMBERLAND COUNTY COMPANY, AS TRUSTEE FOR MORGAN STANLEY IXIS REAL COURT OF COMMON PLEAS ESTATE CAPITAL TRUST, 2006-1 VS. CIVIL DIVISION DANIEL L. CORRIGAN LESLIE A. CORRIGAN No. CIVIL-09-5421 623 3RD STREET NEW CUMBERLAND, PA 17070-2018 Notice is given that a Judgment in the above captioned matter has been entered against you on /p/8 L7 By: T /07 2 If you have any questions concerning this matter ple ontact: Lawrence T. Phelan, Esquire Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jenine R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Joshua I. Goldman, Esquire c "'enay R. Dunn, Esquire drew C. Bramblett, Esquire Attorney or Party Filing 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 * * THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLYRECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BEAN ATTEMPT TO COLLECTA DEBT, BUT ONLYENFORCEMENT OFA LIENAGAINST PROPERTY. ** AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY DEUTSCHE BANK NATIONAL TRUST COMPANY, A5 TRUSTEE FOR MORGAN STANLEY IXIS REAL PHS # 212126 ESTATE CAPITAL TRUST, 2006-1 DEFENDANT SERVICE TEAM/ iin DANIEL L. CORRIGAN LESLIE A. CORRIGAN COURT NO.: CIVIL-09-5421 SERVE LESLIE A. CORRIGAN AT: TYPE OF ACTION 623 3RD STREET XX Notice of Sheriff s Sale NEW CUMBERLAND, PA 17070-2018 SALE DATE: 06/02/2010 SERVED //~~ ~_ Served and made known to l l:6 IG N ,Defendant on the lay of tT +~~ . 20~., at S; sf o'clock ~. M., at (023 Sad ST NEw uMBFRGAw ~~ , in the manner described below: -r? , •~ --i ~[ Defendant personally served. =- ` .' ~ ~'~ rte"'--- _Adult family member with whom Defendant(s) reside(s). f ~ -`a cam'''' sv ~~~,`~ Relationship is ~: _~ .,_ _ Adult in charge of Defendant's residence who refused to give name or relationship. ~' `ty r ~.-.; _ Manager/Clerk of place of lodging in which Defendant(s) reside(s). _: - c~ ~_a rn Agent or person in charge of Defendant's office or usual place of business. ~ • • ~-,~. ~._ _ an officer of said Defendant's company. -~~ ~- Other: Description: Age ~Q_ Height $,D ,, Weight 1 DSO Race ~ Sex ~ Other I, ~D71lIA-t,a j~l~6 LL , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this Zkf'+- day K1MPhRLY CURTY of i~(~ lam, 20Q~. Nn'1 ARY PUBLIC STATE t1F NFW JERSEY Not y 4y rpMMISSION fXP1RES MARCH 7, 2013 i NOT SERVED On the day o , 200_, at o'clock _. M., Defendant NOT FOUND because: _ Vacant _ Bad Address No Answer Service Refused Other: Sworn to and subscribed o ffore me this ~ day B y: Notary: _ Moved _ Does Not Reside (Not Vacant) ATTORNEY FOR PLAINTIFF Lawrence T. Phdan, Esq., id. No. 32227 Frauds S. NalBnan, Esq., Id. No. 62695 Daniel G. Schmteg, Esq., Id. No. 62205 Michde M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., [d. Na. 58745 Shedal R Shah-Joni, Esq., -d. No. 81760 Jenice R. Davey, Esq., Id. No. 87077 Lauren R Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., ld. No. 61791 Andrew L. SpWack, Esq., ld. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalame P. FBakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., id. No. 205047 Courtenay R Dunn, Esq., Id. No. 206779 Andrew C. Brambldt, Esq., W. No. 208375 One Penn Center a[ Suburban Station 1617 John F. Kennedy Blvd., Sui[e 1400 Philadelphia, PA 19103-1814 (2(5)563-7000 AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR MORGAN STANLEY IXIS REAL PHS # 212126 ESTATE CAPITAL TRUST, 2006-1 DEFENDANT SERVICE TEAM/ iin DANIEL L. CORRIGAN LESLIE A. CORRIGAN COURT NO.; CIVIL-09-5421 SERVE DANIEL L. CORRIGAN AT: TYPE OF ACTION 623 3RD STREET XX Notice of Sheriff's Sale NEW CUMBERLAND, PA 17070-2018 SALE DATE: 06/02/2010 SERVED n Served and made known to DMA t ~- L • ~ORRIGA~! Defendant on the 2~'~`day of _~, ~t ~,,_I 5;y~o'clock~?M., at (,2'~ 3fLe Sf, NEwCuMBERtA,1~~A, in the manner described below: .~.~i={: ~ "''~ ~~ _ Defendant personally served. } ~ ~ ~ ' ~ Adult family member with whom Defendant(s) reside(s). ~ ; Relationship is 611 - F ~. - rv r-~ t=` _,_ _ Adult in charge of Defendant's residence who refused to give name or relationship. ,=~_~ _ LL "~ ~ ~ ' _ Manager/Clerk of place of lodging in which Defendant(s) reside(s). ~ . = i~ ~"~; ri _ Agent or person in charge of Defendant's office or usual place of business. ~_; -ice _ an officer of said Defendant's company. ~-:~~- Other: Description: Age ~~ Height 5,b,, Weight 1 gb Race w Sex ~ Other I, ~J4zfl Lt_ , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Swom to and subscribed KIMPERLY CURTY before me this Z~~+t day NQ7ARY P138L1C of ~~, 20f~Q. STATE CIF ~fEW ,FERSEY COMMISSfON EXPIRES MARCH 7, 2013 No y: NOT SERVED On the day , 20Q_, at o'clock _. M., Defendant NOT FOUND hecause: Vacant _ Bad Address No Answer Service Refused Other: Sworn to and subscribed obeffore me this ~6 day B y: Notary: ~~ Moved _ Does Not Reside (Not Vacant) ATTORNEY FOR PLAINTIFF Lawrence T. Phelan, Esq„ Id. No. 32227 Francis S. HalBnan, Esq„ Id. No. 62695 Daniel G. Schmieg, Esq., ld. Na 62205 Mkhek M. Bradford, Esq., Id. No. 69849 Judith T. Romafro, Esq., ld. No. 58745 Shcetal R Shah-Joni, Esq„ Id. No. 8]760 Jenine R Davey, Esq., Id. No.87077 Lauren R. Tabes, Esq., Id. No.93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Fsq„ Id. No. 61791 Andrew L. Spivack, Esq„ Id. Nw 84439 Jaime McGuinness, Esq., Id. Na 90134 Chrisovalante P. Fliakos, Esq„ Id. No. 94620 Joshua L GoMman, Esq„ Id. No. 205047 Courtenay R Dann, Esq„ ld. No. 206779 Andrew G BramblMy Esq., Id. No. 208375 One Penn Center al Suburban Station 1617 John F. Kennedy Blvd„ Suite 1400 Philadelphia, PA 19103-]814 (215)563-7000 IN THE COURT OF COMMON PLEAS ~Y ~ ~ ~~~~ CUMBERLAND COUNTY, PENNSYLVANIA DEUTSCHF, BANK NATIONAL TRUST Court of Common Pleas COMPANY, AS TRUSTEE FOR MORGAN STANLEY IXIS REAL ESTATE CAPITAL Civil Division TRUST, 2006-1 : Plaintiff v. DANIEL L. CORRIGAN LESLIE A. CORRIGAN Defendants AND NOW, this t ~ ~~„ day of CUMBERLAND County No. CIVIL-09-5421 ORDER h'~1 ~1 , 2010, upon consideration of Plaintiff's Motion to Make Rule Absolute, it is hereby ORDERED and DECREED, that the Rule entered upon Defendants shall be and is hereby made absolute; and Plaintiff's Motion to Reassess Damages in the above captained matter is hereby GRANTED. The Prothonotary is ordered to amend the judgment and the Sheriff is ordered to amend the writ nunc pro tunc as follows: Principal Balance $115,728.72 Interest Through June 2, 2010 $11,642.90 Per Diem $25.37 Late Charges $130.95 Legal fees $1,725.00 Cost of Suit and Title $2,121.50 Sheriffs Sale Costs $0.00 Property Inspections/ Property Preservation $120.00 Appraisal/Brokers Price Opinion $190.00 Mortgage Insurance Premium / $0.00 Private Mortgage Insurance Non Sufficient Funds Charge $0.00 Suspense/Misc. Credits ($0.00) Escrow Deficit $3,358.67 TOTAL $135,017.74 Plus interest from June 2, 2010 through the date of sale at six percent per annum. Note: The above figure is not a payoff quote. Sheriffs commission is not included in the above figure. i:~~. ~ ~= ~- A ~ .`7 ~~t a :°q~ r... C'+J (..J ~+~ 12126 1 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY Deutsche Bank National Trust Co: vs. Case Number Daniel L. Corrigan (et al.) 2009-5421 SHERIFF'S RETURN OF SERVICE 04/06/2010 05:05 PM -Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on 4/6/10 at 1705 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description,, in the above entitled action, upon the property of Daniel L. Corrigan and Leslie A.. Corrigan, located at, 424 4th Street, New Cumberland, Cumberland County, Pennsylvania according to law 04/0612010 04:55 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that ono/6/10-at 1655 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Daniel L. Corrigan; by making known unto, Daniel L. Corrigan; personally, at, 623 3rd Street, New Cumberland, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 04/06/2010 04:55 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on 4/6/10 at 1655 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Leslie A. Corrigan, by making known unto, Daniel L. Corrigan, spouse, at, 623 3rd Street, New Cumberland, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 06/01/2010 Property sale postponed to 81412010. 07114/2010 Property sale postponed to 10/6/2010. 10/06/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on October 6, 2010 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Daniel Schmieg, on behalf of Deutsche Bank National Trust Company, as Trustee for Morgan Stanley IXIS Real Estate Capital Trust, 2006-1, 3476 Stateview Blvd, Fort. Mill, SC 29715, being the buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of $ SHERIFF COST: $845.03 SO ANSWERS, November, 08, 2010 RON R ANDERSON, SHERIFF W.0b pd, - a . ;"C' DEUTSC A ,BA14K, NATIONAL''TRUST COMPANY, AS TRUSTEE FOR MORGAN STANLEY IXIS REAL ESTATE CAPITAL TRUST, 2006-1 Plaintiff V. DANIEL L. CORRIGAN LESLIE A. CORRIGAN Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO. CIVIL-09-5421 CUMBERLAND COUNTY AFFIDAVIT PURSUANT TO RULE 3129.1 DEUTSCHE BANK-NATIONAL TRUST COMPANY, AS TRUSTEE FOR MORGAN STANLEY IXIS REAL ESTATE CAPITAL TRUST, 2006-1, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ: of Execution was filed, the following information concerning the real property located at 424 4TH STREET, NEW CUMBERLAND, PA 17070-1801. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) DANIEL L. CORRIGAN LESLIE A. CORRIGAN 2. Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE 623 3RD STREET NEW CUMBERLAND, PA 17070-2018 623 3RD STREET NEW CUMBERLAND, PA 17070-2018 Address (if address cannot be reasonably ascertained, please so indicate) 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) 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. Name Address (if address cannot be reasonably ascertained, please indicate) None. L Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANTIOCCUPANT Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 424 4TH STREET NEW CUMBERLAND, PA 17070-1801 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 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.A. § 4904 relating to unworn falsification to authorities. December 16, 2009 By: Attornor Plaintiff Phelan Hallinan & Schmieg, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 R Peter J. Mulcahy, Esq.; Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq.; Id. No: 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 ,AS Andrew C. Bramblett, Esq., Id. No. 208375 I f DEUTSCHE'BANK NATIONAL TRUST COMPANY, AS COURT OF COMMON PLEAS TRUSTEE FOR MORGAN STANLEY IXIS REAL ESTATE CAPITAL TRUST, 2006-1 CIVIL DIVISION Plaintiff : NO. CIVIL-09-5421 VS. DANIEL L. CORRIGAN LESLIE A. CORRIGAN Defendant(s) : CUMBERLAND COUNTY NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: DANIEL L. CORRIGAN LESLIE A. CORRIGAN 623 3RD STREET NEW CUMBERLAND, PA 17070-2018 * *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 424 4TH STREET, NEW CUMBERLAND, PA 17070-1801 is scheduled to be sold at the Sheriff's Sale on 06/02/2010 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $125,485.56 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR MORGAN STANLEY IXIS REAL ESTATE °CAPITAL TRUST, 2006-1 (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a. deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the `Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 SHORT DESCRIPTION By virtue of a Writ of Execution NO. CIVIL-09-5421 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR MORGAN STANLEY IXIS REAL ESTATE CAPITAL TRUST, 2006-1 vs. DANIEL L. CORRIGAN LESLIE A. CORRIGAN owner(s) of property situate in the BOROUGH OF NEW CUMBERLAND, Cumberland County, Pennsylvania, being (Municipality) 424 4TH STREET, NEW CUMBERLAND, PA 17070-1801 Parcel No. 25-25-0006-050 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $125,485.56 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 LEGAL DESCRIPTION ALL THAT CERTAIN tract or Parcel of land and premises, situate, lying and being in the Borough of New Cumberland in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the south side of Fourth Street 30 feet East from the Southeast corner of Fourth Street and Geary Avenue; thence eastwardly along said Fourth Street 30 feet to line of property now or formerly of Lake Prowell; thence Southwardly along said line of property now or formerly of Lake Prowell, 140 feet to Ruby Avenue; thence Westwardly along said Ruby Avenue 10 feet to line of property now or formerly of Delance Lenhart; thence Northwardly along said line of property now or formerly of Delance Lenhart 40 feet to a point; thence Westwardly along said property of Delance Lenhart 20 feet to fine of property now or formerly of Thomas Singleton; thence Northwardly along said line of property now or formerly of Thomas Singleton, 100 feet to Fourth Street, the Place of BEGINNING. HAVING thereon erected a single two and one-half story frame dwelling house and garage. TITLE TO SAID PREMISES IS VESTED IN Daniel L. Corrigan and Leslie A. Corrigan, h/w, by Deed from Brooke R. Rhodes and Margaret Salter, h/w, dated 02/07/2006, recorded 02/17/2006 in Book 273, Page 1099. PREMISES BEING: 424 4TH STREET, NEW CUMBERLAND, PA 17070-1801 PARCEL NO. 25-25-0006-050 WRIT OF EXECUTION and/or ATTACHMENT , t COMMONWEALTH OF PENNSYLVANIA) NO 09-5421 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY, as Trustee for MORGAN STANLEY IXIS REAL ESTATE CAPITAL TRUST, 2006-1, Plaintiff (s) From DANIEL L. CORRIGAN and LESLIE A. CORRIGAN (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 $125,485.56 L.L. $.50 Interest from 10/812009 to Date of Sale ($20.63 per diem) - $4,909.94 Atty's Comm % Due Frothy $2.00 Atty Paid $247.60 Other Costs Plaintiff Paid Date: 12/18/09 (Seal) C ' R. Long, Prothono r c By: 4h,4t Deputy REQUESTING PARTY: Name: COURTENAY R. DUNN, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG; LLP 1617 JFK'BOULEVARD, SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 206779 On March 22, 2010 the Sheriff levied upon the defendant's interest in the real property situated in C\Ii cNii, New Cumberland Borough, Cumberland County, PA r F.? .. , Known and numbered, 424 4"' Street, New Cumberland; ?... CNIJ ` more fully described oei ExIiibir "A" filed with this writ and by this reference incorporated herein. Date: March 22, 2010 Bye Real estate Coordinator yy, ?El S r, t ,?4 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 16, April 23, and April 30, 2010 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the `aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Writ No. 2009-5421 Civil Zk Deutsche Bank National Trust Co. , ,,.--- As Trustee for Stanley IXIS Real Estate Capital Trust 2006-1 isa Marie Coyne, ditor vs. Daniel L. Corrigan Leslie A. Corrigan SWORN TO AND SUBSCRIBED before me this Atty: Daniel Schmieg 30 da of A ril 2010 By virtue of a Writ of Execution NO. CIVIL-09-5421, DEUTSCHE BANK NATIONAL TRUST COM- , PANY, AS TRUSTEE FOR MORGAN N t STANLEY IXIS REAL ESTATE CAPI- o ary y TAL TRUST, 2006-1 vs. DANIEL L. CORRIGAN, LESLIE A. CORRIGAN, owners of property situate in the BOROUGH OF NEW CUMBERLAND, ?wrr?r?rr N IAL A SEA Cumberland County, Pennsylvania, DEB©RORAM A S being 424 4TH STREET, NEW CUM- NotKy PUNIC ublic BERLAND, PA 1 CUMBERLAND CO NiW ISLE BOROUGH Parcel No. 25-25-0006-050. P Improvements thereon: RESIDEN- , 014 MY Com"Sw Expk" Apt 2S.2 TIAL DWELLING. JUDGMENT AMOUNT: $125,485- .56. The Patriot-News Co. 72020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE the Patr1*otw.Xtws Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949; respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, . place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verily this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and fir saicl County of Dauphin in Miscellaneous Book "M Volume 14, Page 317. Writ No. 2009-5421 Civil Term This ad ran on the date(s) shown below: Deutsche Bank National Trust Co. 04/16/10 As Trustee for Stanley IXIS Real 04123110 Estate Cap"/Trust 04130110 2006-1 VS. -?`.. Davie! L. Corrigan ....... .... .... ..... Leslie A. Corrigan Atty: Daniel Schmieg 8y oiaueotaWfitofExectitimNO.CrnL-o9 Sworn to an 'scribed before me th' ay of May, 2010 A.D. 5421 DEUTSCHE BANK NATIONAL TRUST. COMPANY,L AS TRUSTEE FOR MORGAN STANLEY I]XIS REAL ESTATE CAPITAL " I-R ST. 2006-1 Notary Public %S. D.'1,NII L L. CORRIGAN LESLIE A. CORRIGAN owner(s) of property situate in the BOROUGH' COMMONWEALTH OF PENNSYLVANIA OF NEW CUMBERLAND, Cumberland County, Notarial Seal Pennsylvania, being (Municipality), 424 4TH Sherrie L. Klsner, Notary public rREET, NEW CUMBERLAND, PA 17070- Lower Paxton Twp., Dauphin County 301 My Comrnisslort Expires Nov. 26- 7011 Parcel No. 25-25-0(ft-050 Member; Penn"venle Amodatlon of Notaries ,clmge or street address) nprovements 'thereon:, RESIDENTIAL DWELLING JUDGMENT AMOUNT: x 175 US %, COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Morgan Stanley IXIS Real Estate Capital Trust, 2006-1, Tr is the grantee the same having been sold to said grantee on the 6th day of October A.D., 2010, under and by virtue of a writ Execution issued on the 18th day of December, A.D., 2009, out of the Court of Common Pleas of said County as of Civil Term, 09 Number 5421, at the suit of Morgan Stanley IXIS Real Estate Capital Trust, 2006-1, Tr against Daniel L & Leslie A Corrigan is duly recorded as Instrument Number 201032587. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this _day of A.D.C? ,; Recorder of Deeds MyG=ww ion Eqm theFistMm*OfJUL2M4