HomeMy WebLinkAbout09-5813GOLDBECK McCAFFERTY & McKEEVER
BY: MICHAEL T. MCKEEVER
ATTORNEY I.D. #56129
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
(866) 413-2311
WWW.GOLDBECKLAW.COM
ATTORNEY FOR PLAINTIFF
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE FOR SAXON ASSET SECURITIES TRUST
2007-2
4708 Mercantile Drive North
Fort Worth, TX 76137
Plaintiff
vs.
CALVIN W. WILLIAMS III
Mortgagor and Record Owner
1508 Simpson Ferry Road
New Cumberland, PA 17070
Defendant
Term Oq- 5$13 t?tvi
No.
CIVIL ACTION: MORTGAGE Tom"
Pt: CLGSU19F
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages,
you must take action within twenty (20) days after the Complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further notice for any money claim in the Complaint
of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
AVISO
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS
QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO
DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES
NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL
PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA
DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL
PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES
DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER
DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES.
USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN
ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA
PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO.
SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE
INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS
ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT
A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you
still may be able to SAVE YOUR HOME FROM FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-
243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling.
3). Visit HUD' S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners
in default. Please See the PHFA website biLtp://www.phfa.org/consumers/homeowners/real.aspx.
5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home
Retention options.
6). Foreclosure Resource Center: hLtp://www.philadelphiafed.org/foreclosure/
7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage
or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email
at homeretention(a,goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or
package you requested will be mailed to the address that you request or faxed if you leave a message with that
information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be
reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 86134FC.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
This Action of Mortgage Foreclosure will continue unless you take action to stop it.
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR SAXON
ASSET SECURITIES TRUST 2007-2, 4708 Mercantile Drive North, Fort Worth, TX 76137.
2. The name and address of the Defendant is CALVIN W. WILLIAMS III, 1508 Simpson Ferry Road,
New Cumberland, PA 17070, who is the mortgagor and record owner of the mortgaged premises
hereinafter described.
3. On February 09, 2007 mortgagors made, executed and delivered a mortgage upon the Property
hereinafter described to SAXON MORTGAGE, INC., which mortgage is recorded in the Office of the
Recorder of Deeds of Cumberland County as Book 1982 Page 1449. The mortgage has been assigned to:
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR SAXON ASSET
SECURITIES TRUST 2007-2 by assignment of Mortgage. Plaintiff is the real party in interest pursuant
to a purchase or transfer of the mortgage obligation from the last record holder and an Assignment of
Mortgage to Plaintiff has been and/or will be lodged for recording with the Recorder of Deeds in the
ordinary course of business. The Mortgage and assignment(s) are matters of public record and are
incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which
Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are
matters of public record.
4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit
"A" ("Property").
5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid
for March 01, 2009 and each month thereafter and by the terms of the Mortgage, upon default in such
payments for a period of one month or more, the entire principal balance and all interest due and other
charges are due and collectible.
6. The following amounts are due to Plaintiff on the Mortgage:
Principal Balance ...................................................................
Interest from 02/01/2009 through 08/31/2009 at 6.9500%...
Per Diem interest rate at $29.25
Reasonable Attorney's Fee at 5% of Principal Balance
as more fully explained in the next numbered paragraph
Late Charges from 03/01/2009 to 08/31/2009 .......................
Monthly late charge amount at $51.89
f d 'r.+1 S h
...............$153,616.55
...................$6,201.00
..................$7,680.83
..................... $467.01
Costs o sultan It a eaL .............................................................
Fees .....................................................................................................
Escrow Advance .....................................
Monthly Escrow amount $238.02
....... $900.00
.......$154.00
.......$777.17
$169,796.56
7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less
than the amount demanded based on work actually performed. The Attorney's Fees requested are in
conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up
to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at
Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount
demanded in the Action.
8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the
Defendant in this Action but reserves its right to bring a separate Action to establish that right, if such
right exists. If Defendant has received a discharge of their personal liability in a Bankruptcy proceeding,
this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that
was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to
Pennsylvania law.
9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has
been sent to Defendant by certified and regular mail, as required by Act 160 of 1998 of the
Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s)
attached hereto as Exhibit "B". The Defendant have not had the required face-to-face meeting within
the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant
through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit
Counseling Agency.
WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $169,796.56,
together with interest at the rate of $29.25, per day and other expenses, costs and charges incurred by the
Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law
until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property.
By: ( .
GMcCAFFE TY & McKEEVER
BY: MICHAEL T. MCKEEVER, ESQUIRE
ATTORNEY FOR PLAINTIFF
VERIFICATION
Regina Alexander , as the representative of the Plaintiff corporation
within named do hereby verify that I am authorized to and do make this verification on behalf of the
Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the
best of my knowledge, information and belief. I understand that false statements therein are made
subject to the penalties of 18 Pa. C.S. 4904 relating to unsw als ication to
Dat • rd r
/
SCHE BALK NATIONAL TRUST
ANY, AS TRUSTEE FOR SAXON
3 YT SECURITIES TRUST 2007-2, BY
ON MORTGAGE SERVICES, INC.,
ITS ATTORNEY-IN FACT.
Regina Alexander i "e Pres' ?:7s:.nt
#86134FC - CALVIN W. WILLIAMS III
1508 Simpson Ferry Road New Cumberland, PA 17070
Ex hiditA
SCHEDULE C
Legal Description
Commitment Number: GR06-1130REF
ALL THAT CERTAIN piece or parcel of land, situate in the Borough of New Cumberland, County of Cumberland
and. Commonwealth of Pennsylvania, bounded and described as follows, to wit:
BEGINNING at a point on the South side of Simpson Ferry Road at the dividing line between Lots Nos. 6 and 7
on the hereinafter mentioned Plan of Lots; thence southwardly along said dividing line a distance of one hundred
ninety (190) feet to land now or formerly of Elmer E. Zimmerman; thence eastwardly along land now or formerly of
Elmer E. Zimmerman a distance of seventy (70) feet to a point; thence northwardly on a line parallel with the
dividing line between Lots Nos. 7 and 8 on said Plan a distance of one hundred ninety (190) feet to the southerly
line of Simpson Ferry Road; thence westwardly along Simpson Ferry Road a distance of seventy (70) feet to Lot
No. 6, the place of BEGINNING.
BEING all of Lot No. 7 and the westerly twenty (20) feet of Lot No. 8, Block "C" in a Plan of Lots known as
Zimmerman Acres as recorded in the Cumberland County Recorder's Office in Plan Book 3, Page 51.
HAVING THEREON ERECTED a single dwelling house known as No. 1508 Simpson Ferry Road, New
Cumberland, Pennsylvania.
?hibit B
ACT 91 NOTICE
DATE OF NOTICE: 06/11/2009
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THE PURPOSE OF COLLECTING THE DEBT.
This is an official notice that the mortgage on your home is in default, and the
lender intends to foreclose Specific information about the nature of the default is provided in
the attached pages.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be
able to help to save your home. This Notice explains how the program works.
To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT
COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this
Notice with you when you meet with the Counseling Agency.
The name, address and phone number of Consumer Credit Counseling Agencies serving
your County are listed at the end of this Notice. If you have any questions, you may call the
Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired
hearing can call (717) 780-1869.)
This Notice contains important legal information. If you have any questions,
representatives at the Consumer Credit Counseling Agency may be able to help explain it.
You may also want to contact any attorney in your area. The local bar association may be able
to help you find a lawyer.
La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar
viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion
immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al
numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado
"Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la
perdida del derecho a redimir su hipoteca.
Prepared by: GOLDBECK McCAFFERTY & McKEEVER
Suite 5000 - Mellon Independence Center.
701 Market Street
Philadelphia, PA 19106
Fax (215) 627-7734
1
Date: 06/ I 1 /2009
Homeowners Name: CALVIN W. WILLIAMS III
Property Address: 1508 Simpson Ferry Road, New Cumberland, PA 17070
Loan Account No.: 12067870
Original Lender: SAXON MORTGAGE SERVICES INC.
Current Lender/Servicer: SAXON MORTGAGE SERVICES INC.
HOMEOWNERS'
EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL
ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE
MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S
EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE
ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
* IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
* IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
* IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for
mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the
designated consumer credit counseling agencies listed at the end of this Notice.
THIS MEETING MUST OCCUR WITHIN THE NEXT (33) DAYS. IF YOU DO NOT
APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE
YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO
DATE.
CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer
credit counseling agencies listed at the end of this notice, the lender may NOT take action against you
for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of
designated consumer credit counseling agencies for the county in which the property is located are set
forth at the end of this Notice_ It is only necessary to schedule one face-to-face meeting. Advise your
lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the
reasons set forth later in this Notice (see following pages for specific information about the nature of
your default.) You have the right to apply for financial assistance from the Homeowner's Emergency
Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's
Emergency Assistance Program Application with one of the designated consumer credit counseling
agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications
for the program and they will assist you in submitting a complete application to the Pennsylvania
Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your
application MUST be filed or postmarked within thirty (30) days of your fact-to-face meeting with the
counseling agency.
YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU
HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE
POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA
WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY
PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS
EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF
FORECLOSURE."
YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND
THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER
FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS
EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE
FORECLOSURE WILL BE STOPPED.
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 filed bankruptcy you can still apply for
Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property
located at: 1508 Simpson Ferry Road, New Cumberland, PA 17070 IS SERIOUSLY IN DEFAULT
because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months
and the following amounts are now past due:
(a) Monthly payment from 03/01/2009 thru 06/11/2009
(4 mos. at $1,275.95/month) $5,103.80
(b) Late charges from 03/01/2009 thru06/11/2009 (4 mos. at $51.89/month) $207.56
(c) Other charges; Escrow, Inspec., NSF Checks
(d) Other provisions of the mortgage obligation, if any
(e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $5,311.36
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 $5,311.36, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME
DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check,
certified check or money order made payable and sent to:
SAXON MORTGAGE SERVICES INC.
4708 Mercantile Drive North
Fort Worth, TX 76137
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default
within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to
accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be
considered due immediately and you may lose the chance to pay the mortgage in monthly installments.
If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also
intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property.
IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the
Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the
delinquency before the lender brings legal proceedings against you, you will still be required to pay the
reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are
started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender
even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which
may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY
Period, you will not be required to pay attorney's fees.
OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the
default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have
the right to cure the default and prevent the sale at any ime up to one hour before the Sheriffs Sale.
You may do so by paving 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 four (4) to six (6)
months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to
you before the sale. Of course, the amount needed to cure the default will increase the longer you wait.
You may find out at any time exactly what the required payment or action will by contacting the
lender.
HOW TO CONTACT THE LENDER:
Name of Lender: SAXON MORTGAGE SERVICES INC.
Address: 4708 Mercantile Drive North
Fort Worth, TX 76137
Phone Number: 888-325-3502
Contact Person: Loss Mitigation Department
EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of
the mortgaged property and your right to occupy it. If you continue to live in the property after the
Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by
the lender at any time.
ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who
will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees
and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
* TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE
DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF
THIS DEBT.
TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO
DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT
HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY
CALENDAR YEAR.)
* TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH
ACTION BY THE LENDER.
TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
Contact: Loss Mitigation Department
Phone Number: 888-325-3502
HEMAP Consumer Credit Counseling Agencies
I Report last updated: 5/29/2009 7:58:33 AM
CCCS of Northeastern PA
401 Laurel Street
Pittston, PA 18640
570.602.2227
800.922.9537
CRAWFORD County
Booker T. Washington Center
1720 Holland Street
Erie, PA 16503
814.453.5744
CCCS of Western PA
4402 Peach Street
Erie, PA 16509
888.511.2227 ext
108
888.511.2227 ext
108
Center for Family Services, Inc.
213 Center Street
Meadville, PA 16335
814.337.8450
Greater Erie Community Action Committee
18 West 9TH Street
Erie, PA 16501
814.459.4581
Shenango Valley Urban League, Inc.
601 Indiana Avenue
Farrell, PA 16121
724.981.5310
St. Martin Center
1701 Parade Street
Erie, PA 16503
814.452.6113
CUMBERLAND County
Adams County Interfaith Housing Authority
40 E High Street
Gettysburg, PA 17325
717.334.1518
Loveship, Inc.
2320 North 5th Street
Harrisburg, PA 17110
717.232.2207
Maranatha
43 Philadelphia Avenue
Waynesboro, PA 17268
717.762.3285
PHFA
211 North Front Street
Harrisburg, PA 17110
717.780.3940
800.342.2397
DAUPHIN County
CCCS of Western PA
2000 Linglestown Road
Harrisburg, PA 17102
888.511.2227
888.511.2227
Community Action Commission of Captial Region
1514 Derry Street
Harrisburg, PA 17104
717.232.9757
Loveship, Inc.
2320 North 5th Street
Harrisburg, PA 17110
717.232.2207
Opportunity Inc.
301 East Market Street
York, PA 17403
717.424.3645
PHFA
211 North Front Street
Harrisburg, PA 17110
717.780.3940
800.342.2397
DELAWARE County
CCCS of Western PA
2000 Linglestown Road
Harrisburg, PA 17102
888.511.2227
888.511.2227
Community Action Commission of Captial Region
1514 Derry Street
Harrisburg, PA 17104
717.232.9757
Acom Housing Corporation
846 North Broad Street
Philadelphia, PA 19130
215.765.1221
Advocates for Financial Independence
202 East Hinkley Avenue
Ridley Park, PA 19078
215.389.2810
Page 8 of 21
R.F-D-4--T'-;,r r
THE P-" 7 "ONOTAPY
2009 A iG 24 ii 12: 12
418.50 Pts A7r4
CIO 3944x1
PT* aaq (v55
Sheriffs Office of Cumberland County
R Thomas Kline
Sheriff
Ronny R Anderson
Chief Deputy
Jody S Smith
Civil Process Sergeant
GQt?+?tt? of ?urrrGr?.f???
OFFICE `F ?"= S! ERiFF
`d
FJLEE? 0?-` ;
OF THE F ... ' ?EfiRY
Edward L Schorpp
Solicitor
209 H-P - I PV1 2. 17
Deutsche Bank National Trust Co.
Case Number
vs.
Calvin W. Williams, III 2009-5813
SHERIFF'S RETURN OF SERVICE
08/29/2009 10:56 AM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on
August 29, 2009 at 1052 hours, she served a true copy of the within Complaint in Mortgage Foreclosure,
upon the within named defendant, to wit: Calvin W. Williams, III, by making known unto Hugo Pastor, adult
in charge at 1508 Simpson Ferry Road 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. The
defendant Calvin W. Williams, III does not reside at 1508 Simpson Ferry Road New Cumberland, PA
17070, the tenant is Hugo Pastor.
SHERIFF COST: $43.30 eOA
August 31, 2009 R THOMAS KLINE, SHERIFF
Ar u?' ", I
t Sher ff
Sheriffs Office of Cumberland County
F `
R Thomas Kline
r TI-E
Sher
??,ti,ti'r fit It tnf?f r?,f??r? n nr -rti n n , . t .,
Ronny R Anderson u' :^p
Chief Deputy
Jody S Smith
Civil Process Sergeant
Edward L Schorpp
Solicitor
Deutsche Bank National Trust Co.
vs.
Calvin W. Williams, III
Case Number
2009-5813
SHERIFF'S RETURN OF SERVICE
09123/2009 10:28 AM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on September
23, 2009 at 1028 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Calvin W. Williams, III, by making known unto himself personally, at 157
South 32nd Street Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time
handing to him personally the said true and correct copy of the same.
SHERIFF COST: $50.50
September 23, 2009
SO ANSWERS,
R THOMAS KLINE, SHERIFF
By w<
Deputy Sheriff
In the Court of Common Pleas of Cumberland County
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE FOR SAXON ASSET SECURITIES TRUST 2007-2
4708 Mercantile Drive North
Fort Worth, TX 76137
Plaintiff
vs.
CALVIN W. WILLIAMS III
(Mortgagor(s) and Record Owner(s))
1508 Simpson Ferry Road
New Cumberland, PA 17070
Defendant(s)
No. 09-5813civilterm
PRAECIPE FOR JUDGMENT
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE
OF COLLECTING THE DEBT.
Enter the Judgment in favor of Plaintiff and against CALVIN W. WILLIAMS III by default for want of an Answer.
Assess damages as follows:
Debt
Interest from 10/28/09 to
Date of Sale per diem at $29.25
Total
$172,043.63
(Assessment of Damages attached)
I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO
BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT.
I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment
is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the
filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 /#-tl
Michael T. McKeever
Attorney for Plaintiff
I.D. #56129
AND NOW 0124 A a , Judgment is entered in favor of
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTE FOR SAXON ASSET SECURITIES TRUST 2007-
2 and against CALVIN W. WILLIAMS III by default for want of an Answer and damages assessed in the sum of
$172,043.63 as per the above certification.
Om-thonotary
86134FC
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED
FOR THE PURPOSE OF COLLECTING THE DEBT.
TO:
CALVIN W. WILLIAMS III
WILLIAMS III, CALVIN W.
149 South Locust Point Road
Mechanicsburg, PA 17055
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE FOR SAXON ASSET SECURITIES TRUST 2007-2
4708 Mercantile Drive North
Fort Worth, TX 76137
Plaintiff
VS.
CALVIN W. WILLIAMS III
(Mortgagor(s) and Record Owner(s))
1508 Simpson Ferry Road
New Cumberland, PA 17070
Defendant(s)
TO: CALVIN W. WILLIAMS III
149 South Locust Point Road
Mechanicsburg, PA 17055
DATE OF THIS NOTICE: October 16, 2009
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Action of
Mortgage Foreclosure
Term
No. 09-5813civilterm
IWORTANT 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 (10) 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. 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
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
Michael T. McKeever
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever, Esq.
Attorney for Plaintiff
Suite 5000 - 701 Market Street.
Philadelphia, PA 19106 215-825-6318
86134FC
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED
FOR THE PURPOSE OF COLLECTING THE DEBT.
TO:
CALVIN W. WILLIAMS III
WILLIAMS III, CALVIN W.
1508 Simpson Ferry Road
New Cumberland, PA 17070
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE FOR SAXON ASSET SECURITIES TRUST 2007-2
4708 Mercantile Drive North
Fort Worth, TX 76137
Plaintiff
VS.
CALVIN W. WILLIAMS III
(Mortgagor(s) and Record Owner(s))
1508 Simpson Ferry Road
New Cumberland, PA 17070
Defendant(s)
TO_ CALVIN W. WILLIAMS III
1508 Simpson Ferry Road
New Cumberland, PA 17070
DATE OF THIS NOTICE: October 16, 2009
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Action of
Mortgage Foreclosure
Term
No. 09-5813 civilterm
01PORTANT 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 (10) 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. 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
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
Michael T. McKeever
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever, Esq.
Attorney for Plaintiff
Suite 5000 - 701 Market Street.
Philadelphia, PA 19106 215-825-6318
86134FC
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED
FOR THE PURPOSE OF COLLECTING THE DEBT.
TO:
CALVIN W. WILLLAMS III
WILLIAMS III, CALVIN W.
157 South 32nd Street
Camp Hill, PA 17011
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE FOR SAXON ASSET SECURITIES TRUST 2007-2
4708 Mercantile Drive North
Fort Worth, TX 76137
Plaintiff
vs.
CALVIN W. WILLIAMS III
(Mortgagor(s) and Record Owner(s))
1508 Simpson Ferry Road
New Cumberland, PA 17070
Defendant(s)
TO: CALVIN W. WILLIAMS III
157 South 32nd Street
Camp Hill, PA 17011
DATE OF THIS NOTICE: October 16, 2009
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Action of
Mortgage Foreclosure
Term
No. 09-5813 civilterm
Eff ORTANT 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 (10) 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 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
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
Michael T. McKeever
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever, Esq.
Attorney for Plaintiff
Suite 5000 - 701 Market Street.
Philadelphia, PA 19106 215-825-6318
VERIFICATION OF NON-MILITARY SERVICE
The undersigned, as the representative for the Plaintiff corporation within named do
hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation
and that the facts set forth in the foregoing verification of Non-Military Service are true and
correct to the best of my knowledge, information and belief. I understand that false statements
therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to
authorities.
1. That the above named Defendant, CALVIN W. WILLIAMS III, is about unknown
years of age, that Defendant's last known residence is 157 South 32nd Street Camp Hill, PA 17011,
and is engaged in the unknown business located at unknown address.
2. That Defendant is not in the Military or Naval Service of the United States or its
Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of
Congress of 1940 and its Amendments.
Date:
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney I.D. #56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR SAXON ASSET SECURITIES
TRUST 2007-2
4708 Mercantile Drive North
Fort Worth, TX 76137
Plaintiff
VS.
CALVIN W. WILLIAMS III
(Mortgagor(s) and Record owner(s))
1508 Simpson Ferry Road
New Cumberland, PA 17070
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION LAW
ACTION OF MORTGAGE FORECLOSURE
No. 09-5813civilterm
ORDER FOR JUDGMENT
Please enter Judgment in favor of DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE FOR SAXON ASSET SECURITIES TRUST 2007-2, and against CALVIN W. WILLIAMS III for
failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States
of America) from the date of service of the Complaint, in the sum of $172,043.63.
lAb
Michael T. McKeever"
Attorney for Plaintiff
I hereby certify that the above names are correct and that the precise residence address of the judgment
creditor is DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR SAXON ASSET
SECURITIES TRUST 2007-2 4708 Mercantile Drive North Fort Worth, TX 76137 and that the name(s) and last
known address(es) of the Defendant(s) is/are CALVIN W. WILLIAMS III, 157 South 32nd Street Camp Hill, PA
17011;
GOLDBECK MCCAFFERTY McKEEVER
BY: Michael T. McKeever
Attorney for Plaintiff
ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly assess the damages in this case to be as follows:
Principal Balance $153,616.55
Interest from 02/01/2009 through $7,868.25
10/27/2009
Reasonable Attorney's Fee $7,680.83
Late Charges $570.79
Costs of Suit and Title Search $900.00
Escrow Payments Due 2 X $238.02 $476.04
Fees $154.00
Escrow Advance $777.17
$172,043.63
GOLDBECK cCA FERT & McKEEVER
BY: Michael T. McKeever
Attorney for Plaintiff
AND NOW, this aQ4- day of 2009 damages are assessed as above.
OFF
o Prothy 4,?
F1LE1.?,:?r=aC?.
OF THE
2009OOT29 AN 11:570
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14.00 Pp A ml
CIO, Sa34qg
e .13 a73A
Rule of Civil Procedure No. 236 - Revised
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR SAXON ASSET SECURITIES TRUST 2007-
2
4708 Mercantile Drive North
Fort Worth, TX 76137
Plaintiff
vs.
CALVIN W. WILLIAMS III
(Mortgagors and Record Owner(s))
1508 Simpson Ferry Road
New Cumberland, PA 17070
Defendant(s)
No. 09-5813civilterm
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE
PURPOSE OF COLLECTING THE DEBT.
NOTICE
Notice is given that a judgment in the above-captioned er h red against you.
urt Long
Pro
By:
Deputy
If you have any questions concerning the above, please contact:
1o/aQ/oq
Michael T. McKeever
Goldbeck McCafferty & McKeever
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
Michael T. McKeever
Attorney I.D.#56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR SAXON ASSET SECURITIES
TRUST 2007-2
4708 Mercantile Drive North
Fort Worth, TX 76137
vs.
CALVIN W. WILLIAMS III
Mortgagor(s) and Record Owner(s)
1508 Simpson Ferry Road
New Cumberland, PA 17070
IN THE COURT OF COMMON PLEAS
Plaintiff
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 09-5813civilterm
Defendant(s)
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
Interest from 10/28/09
to Date of Sale per
diem at $29.25
(Costs to be added)
$172,043.63
141
GOLDBECK MICA ERTY & McKEEVER
BY: Michael T. McKeever
Attorney for Plaintiff
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All that certain piece or parcel of land, situate in the Borough of New Cumberland, County of
Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit:
BEGINNING at a point on the South side of Simpson Ferry Road at the dividing line between Lots Nos.
6 and 7 on the hereinafter mentioned Plan of Lots; thence southwardly along said dividing line a
distance of one hundred ninety (190) feet to land now or formerly of Elmer E. Zimmerman thence
eastwardly along land now or formerly of Elmer E. Zimmerman a distance of seventy (70) feet to a
point; thence northwardly on a line parallel with the dividing line between Lots Nos. 7 and 8 on said
Plan a distance of one hundred ninety (190) feet to the southerly line of Simpson Ferry Road; thence
westwardly along Simpson Ferry Road a distance of seventy (70) feet to Lot No.6, the Place of
BEGINNING.
BEING all of Lot No. 7 and the westerly twenty (201 feet of Lot No. 8, Block "C" in a Plan of Lots
known as Zimmerman acres are recorded in the Cumberland County Recorder's Office in Flan book 3,
Page 51.
Parcel#: 26-24-0809-277
Property address: 1508 Simpson Ferry Road, New Cumberland, Pa 17070.
Being the same premises which Hubert Lemay and Eva Lemay, his wife, by Deed dated 08/04/06 and
recorded 08/09/06 in the Office of the Recorder of Deeds in and for Cumberland County, in Deed Book
276 Page 522, granted and conveyed unto Calvin Williams.
Michael T. McKeever
Attorney I.D. #56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE FOR SAXON ASSET SECURITIES TRUST 2007-
2
4708 Mercantile Drive North
Fort Worth, TX 76137
vs.
CALVIN W. WILLIAMS III
Mortgagor(s) and Record Owner(s)
1508 Simpson Ferry Road
New Cumberland, PA 17070
Plaintiff
Defendant(s)
IN THE COURT OF
COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF
MORTGAGE FORECLOSURE
NO.09-5813civilterm
CERTIFICATION AS TO THE SALE OF REAL PROPERTY
I, Michael T. McKeever, Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and
I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the
Act.
P6 4
Michael T. McKeever
Attorney for plaintiff
FILE D--OJ ICE
OF THIc P"?C)T.,-'()NOTARY
2009 0CT 29 AM 11.50
Cl1P&_ ?P 1.'I LINTY
PENNSYLVA CIA
do
I
Goldbeck McCafferty & McKeever
BY: Michael T. McKeever
Attorney I.D. 456129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR SAXON ASSET
SECURITIES TRUST 2007-2
4708 Mercantile Drive North
Fort Worth, TX 76137
Plaintiff
VS.
CALVIN W. WILLIAMS III
(Mortgagor(s) and Record Owner(s))
1508 Simpson Ferry Road
New Cumberland, PA 17070
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
No. 09-5813civilterm
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR SAXON ASSET SECURITIES
TRUST 2007-2, Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth as of the date the
praecipe for the writ of execution was filed the following information concerning the real property located at:
1508 Simpson Ferry Road
New Cumberland, PA 17070
LName and address of Owner(s) or Reputed Owner(s):
CALVIN W. WILLIAMS III
157 South 32nd Street
Camp Hill, PA 17011
2. Name and address of Defendant(s) in the judgment:
CALVIN W. WILLIAMS III
157 South 32nd Street
Camp Hill, PA 17011
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
i-
SCOTT A. MARLOW
AWAITING FOR LIENHOLDER ADDRESS
4. Name and address of the last recorded holder of every mortgage of record:
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
1508 Simpson Ferry Road
New Cumberland, PA 17070
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
DATED: October 27, 2009
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever, Esq.
Attorney for Plaintiff
C-9
Rl PD--Q FICF
OF THEE P; TL' Nlo. TA??Y
2009 OC T 29 AM 11: 50
PENNSYLeIA NIA.
r
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney I.D.#56129
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6318
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR SAXON ASSET
SECURITIES TRUST 2007-2
4708 Mercantile Drive North
Fort Worth, TX 76137
Plaintiff
VS.
CALVIN W. WILLIAMS III
Mortgagor(s) and Record Owner(s)
1508 Simpson Ferry Road
New Cumberland, PA 17070
Defendant(s' ,
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Term
No. 09-5 813 civilterm
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: WILLIAMS III, CALVIN W.
CALVIN W. WILLIAMS 111
157 South 32nd Street
Camp Hill, PA 17011
Your house at 1508 Simpson Ferry Road, New Cumberland, PA 17070 is scheduled to be sold at
Sheriffs Sale on Wednesday, March 03, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL
Courthouse to enforce the court judgment of $172,043.63 obtained by DEUTSCHE BANK NATIONAL
TRUST COMPANY, AS TRUSTEE FOR SAXON ASSET SECURITIES TRUST 2007-2 against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
09-5813civilterm
IN THE COURT OF COMMON PLEAS
of Cumberland County
To prevent this Sheriffs Sale you must take immediate action:
09-5813civilterm
1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR SAXON ASSET SECURITIES TRUST 2007-2, the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay call our office at
215-825-6329 or 1-866-413-2311.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
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 the Sheriff of 717-240-6390.
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 a 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 schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. 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 schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.orgJforeclosure/
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
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
09-5813civilterm
717-243-9400
r
09-5813civilterm
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: or 717-243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website
http://www.phfa.org/consumers/homeowners/real.aspx.
5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at homeretentionkaoldbecklaw.com.
Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you
requested will be mailed to the address that you request or faxed if you leave a message
with that information. The attorney in charge of our firm's Homeowner Retention
Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418.
Please reference our Attorney File Number of 86134FC.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
09-5813civilterm
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney I.D.#56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6318
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR SAXON ASSET
SECURITIES TRUST 2007-2
4708 Mercantile Drive North
Fort Worth, TX 76137
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
vs.
CALVIN W. WILLIAMS III
Mortgagor(s) and Record Owner(s)
1508 Simpson Ferry Road
New Cumberland, PA 17070
Defendant(s
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Term
No. 09-5813civilterm
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: WILLIAMS III, CALVIN W.
CALVIN W. WILLIAMS 111
149 South Locust Point Road
Mechanicsburg, PA 17055
Your house at 1508 Simpson Ferry Road, New Cumberland, PA 17070 is scheduled to be sold at
Sheriffs Sale on Wednesday, March 03, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL
Courthouse to enforce the court judgment of $172,043.63 obtained by DEUTSCHE BANK NATIONAL
TRUST COMPANY, AS TRUSTEE FOR SAXON ASSET SECURITIES TRUST 2007-2 against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
r
09-5813civilterm
1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR SAXON ASSET SECURITIES TRUST 2007-2, the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay call: 215-825-6329 or
1-866413-2311.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
You may also be able to stop the sale through other legal proceedings.
4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIF'F'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
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 the Sheriff of 717-240-6390.
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 a 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 schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. 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 schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house 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
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
09-5813civilterm
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: or 717-243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website:
http://www.phfa.org/consumers/homeowners/real.gpx.
5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at homeretention(2goldbecklaw.com.
Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you
requested will be mailed to the address that you request or faxed if you leave a message
with that information. The attorney in charge of our firm's Homeowner Retention
Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418.
Please reference our Attorney File Number of 86134FC.
Para informacion en espanol puede communicarse con Loretta a1215-825-6344.
l ,r
09-5813civilterm
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney I.D.#56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6318
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR SAXON ASSET
SECURITIES TRUST 2007-2
4708 Mercantile Drive North
Fort Worth, TX 76137
Plaintiff
vs.
CALVIN W. WILLIAMS III
Mortgagor(s) and Record Owner(s)
1508 Simpson Ferry Road
New Cumberland, PA 17070
Defendant(s;
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Term
No. 09-5813civilterm
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: WILLIAMS III, CALVIN W.
CALVIN W. WILLIAMS 111
1508 Simpson Ferry Road
New Cumberland, PA 17070
Your house at 1508 Simpson Ferry Road, New Cumberland, PA 17070 is scheduled to be sold at
Sheriffs Sale on Wednesday, March 03, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL
Courthouse to enforce the court judgment of $172,043.63 obtained by DEUTSCHE BANK NATIONAL
TRUST COMPANY, AS TRUSTEE FOR SAXON ASSET SECURITIES TRUST 2007-2 against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
IN THE COURT OF COMMON PLEAS
To prevent this Sheriffs Sale you must take immediate action:
4
09-5813civilterm
1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR SAXON ASSET SECURITIES TRUST 2007-2, the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay call: 215-825-6329 or
1-866413-2311.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
You may also be able to stop the sale through other legal proceedings.
4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
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 the Sheriff of 717-240-6390.
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 a 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 schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. 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 schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house 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
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
4
09-5813civilterm
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: or 717-243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website:
hLtp://www.phfa.org/consumers/homeowners/real.gWx.
5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866413-2311 or via email at homeretentionkgoldbecklaw.com.
Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you
requested will be mailed to the address that you request or faxed if you leave a message
with that information. The attorney in charge of our firm's Homeowner Retention
Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418.
Please reference our Attorney File Number of 86134FC.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 09-5813 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY,
As Trustee for SAXON ASSET SECURITIES TRUST 2007-2, Plaintiff (s)
From CALVIN W. WILLIAMS III
(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 $172,043.63
L.L. $.50
Interest from 10/28/09 to Date of Sale per diem at $29.25 -- to be Determined
Atty's Comm % Due Prothy $2.00
Atty Paid $222.80 Other Costs
Plaintiff Paid
Date: 10/29/09
urtis R. Lo , r th not
(Seal) By:
REQUESTING PARTY:
Name: MICHAEL T. McKEEVER, ESQUIRE
Address: GOLDBECK McCAFFERTY & McKEEVER
SUITE 5000-MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Deputy
Supreme Court ID No. 56129
GOLDBECK McCAFFERTY 8~ McKEEVER
BY: Michael T. McKeever
Attorney I.D. #56129
Suite 5000 -Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
,.. .
T iL~E~-~~' ~~E
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2010 J~~~ i S °~ l ~ i7
.,
DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR SAXON ASSET SECURITIES
TRUST 2007-2
4708 Mercantile Drive North
Fort Worth, TX 76137
Plaintiff
vs.
CALVIN W. WILLIAMS III
1508 Simpson Ferry Road
New Cumberland, PA 17070
Defendant(s)
PRAECIPE TO VACATE JUDGN~NT
TO THE PROTHONOTARY:
No. 09-5813civilterm
Kindly vacate the judgment upon payment of your costs only.
r
C AEL T. MCKEEVER, ESQUIRE
~8, oo Pa ATN
C i~ 533(0'3
Q*' dy 3to~0
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
~ w
GOLDBECK McCAFFERTY & McKEEVER
ATTORNEY FOR PLAINTIFF
BY: Michael T. McKeever
Attorney LD. #56129
Suite 5000 -Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6321
-- - , ~ „r,,,r ~,r., ,,,,j~ ,,
rC..' ~.! `via ~ t_; r. ..H
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR SAXON
ASSET SECURITIES TRUST 2007-2
4708 Mercantile Drive North
Fort Worth, TX 76137
Plaintiff
vs.
CALVIN W. WILLIAMS III
1508 Simpson Ferry Road
New Cumberland, PA 17070
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
No. 09-5813civilterm
PRAECIPE TO DISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly mark the above case Discontinued and Ended upon payment of your costs only.
Michael T. McKeever, Esquire
Attorney for Plaintiff