HomeMy WebLinkAbout09-7116Martha E. Von Rosenstiel, P.C.
Martha E. Von Rosenstiel, Esquire
649 South Avenue, Unit #7
Secane, PA 19018
(610) 328-2887
Attorney I.D. #52634
U.S. BANK NATIONAL ASSOCIATION, AS
SUCCESSOR TRUSTEE TO BANK OF
AMERICA, NATIONAL ASSOCIATION, AS
SUCCESSOR BY MERGER TO LASALLE
BANK, N.A. AS TRUSTEE FOR THE MLMI
TRUST SERIES 2006-MLN1
14523 SW Millikan Way, Suite 200
Beaverton, OR 97005
PLAINTIFF
V.
MATTHEW J. GILBERT AND BETH A.
GILBERT
123 Holly Drive
Mechanicsburg, PA 17055
DEFENDANTS
25268CFC-DD
Attorney for Plaintiff
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
NO. 0q-17111o 0-t"a-Term
CIVIL ACTION - MORTGAGE FORECLOSURE
You have been sued in court. If you wish to defend against the claims
set forth in the following pages, you must take action within twenty
(20) days after this complaint and notice are served, by entering a
written appearance personally or by attorney and filing in writing with
the court your defenses or objections to the claims set forth against you.
You are warned that if you fail to do so the case may proceed without
you and a judgment may be entered against you by the court without
further notice for any money claimed in the complaint or for any other
claim or relief requested by the plaintiff. You may lose money or
property or other rights important to you
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT
ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT
HHtING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A
LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU
WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELEGIBLE PERSONS AT A
REDUCED FEE OR NO FEE
Le han demandado a usted en la corte. Si usted quiere defenderse de
estas demandas expuestas en las paginas siguientes, usted tiene
veinte (20) dial de plazo al partir de la fecha de la demanda y la
notificacion. Hace falta a sentar una comparencia escrita o en
persona o con un abogado y entregar a la corte en forma escrita sus
defensas o sus objeciones a las.demandas en contra de su persona.
Sea a visado que si usted no se defiende, la corte toma ra medidas y
puede continuar la demanda en contra suya sin previo aviso o
notificacion. Ademas, la corte puede decidir a favor del demandante
y requiere que usted cumpla con todas las provisioner de esta
demanda. Usted puede perder dinero o sus propiedades o otros de
rechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO
INMEDIATAMENTE. SI NO TIENE ABOGADO VAYA EN
PERSONA O TELEFONA A LA OFICINA ESCRITA ABAJO.
ESTA OFICINA LE PUEDE PROVEER INFORMACION
SOBRE COMO CONTRATAR A UN ABOGADO. SI USTED
NO TIENE EL DINERO SUFICIENTE PARA CONTRATAR A
UN ABOGADO, LE PODEMOS DAR INFORMACION
SOBRE AGENCIES QUE PROVEEN SERVICIO LEGAL A
PERSONAS ELEGIBLE PARA SERVICIOS A COSTO
REDUCIDO O GRATUITO
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
717-249-3166
800-990-9108
THIS IS AN ATTEMPT TO COLLECT A DEBT
ANY INFORMATION OBTAINED MAY BE
USED FOR THAT PURPOSE
IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS
OFFICE, BE ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15. U.S.C. §1692,
et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR
ANYT PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN
THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF
WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION
THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID.
LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS
PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME
AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE
THIRTY(30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE
SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES
THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION
WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME.
FURTHERMORE, NO REQQEST WILL BE MADE TO THE COURT FOR A
JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE
RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE
DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN
THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECFEIPT OF THIS
COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH
LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE
REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY
FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT.
IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT
AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON
REAL ESTATE.
Martha E. Von Rosenstiel, P.C.
Martha E. Von Rosenstiel, Esquire
649 South Avenue, Unit #7
25268CFC-DD
Attorney for Plaintiff
Secane, PA 19018
(610) 328-2887
Attorney I.D. #52634
U.S. BANK NATIONAL ASSOCIATION, AS
SUCCESSOR TRUSTEE TO BANK OF
AMERICA, NATIONAL ASSOCIATION, AS
SUCCESSOR BY MERGER TO LASALLE
BANK, N.A. AS TRUSTEE FOR THE MLMI
TRUST SERIES 2006-MLN1
14523 SW Millikan Way, Suite 200
Beaverton, OR 97005
PLAINTIFF
V.
MATTHEW J. GILBERT AND BETH A.
GILBERT
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
NO. 0 9- 7 I 1 G CLJ'Lt ! ?. .
123 Holly Drive
Mechanicsburg, PA 17055
DEFENDANTS
CIVIL ACTION - MORTGAGE FORECLOSURE
THIS IS AN ATTEMPT TO COLLECT A DEBT
ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE
1. Plaintiff is U.S. Bank National Association, as Successor Trustee to Bank of America,
National Association, as successor by merger to LaSalle Bank, N.A. as Trustee for the MLMI
Trust Series 2006-MLN1, a bank organized and existing under state law, with offices for the
conduct of business at 14523 SW Millikan Way, Suite 200, Beaverton, OR 97005.
2. Defendants, Matthew J. Gilbert and Beth A. Gilbert are the mortgagors and real
owners of premises 123 Holly Drive, Mechanicsburg, PA 17055, hereinafter described, whose
last known address is listed in the caption.
3. Plaintiff brings this action in mortgage foreclosure against defendants, mortgagors and
real owners, to foreclose a certain indenture of mortgage made, executed and delivered by the
above named defendants, mortgagors and real owners to Mortgage Electronic Registration
Systems, Inc. as Nominee for Mortgage Lenders Network on May 5, 2006, which mortgage is
recorded on May 10, 2006 in the Office of the Recorder of Deeds of Cumberland County in
Mortgage Record Book 1950, Page 832, secured on premises 123 Holly Drive, Mechanicsburg,
PA 17055 a true and correct description of which is attached hereto as Exhibit I.
4. The mortgage has since been assigned to the Plaintiff herein.
5. Plaintiff alleges each and every term, condition and covenant in the aforesaid
mortgage, and hereby incorporates them herein by reference thereto.
6. The aforesaid mortgage is in default in that monthly installments of principal and
interest have not been made in conformity with the terms of the mortgage, from June 2009 and
each month thereafter, up to and including the present time.
7. Under the terms of the aforesaid mortgage, upon default of payments set forth in the
mortgage documents, the entire principal balance and all interest due thereon are collectible
forthwith.
8. The following is an itemized statement of the amount due plaintiff under the terms of
the aforesaid mortgage:
Principal Balance $ 157,451.11
Interest from 5/1/2009 to 10/13/2009
at $35.37 per diem $ 5,871.42
Accrued late charges $ 3,085.81
Accrued Escrow deficit $ 14,023.30
Corporate Advances $ 167.00
Attorney's Fee (5% of unpaid
Principal balance) $ 7,872.56
Title Information Certificate $ 415.00
NSF Fee $ 40.00
Total $ 188,926.20
9. The attorney's fees set forth above are in conformity with the mortgage documents and
Pennsylvania Law and will be collected in the event of a third party purchaser at Sheriffs sale. If
the mortgage is reinstated prior to the Sheriffs sale, reasonable attorney's fees will be charged
based on work actually performed.
10. Plaintiff sent to defendants, mortgagors and real owners a combined Notice and
Warning of Intention to Foreclose and Notices of Homeowners' Emergency Mortgage Assistance
Act of 1983 advising of rights available under the statutes. To date payments have not been
received and Act 91 assistance has not been granted, although the applicable time periods
provided by statute have expired (Exhibit II).
WHEREFORE, plaintiff demands judgment for foreclosure and sale of the mortgaged
premises in the amount of $188,926.20, plus per diem interest at $35.37 from October 14, 2009
to the date of judgment plus costs thereon.
Martha E. Von Rosenstiel
Attorney for Plaintiff
VERIFICATION
MARTHA E. VON ROSENSTIEL, ESQUIRE, of full age, verifies that she is the
attorney for the plaintiff in the foregoing action; that she is authorized to make this verification
on behalf of plaintiff; and that the statements made in the foregoing Complaint in Mortgage
Foreclosure are true and correct to the best of her knowledge, information and belief.
This verification is being executed by the attorney for plaintiff in accordance with Pa
R.C.P. 1024( c ) as a signed verification could not be obtained by plaintiff within the time
allowed for filing of the pleading.
I understand that false statements herein are made subject to penalties of 18 Pa C.S.
Section 4904 relating to unsworn falsification to authorities.
Martha E. Von osens ie
Attorney for Plaintiff
LEGAL DESCRIPTION
ALL THAT CERTAIN lot or piece of ground with the improvements thereon erected, situate in
the Township of Upper Allen, County of Cumberland, and State of Pennsylvania, bounded and
described as follows:
BEGINNING at a point in the Southern line of Holly Drive (50 feet wide), which said point is in
the division line between Lots Nos. 76 and 77 on the hereinafter mentioned Plan of Lots; thence
along the Southern line of Holly Drive, North 65 degrees 24 minutes 40 seconds East, 90.00 feet
to a point in the division line between Lots Nos. 77 and 78 on said Plan; thence along the
division line between Lots Nos. 77 and 78, South 24 degrees 35 minutes 20 seconds East, 153.13
feet to a point; thence South 67 degrees 40 minutes 15 seconds West, 90.07 feet to a point in the
division line between Lots Nos. 76 and 77 on said Plan, aforementioned; thence along the
division line between Lots Nos. 76 and 77, North 24 degrees 35 minutes 20 seconds West,
149.58 feet to a point in the Southern line of Holly Drive, aforementioned, at the point and place
of Beginning.
BEING Lot No. 77, Section 5, Revised, of the Plan of Spring Run Acres, which Plan is recorded
in the Cumberland County Recorder's Office in Plan Book 20, Page 87.
HAVING THEREON ERECTED a brick and aluminum Dutch Colonial two-story dwelling
known and numbered as 123 Holly Drive, Mechanicsburg, Pennsylvania.
TAX PARCEL #42-28-2421-078
onNerr.o
Wilshire-
September 8, 2009
CERTIFIED RETURN RECEIPT AND REGULAR FIRST CLASS MAIL
LI78G
GILBERT, MATTHEW J
123 HOLLY DR
MECHANICSBURG, PA 17055
RE: Loan No.: 2619050
ACT 91 NOTICE
Phone
888.502.0100
Fax
503.952.7476
Website
https://www.wec.ml.com
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
(Continued)
YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION
PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE
OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE
COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE
http://www.ago.state.co.us/cadeicadcmain.cfm. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is
licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan
Way, Beaverton, OR. Wilshire's office hours are Monday - Friday 6:00 am to 5:00 pm Pacific time, holidays excluded.
L178G
Wilshire Credit Corporation
Payments
P.O. BOX 105344; Atlanta, GA 30348-5344
or P.O. Box 7195; Pasadena, CA 91109-7195
Correspondence
P.O. Box 8517; Portland, OR 97207-8517
GILBERT, MATTHEW J
Loan No.: 2619050
Page 2
September 8, 2009
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE
ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO
ESTA AGENCIA.(PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL
PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A
REDIMIR SU HIPOTECA.
HOMEOWNERS' NAME(S):
PROPERTY ADDRESS:
LOAN ACCT. NO.:
ORIGINAL LENDER:
CURRENT LENDER/SERVICER:
GILBERT, MATTHEW J
123 HOLLY DR
MECHANICSBURG, PA 170555527
2619050
Mortgage Lenders Network USA, Inc.
Wilshire Credit Corporation
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY
MORTGAGE ASSISTANCE:
• IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS, AND
(Continued)
YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION
PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE
OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE
COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE
http://www.ago.state.co.us/cadc/cademain.cfm. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is
licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan
Way, Beaverton, OR. Wilshire's office hours are Monday - Friday 6:00 am to 5:00 pm Pacific rime, holidays excluded.
L/ 78G
This Notice contains important legal information. If you have any questions,
representatives at the Consumer Credit Counseling Agency may be able to help explain it.
You may also want to contact an attorney in your area. The local bar association may be
able to help you find a lawyer.
GILBERT, MATTHEW J
Loan No.: 2619050
Page 3
September 8, 2009
• 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 consumer credit
counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN
THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE, 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. You must have a face-to-face meeting with one of the
designated consumer credit counseling agencies within thirty-three (33) calendar days.
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 Mortgage Assistance Program
Application with one of the designated consumer credit counseling agencies listed at the end of this Notice.
Only consumer credit counseling agencies have applications for the program and they will assist you in
submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender
from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty(30)
days of your face-to-face'meeting with the counseling agency.
YOU SHOULD FILE A HEMAP APPLICATION AS SOONAS POSSIBLE. IF YOU HA VE A MEETING WITH A
COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE JM FILE AN
APPLICATION WITHPHFA 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 FORCLOSURE'
YUU HAVE I. . K[c;HT "U t ILE A HEMP APPLILAI1UN EVEN BEYUND THESE TIME PE. IOD . A LATE
APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF
YOUR APPLICATION IS EVENTUALLYAPPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE
FORECLOSURE WILL BE STOPPED.
(Continued)
YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION
PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE
OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE
COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE
http://www.ago.state.co.us/cadc/cadcmain.cftn. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is
licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan
Way, Beaverton, OR. Wilshire's office hours are Monday - Friday 6:00 am to 5:00 pm Pacific time, holidays excluded.
Ll78G
GILBERT, MATTHEW J
Loan No.: 2619050
Page 4
September 8, 2009
AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be
disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance
Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure
proceedings will be pursued against you if you have met the time requirements set forth above. You will be
notified directly by the Pennsylvania Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE
FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE
CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(If you have 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:
123 HOLLY DR
MECHANICSBURG, PA 170555527
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following
amounts are now past due:
Your loan is delinquent for the following months: June 2009, July 2009, August 2009, September 2009
Past Due Installments: Totals
Principal $518.59
Interest 4,387.10
Escrow Installment 3,608.52
$8,514.21
Other Open Charges: Prior Servicer Charge WCC Char>ies
Late Charges $0.00 $2,931.66 $2,931.66
Returned Check Charge, 0.00 40.00 40.00
Speedpay Charges 0.00 15.00 15.00
Escrow Advance Interes 0.00 363.37 363.37
Property Inspections 0.00 22.00 22.00
Valuations 0.00 130.00 130.00
$3,502.03
(Continued)
YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION
PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE
OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE
COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE
http://www.ago.state.co.us/cade/cadcmain.cfm. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is
licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan
Way, Beaverton, OR. Wilshire's office hours are Monday - Friday 6:00 am to 5:00 pm Pacific time, holidays excluded.
L178G
GILBERT, MATTHEW J
Loan No.: 2619050
Page 5
September 8, 2009
Less Suspense (Balance)
$0.00
TOTAL $12,016.24
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
$12,016.24, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE
DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check,
certified check or money order made payable and sent to:
Wilshire Credit Corporation
P.O. Box 7195
Pasadena, CA 91109-7195
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the
date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt, This means that
the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to
pay the mortgage in monthly installments. If full payment of the total amount past due is not made within
THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your
mortgaged 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 begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that
were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay
all reasonable attorney's fees actually incurred by the lender even if they exceed $ 50.00. Any attorney's fees
will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the
default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees,
OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and
all other sums due under the mortgage.
T TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default
within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the
default and prevent the sale at any time up to one hour before the Sheriffs Sale You may do so by paying the
total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs
connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writine
by the lender, and by performing _anyother 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 SHERIFFS SALE DATE - It is estimated that the earliest date that such a Sheriffs
(Continued)
YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION
PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE
OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE
COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE
http://www.ago.state.co.us/cadc/cadcmain.cfm. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is
licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan
Way, Beaverton, OR. Wilshire's office hours are Monday - Friday 6:00 am to 5:00 pm Pacific time, holidays excluded.
L! 78G
GILBERT, MATTHEW J
Loan No.: 2619050
Page 6
September 8, 2009
Sale of the mortgaged property could be held would be approximately eight (8) months from the date of this
Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the
amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what
the required payment or action will be by contacting the lender/servicer.
rl.101?'Alllxklla Axe a It
Name of Lender/Servicer:
Address:
Phone Number:
Fax Number:
Contact Person(s):
E-Mail Address:
Wilshire Credit Corporation
P.O. Box 8517
Portland, OR 97207-8517
888.917.1050
503.946.3848
Holli Jennings or David Solomon
loanworkoutgeneral@wcc.mLcom
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 or X may not (CHECK ONE) sell or transfer your home to
a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and
attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are
satisfied.
YOU MAY ALSO 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
(Continued)
YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION
PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE
OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE
COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE
http://www.ago.state.co.us/eade/cadcmain.cfm. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is
licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan
Way, Beaverton, OR. Wilshire's office hours are Monday - Friday 6:00 am to 5:00 pm Pacific time, holidays excluded.
L! 78G
GILBERT, MATTHEW J
Loan No.: 2619050
Page 7
September 8, 2009
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.
Enclosed is a list of Consumer Credit Counseling Agencies serving your county.
Sincerely,
Wilshire Credit Corporation
Enclosures: PHFA list of HEMAP-approved agencies,How to Avoid Foreclosure
YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION
PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE
OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE
COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE
http://Www.ago.state.co.us/cadc/cadcmain.cfm. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is
licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan
Way, Beaverton, OR. Wilshire's office hours are Monday - Friday 6:00 am to 5:00 pm Pacific time, holidays excluded.
L 178G
MV 19h Wilshire-
United States Department of Housing and
Urban Development Servicemembers
Civil Relief Act Notice
Legal Rights and Protections Under the SCRA
Servicemembers on "active duty" or "active service," or a dependent of such a servicemember may be entitled to certain legal
protections and debt relief pursuant to the Servicemembers Civil Relief Act (50 U.S.C App. 501, et seq.) (SCRA).
Who May Be Entitled to Legal Protections Under the SCRA?
• Active duty members of the Army, Navy, Air Force, Marine Corps, Coast Guard, and active service National Guard;
• Active servicemembers of the commissioned corps of the National and Atmospheric Administration;
• Active servicemembers of the commissioned corps of the Public Health Service;
• United States citizens serving with the armed forces of a nation with which the United States is allied in the prosecution of a
war or military action; and
• Dependants of the above (e.g., spouse or children).
What Legal Protections Are Servicemembers Entitled to Under the SCRA?
The SCRA states that a debt incurred by a servicemember, or spouse jointly, prior to entering military service shall not bear
interest at a rate above 6 percent during the period of military service.
The SCRA states that in a legal action to enforce a debt against real estate that is filed during, or within 90 days after the
servicemember's military service, a court may stop the proceedings for a period of time, or adjust the debt. In addition, the
sale, foreclosure, or seizure of real estate shall not be valid if it occurs during, or within 90 days, after the servicemember's
military service unless the creditor has obtained a court order approving the sale, foreclosure, or seizure of the real estate.
How Does a Servicemember or Dependent Request Relief Under the SCRA?
• A servicemember or dependent, or both, may request relief under the SCRA by providing the lender/servicer a written notice
with a copy of the servicemember's military orders.
Wilshire Credit Corporation
P.O. Box 8517
Portland, OR 97207-8 5 1 7
How Does a Servicemember or Dependent Obtain Information About the SCRA?
• The U.S. Department of Defense's information resource is "Military One Source." Web site:
<http://www.militaryonesource.coin>. The toll-free telephone numbers for Military One Source are: From the United States:
1-800-342-9647. From outside the United States (with applicable access code): 800-342-9647-7. International Collect: 1-484-
530-5908.
• Servicemembers and dependents with questions about the SCRA should contact their unit's Judge Advocate, or their
installation's Legal Assistance Officer. A military legal assistance office locator for each branch of the armed forces is
available at: <http://legalassistance.law.af.mil/content/locator.Thn>.
YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION
PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE
OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE
COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE
http://www.ago.state.co.us/cadc/cadcmain.cfm. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is
licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan
Way, Beaverton, OR. Wilshire's office hours are Monday - Friday 6:00 am to 5:00 pm Pacific time, holidays excluded.
L 178G
W. Wilshire-
September 8, 2009
CERTIFIED RETURN RECEIPT AND REGULAR FIRST CLASS MAIL
L 178G
GILBERT, BETH A
123 HOLLY DR
MECHANICSBURG, PA 17055
RE: Loan No.: 2619050
ACT 91 NOTICE
Phone
888.502.0100
Fax
503.952.7476
Website
hftps://www.woc.mi.com
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
(Continued)
YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION
PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE
OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE
COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE
http://www.ago.state.co.us/cadc/cadcmain.cfn. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is
licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan
Way, Beaverton, OR. Wilshire's office hours are Monday - Friday 6:00 am to 5:00 pm Pacific time, holidays excluded.
L 178G
Wilshire Credit Corporation
Payments
P.O. BOX 105344; Atlanta, GA 30348-5344
or P.O. Box 7195; Pasadena, CA 91109-7195
Correspondence
P.O. Box 8517; Portland, OR 97207-8517
GILBERT, BETH A
Loan No.: 2619050
Page 2
September 8, 2009
LA NOTIFICACI6N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE
ESTA NOTIFICACI6N OBTENGA UNA TRADUCCI6N INMEDIATAMENTE LLAMANDO
ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL
PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A
REDIMIR SU HIPOTECA.
HOMEOWNERS' NAME(S):
PROPERTY ADDRESS:
LOAN ACCT. NO.:
ORIGINAL LENDER:
CURRENT LENDER/SERVICER:
GILBERT, BETH A
123 HOLLY DR
MECHANICSBURG, PA 170555527
2619050
Mortgage Lenders Network USA, Inc.
Wilshire Credit Corporation
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL A 15TANCE
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
(Continued)
YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION
PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE
OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE
COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE
http://www.ago.state.co.us/cadc/cadcmain.cfm. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is
licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan
Way, Beaverton, OR. Wilshire's office hours are Monday - Friday 6:00 am to 5:00 pm Pacific time, holidays excluded.
L178G
This Notice contains important legal information. If you have any questions,
representatives at the Consumer Credit Counseling Agency may be able to help explain it.
You may also want to contact an attorney in your area. The local bar association may be
able to help you find a lawyer.
GILBERT, BETH A
Loan No.: 2619050
Page 3
September 8, 2009
• 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 consumer credit
counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN
THIRTY-THREE (331 DAYS OF THE DATE OF THIS NOTICE, 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. You must have a face-to-face meeting with one of the
designated consumer credit counseling agencies within thirty-three (33) calendar days.
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 Mortgage Assistance Program
Application with one of the designated consumer credit counseling agencies listed at the end of this Notice.
Only consumer credit counseling agencies have applications for the program and they will assist you in
submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender
from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty(30)
days of your face-to-face meeting with the counseling agency.
YOU SHOULD FILE A HEMAP APPLICATION AS SOONAS POSSIBLE. IF YO U HA VE A MEETING WITH A
COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE fn FILE AN
APPLICATION WITHPHFA 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 FORCLOSURE ".
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 EVENTUALLYAPPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE
FORECLOSURE WILL BE STOPPED.
(Continued)
YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION
PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE
OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE
COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE
http://www.ago.state.co.us/eadc/cadcmain.cfm. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is
licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan
Way, Beaverton, OR. Wilshire's office hours are Monday - Friday 6:00 am to 5:00 pm Pacific time, holidays excluded.
LI78G
GILBERT, BETH A
Loan No.: 2619050
Page 4
September 8, 2009
AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be
disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance
Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure
proceedings will be pursued against you if you have met the time requirements set forth above. You will be
notified directly by the Pennsylvania Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE
FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE
CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (,Bring it up to datg j
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property
located at:
123 HOLLY DR
MECHANICSBURG, PA 170555527
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following
amounts are now past due:
Your loan is delinquent for the following months: June 2009, July 2009, August 2009, September 2009.
Past Due Installments: Totals
Principal $518.59
Interest 4,387.10
Escrow Installment 3,608.52
$8,514.21
Other Open Charges: Prior Servicer Charge WCC Charges
Late Charges $0.00 $2,931.66 $2,931.66
Returned Check Charge,, 0.00 40.00 40.00
Speedpay Charges 0.00 15.00 15.00
Escrow Advance Interes 0.00 363.37 363.37
Property Inspections 0.00 22.00 22.00
Valuations 0.00 130.00 130.00
$3,502.03
(Continued)
YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION
PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE
OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE
COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE
http://www.ago.state.co.us/cade/eademain.cfm. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is
licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan
Way, Beaverton, OR. Wilshire's office hours are Monday - Friday 6:00 am to 5:00 pm Pacific time, holidays excluded.
L 178G
GILBERT, BETH A
Loan No.: 2619050
Page 5
September 8, 2009
Less Suspense (Balance)
$0.00
TOTAL $12,016.24
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
$12,016.24, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE
DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check,
certified check or money order made payable and sent to:
Wilshire Credit Corporation
P.O. Box 7195
Pasadena, CA 91109-7195
IF YOU DO NOT CURE THE. DEFAUL - 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 u own your
mortgaged prollertY
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 begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that
were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay
all reasonable attorney's fees actually incurred by the lender even if they exceed $ 50.00. Any attorney's fees
will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the
default within the THIRTY (30) DAY period you will not be required to pa 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 SAL E - If you have not cured the default
within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the
default and prevent the sale at any time up to one hour before the Sheriffs Sale You may do so by 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
(Continued)
YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION
PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE
OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE
COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE
http://www.ago.state.co.us/cads/cadcmain.cfln. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is
licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan
Way, Beaverton, OR. Wilshire's office hours are Monday - Friday 6:00 am to 5:00 pm Pacific time, holidays excluded.
L / 78G
GILBERT, BETH A
Loan No.: 2619050
Page 6
September 8, 2009
Sale of the mortgaged property could be held would be approximately eight (8) months from the date of this
Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the
amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what
the required payment or action will be by contacting the lender/servicer.
HOW TO CONTACT THE LENDER/SERVICER:
Name of Lender/Servicer:
Address:
Phone Number:
Fax Number:
Contact Person(s):
E-Mail Address:
Wilshire Credit Corporation
P.O. Box 8517
Portland, OR 97207-8517
888.917.1050
503.946.3848
Holli Jennings or David Solomon
loanworkoutgeneral@wcc.ml.com
EFFECT OF SHERIFF'S 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 or X may not (CHECK ONE) sell or transfer your home to
a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and
attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are
satisfied.
YOU MAY ALSO 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
(Continued)
YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION
PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE
OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE
COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE
http://www.ago.state.co.us/cadc/cadcmain.cfm. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is
licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan
Way, Beaverton, OR. Wilshire's office hours are Monday - Friday 6:00 am to 5:00 pm Pacific time, holidays excluded.
LI78G
GILBERT, BETH A
Loan No.: 2619050
Page 7
September 8, 2009
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.
Enclosed is a list of Consumer Credit Counseling Agencies serving your county.
Sincerely,
Wilshire Credit Corporation
Enclosures: PHFA list of HEMAP-approved agencies,How to Avoid Foreclosure
YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION
PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE
OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE
COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE
http://www.ago.state.co.us/cade/cademain.cfn. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is
licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan
Way, Beaverton, OR. Wilshire's office hours are Monday - Friday 6:00 am to 5:00 pm Pacific time, holidays excluded.
L178G
MV ' Wilshire-
United States Department of Housing and
Urban Development Servicemembers
Civil Relief Act Notice
L eeal Rh!hts and Protections Under thg SCRA
Servicemembers on "active duty" or "active service," or a dependent of such a servicemember may be entitled to certain legal
protections and debt relief pursuant to the Servicemembers Civil Relief Act (50 U.S.C App. 501, et seq.) (SCRA).
Who May Be Entitled to Legal Protections Under the SCRA?
• Active duty members of the Army, Navy, Air Force, Marine Corps, Coast Guard, and active service National Guard;
• Active servicemembers of the commissioned corps of the National and Atmospheric Administration;
• Active servicemembers of the commissioned corps of the Public Health Service;
• United States citizens serving with the armed forces of a nation with which the United States is allied in the prosecution of a
war or military action; and
• Dependants of the above (e.g., spouse or children).
What Legal Protections Are Servicemembers Entitled to Under the SC A?
The SCRA states that a debt incurred by a servicemember, or spouse jointly, prior to entering military service shall not bear
interest at a rate above 6 percent during the period of military service.
The SCRA states that in a legal action to enforce a debt against real estate that is filed during, or within 90 days after the
servicemember's military service, a court may stop the proceedings for a period of time, or adjust the debt. In addition, the
sale, foreclosure, or seizure of real estate shall not be valid if it occurs during, or within 90 days, after the servicemember's
military service unless the creditor has obtained a court order approving the sale, foreclosure, or seizure of the real estate.
How Does a Servicemember or Dependent Request Relief Under the SCRA?
• A servicemember or dependent, or both, may request relief under the SCRA by providing the lender/servicer a written notice
With a copy of the servicemember's military orders.
Wilshire Credit Corporation
P.O. Box 8517
Portland, OR 97207-8517
How Does a Servicemember or Dependent Obtain Information About the 4C A?
• The U.S. Department of Defense's information resource is "Military One Source." Web site:
<Iittp://www.militaiyonesource.coin>. The toll-free telephone numbers for Military One Source are: From the United States:
1-800-342-9647. From outside the United States (with applicable access code): 800-342-9647-7. International Collect: 1-484-
530-5908.
• Servicemembers and dependents with questions about the SCRA should contact their unit's Judge Advocate, or their
installation's Legal Assistance Officer. A military legal assistance office locator for each branch of the armed forces is
available at: <:http://Ie?,yalassistance.law.af.niil/content/locator.ph --.
YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION
PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE
OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE
COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE
http://www.ago.state.co.us/cads/cadcmain.cfin. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is
licensed by the Collection Service Board of the Department of Commerce and Insurance. Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan
Way, Beaverton, OR. Wilshire's office hours are Monday - Friday 6:00 am to 5:00 pm Pacific time, holidays excluded.
L 178G
FILE' _.,-r,
THE IARY
2009 OCT 16 N 2: 2 0
( 1h
. +rjg .5o Pa ATtl
oZ3o21(o(o
Sheriffs Office of Cumberland County
FILED-tai ACE
R Thomas Kline OF THE PDCT# 101 OTM
Sheriff
f ??rta of ii ?t?brr?
Ronny R Anderson ` s 2009 OCT 29 AM 10: 18
Chief Deputy
`
Jody S Smith CU (J UNFIr r
Civil Process Sergeant aFIFIce OF THE swERIFF
Edward L Schorpp
Solicitor
US Bank National Association Case Number
vs. 2009-7116
Matthew J. Gilbert
SHERIFF'S RETURN OF SERVICE
10/27/2009 07:07 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on October 27,
2009 at 1907 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Beth A. Gilbert, by making known unto herself personally, at 123 Holly
Drive Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time
handing to her personally the said true and correct copy of the same.
10/27/2009 07:07 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on October 27,
2009 at 1907 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Matthew J. Gilbert, by making known unto Beth Gilbert, wife of defendant
at 123 Holly Drive Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same
time handing to her personally the said true and correct copy of the same.
SHERIFF COST: $53.00 SO ANSWERS, ?y
October 28, 2009 R THOMAS KLINE, SHERIFF
-?
Deputy heriff
MARTHA E. VON ROSENSTIEL, P.C.
Martha E. Von Rosenstiel, Esquire / No. 52634 PROTHONOTAR"(
Jacqueline F, McNally, Esquire / No. 201332'
649 South Avenue, Suite 7
Secane, PA 19018
(610) 328-2887
Attorneys for Plaintiff
U.S. BANK NATIONAL ASSOCIATION,
AS SUCCESSOR TRUSTEE TO BANK OF
AMERICA, NATIONAL ASSOCIATION,
AS SUCCESSOR BY MERGER TO
21112 FHB -9 AM 35
c,UMBENRLAND COUNTY
25268-CPG-JFM
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
LASALLE BANK, N.A. AS TRUSTEE FOR :
THE MLMI TRUST SERIES 2006-MLN1 Case No: 09 - 7116
Plaintiff
vs.
MATTHEW J. GILBERT AND BETH A.
GILBERT
Defendant(s)
PRAECIPE TO SUBSTITUTE ATTORNEY
TO THE PROTHONOTARY:
Kindly withdraw my appearance as attorney for the Plaintiff in the abov
Respectfully Submitted,
MARTHA E. VON RO;
P.C.
E. Von Rosenstiel, Esquire
Jacqueline F. McNally, Esquire
Attorneys for Plaintiff
Dated: January 11, 2012
TO THE PROTHONOTARY:
action.
Kindly enter my appearance as attorney for the Plaintiff in the above captioned action.
Dated: January 11, 2012
Respectfully Submitted,
MCCABE, WEISBERG & CONWAY, P.C.
' ??/C Gt/f
BY:
McCABE, WEISBERG, CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009
HEIDI R. SPIVAK, ESQUIRE - ID #74770
MARISA J. COHEN, ESQUIRE - ID # 87830
KEVIN T. McQUAIL, ESQUIRE - ID # 307169
CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480
BRIAN T. LaMANNA, ESQUIRE - ID # 310321
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
U.S. BANK NATIONAL ASSOCIATION,
AS SUCCESSOR TRUSTEE TO BANK OF
AMERICA, NATIONAL ASSOCIATION,
AS SUCCESSOR BY MERGER TO
LASALLE BANK, N.A. AS TRUSTEE FOR
THE MLMI TRUST SERIES 2006-MLNl
Plaintiff
VS.
MATTHEW J. GILBERT AND BETH A.
GILBERT
Defendants
Attorneys for Plaintiff
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Case No. 09-7116
CERTIFICATE OF SERVICE
I, MARC S. WEISBERG, Esquire, Attorney for Plaintiff, hereby certifies that a true and correct
copy of the within Praecipe to Substitute Attorney was served on the below parties on the day of
February, 2012, by the United States mail, first class:
Matthew J. Gilbert
Beth A. Gilbert
123 Holly Drive
Mechanicsburg, PA 17055
DATE: I ?L
MAR S. WEISBERG, ESQUIRE
Attorney for Plaintiff
U.S. BANK, NATIONAL ASSOCIATION,
AS SUCCESSOR TRUSTEE TO BANK
OF AMERICA, NATIONAL
ASSOCIATION, AS SUCCESSOR BY IN THE COURT OF COMMON PLEAS
MERGER TO LASALLE BANK, N.A. OF THE NINTH JUDICIAL DISTRICT
AS TRUSTEE FOR THE OF MLMI
TRUST, SERIES 2006-MLN1
Plaintiff
V.
MATTHEW J. GILBERT AND
BETH A. GILBERT
Defendants 2009-07116 CIVIL TERM
IN RE: PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT
BEFORE HESS, P.J., MASLAND, AND PLACEY, J.J.
ORDER OF COURT
AND NOW, this 4th day of April 2013, upon consideration of Plaintiffs Motion for
Summary Judgment and the accompanying memorandum, together with a review of the
Complaint, Defendant's answer that is a letter filed with the Court indicating an attempt
to participate in a "Home Affordable Modification Trial Period Plan"; and no brief or
response to this Motion, the Motion for Summary Judgment in Mortgage Foreclosure is
GRANTED.
Judgment is entered against Defendant's in the amount stated in Plaintiffs
Affidavit, $205,101.43, together with interest at a rate of$35.0678 per day from 17
August 2012 to the entry of judgment, plus costs and interest from the date of judgment
as provided by law.
BY THE COURT,
Thomas A. I cey C.P.J.
Distribution:
Marc S. Weisberg, Esq.
Matthew J. Gilbert �.
d' Beth A. Gilbert _
Court Administrator-
/gnu,lean / �--<-.> 1 `
>C*� CD'
McCABE,WEISBERG AND CONWAY,P.C.
BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff
MARC S.WEISBERG,ESQUIRE-ID# 17616
EDWARD D.CONWAY,ESQUIRE -ID#34687
MARGARET GAIRO,ESQUIRE-ID# 34419
ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009
HEIDI R.SPIVAK,ESQUIRE-ID#74770 fiv j
MARISA J.COHEN,ESQUIRE-ID#87830 '�'l j" 1' f 1
CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 � i;y
ANN E.SWAB ZESQUIRE-ID#0 926 321 � Ehf�t'$}'LVAt��Nr}'
JOSEPH F.RIGA,ESQUIRE-ID#57716
JOSEPH I.FOLEY,ESQUIRE-ID#314675
CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673
JENNIFER L.WUNDER,ESQUIRE-ID#315954
LENA KRAVETS,ESQUIRE-ID#316421
123 South Broad Street,Suite 1400
Philadelphia,Pennsylvania 19109
215 790-1010
U.S.Bank,National Association,as Successor Trustee to CUMBERLAND COUNTY
Bank of America,N.A.,as Successor by Merger to COURT OF COMMON PLEAS
Lasalle Bank,N.A.,as Trustee for the Certificateholders
of the MLMI Trust,Mortgage Loan Asset-Backed
Certificates,Series 2006-MLN1
Plaintiff Number 2009-07116
V.
Matthew J.Gilbert and Beth A.Gilbert
Defendants
ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT
TO THE PROTHONOTARY:
Kindly enter judgment in favor of Plaintiff and against Defendants,Matthew J.Gilbert and Beth A.Gilbert,in the
above-captioned matter as set forth in the attached Order dated April 4,2013 and assess damages as follows:
Amount Due $205,101.43
Interest from 8/18/12 to 2/17/14
per diem thereafter$35.0678 $ 19,252.22
Total $224,353.65
Mc=McCabe, Q CONWAY,P.C.
BY: [ Marc S.Wei erg,Esq.
[ ]Edward D.Conway,Esq. [ ]Margaret Gairo,Esq.
[ ]Andrew L.Markowitz,Esq. [ ]Heidi R.Spivak,Esq.
[ ]Marisa J.Cohen,Esq. [ ]Christine L.Graham,Esq.
[ ]Brian T.LaManna,Esq. [ ]Ann E.Swartz,Esq.
[ ]Joseph F.Riga,Esq. [ ]Joseph I.Foley,Esq.
[ ]Celine P.DerKrikorian,Esq. [ ]Jennifer L.Wunder,Esquire
[ ]Lena Kravets,Esquire
Attorneys for Plaintiff
AND NOW, this O day of I y� , 2014, Judgment is entered in favor of Plaintiff, U.S. Bank,
National Association,as Successor Trustee to Bank of America,N.A.,as Successor by Merger to Lasalle Bank,N.A.,as
Trustee for the Certificateholders of the MLMI Trust,Mortgage Loan Asset-Backed Certificates,Series 2006-MLNI,and
against Defendants,Matthew J.Gilbert and Beth A.Gilbert,in rem only and not in personam,and damages are assessed in
the amount of$224,95+6�,plus interest and costs. awl
6
'Po5 J bi. 3 BY PRO
Y. c� } �$�I 33
�- ' red
McCABE,WEISBERG AND CONWAY,P.C.
BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff
MARC S.WEISBERG,ESQUIRE-ID# 17616
EDWARD D.CONWAY,ESQUIRE -ID#34687
MARGARET GAIRO,ESQUIRE-ID# 34419
ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009
HEIDI R. SPIVAK,ESQUIRE-ID#74770
MARISA J.COHEN,ESQUIRE-ID#87830
CHRISTINE L.GRAHAM,ESQUIRE-ID#309480
BRIAN T.LAMANNA,ESQUIRE-ID#310321
ANN E. SWARTZ,ESQUIRE-ID#201926
JOSEPH F.RIGA,ESQUIRE-ID#57716
JOSEPH I.FOLEY,ESQUIRE-ID#314675
CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673
JENNIFER L.WUNDER,ESQUIRE-ID#315954
LENA KRAVETS,ESQUIRE-ID#316421
123 South Broad Street, Suite 1400
Philadelphia,Pennsylvania 19109
215 790-1010
U.S.Bank,National Association,as Successor Trustee CUMBERLAND COUNTY
to Bank of America,N.A.,as Successor by Merger to COURT OF COMMON PLEAS
Lasalle Bank,N.A.,as Trustee for the
Certificateholders of the MLMI Trust,Mortgage Loan Number 2009-07116
Asset-Backed Certificates, Series 2006-MLN1
Plaintiff
v.
Matthew J.Gilbert and Beth A.Gilbert
Defendants
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA:
SS.
COUNTY OF PHILADELPHIA:
The undersigned,being duly sworn according to law,deposes and says that the Defendants,Matthew J.Gilbert
and Beth A.Gilbert, are not in the Military or Naval Service of the United States or its Allies,or otherwise within the
provisions of the Servicemembers Civil Relief Act,50 U.S.C.App. §501,et seq.;and that the Defendants,Matthew J.
Gilbert and Beth A.Gilbert,are over eighteen(18)years of age,and reside as follows:
Matthew J.Gilbert,
123 Holly Drive
Mechanicsburg,PA 17055
Beth A.Gilbert,
123 Holly Drive
Mechanicsburg,PA 17055
MCCABE,WEISBERG CONWAY, .C.
SWORN AND SUBSCRIBED P
BY:
BEFORE ME THIS AL DAY [ ]Terrence J.McCabe,Esq. [ arc S.Weisberg,Esq.
[ ]Edward D.Conway,Esq. [ ]Margaret Gairo,Esq.
OF 2014 [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq.
Marisa J.Cohen,Esq. [ ]Christine L.Graham,Esq.
[ ]Brian T.LaManna,Esq. [ ]Ann E. Swartz,Esq.
NOTARY PUBLIC [ ]Joseph F.Riga,Esq. [ ]Joseph I.Foley,Esq.
COMMONWEALTH OF PENNSYLVANIA [ ]Celine P.DerKrikorian,Esq. [ ]Jennifer L.Wunder,Esquire
NOT4RlAL SEAL [ ]Lena Kravets,Esquire
DEAN R.JACOBS JR.,Notary Public Attorneys for Plaintiff
City of Philadeiphla,r hila.County
My Commission Expires June 27,2017
Department of Defense Manpower Data Center Results as of:Fab-19-201406:57:17 AM
SCRA 3.0
Status Ropwt
Pursuant to Savicemenibers Civil Relief Act
Last Name: GILBERT
First Name: MATTHEW
Middle Name: J.
Active Duty Status As Of: Feb-19-2014
On Active Duty On AcNal Duty status Date
"a Start Date Active Duty End Date Statue Servksa Cam t
NA NA Na 4, NA
This response reflects the 1tWividuaW aotfve duty status based on the Aar Du Status Date
S
left Active Wfthln 367 Dwya of Active Duty Statue Date
Active D Start Date Active , End Data': Statue Servka Can rant
NA NA NA
This response reflects where 1h6anclMdual left active d status wlihln 3LTdays precedi!V theIA44"'6uty Status Date
The Member or Me/Her Lit Was Nogfled of a Future Call-Up ro Active Duty'on Active D` Status Date
Order Notification Start Date Order Notiflcadw End Dais Status Service Dcrru ponen t
NA ..tits... ' "ti` NA
This response reflects whet U-1,111 or histherlihit has received earl tYt4tlif$et�h to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
A 4%,i#47_44�
Mary M.Snavely-Dixon,Director
Department of Defense-Manpower Data Center
4800 Mark Center Drive,Suite 04E25
Arlington,VA 22350
The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility
Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 at seq,as amended)(SCRA)(formerly known as
the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the
individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family
member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the
protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil"URL:http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status
date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c).
This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active
duty on the Active Duty Status Date.
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve
Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps).
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1).
Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not
actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA
are protected
WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.
Certificate ID: 77G2PD98T020N20
Department of Defense Manpower Data Center Results as of:Feb-19-2014 06:59:04 AM
SCRA 3.0
40 19%WS Repw
Pmu mt to SmTkemembers Civfl Relief Act
Last Name: GILBERT
First Name: BETH
Middle Name: A.
Active Duty Status As Of: Feb-19-2014
k1 Activa Ou Qn AcMve Status Date 7
Active Du Start Date Active End Date,' Statue 8ervk Componen t
JO '_ NA
NA NA
This response re%g§the Individuals'active du status based on the ActWe DuT status Date
Left Active Within 367 Days of Aetive Du status bete
Active Duty Date Active Duty End Date' Statue Servke GeH11 t
NA t 71) (�NA _ o NA
This response reflects Where ihBindi4ldual left active �af us w4;06X'a di the ctive'Du Status Date
E �
This Member or Hls/Ner Unit Was Notirted of a Future celWip to Active on Active 6uty. 318tus beta
Order Notiflcatkm Start Date Order Notlflcatbn End Date status service climpovht
NA 3 .Nd' aury,'r NA
b
This response reflects whether the it dK4dual or his/herYunit has reaefved earl notifloadon to report for active duty
-
Upon searching the data banks of the Department of Defense Manpower Qeta tenter,based on the information that you provided,the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
Y)Iaot )4. LA.A.01.
7"'lill
t
Mary M.Snavely-Dixon,Director
Department of Defense-Manpower Data Center
4800 Mark Center Drive,Suite 04E25
Arlington,VA 22350
The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility
Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 at seq,as amended)(SCRA)(formerly known as
the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the
individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family
member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the
protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil"URL:hftp://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status
date and you fail to obtain this additional Service verification,punitive provisions of the SCRA maybe invoked against you. See 50 USC App.§521(c).
This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active
duty on the Active Duty Status Date.
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve
Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps).
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1).
Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not
actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA
are protected
WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.
Certificate ID: 87WE3DC8R020F70
McCABE,WEISBERG AND CONWAY,P.C.
BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff
MARC S.WEISBERG,ESQUIRE-ID# 17616
EDWARD D.CONWAY,ESQUIRE -ID#34687
MARGARET GAIRO,ESQUIRE-ID# 34419
ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009
HEIDI R. SPIVAK,ESQUIRE-ID#74770
MARISA J.COHEN,ESQUIRE-ID#87830
CHRISTINE L.GRAHAM,ESQUIRE-ID#309480
BRIAN T.LAMANNA,ESQUIRE-ID#310321
ANN E. SWARTZ,ESQUIRE-ID#201926
JOSEPH F.RIGA,ESQUIRE-ID#57716
JOSEPH I.FOLEY,ESQUIRE-ID#314675
CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673
JENNIFER L.WUNDER,ESQUIRE-ID#315954
LENA KRAVETS,ESQUIRE-ID#316421
123 South Broad Street,Suite 1400
Philadelphia,Pennsylvania 19109
215 790-1010
U.S.Bank,National Association,as Successor Trustee COURT OF COMMON PLEAS
to Bank of America,N.A.,as Successor by Merger to CUMBERLAND COUNTY
Lasalle Bank,N.A.,as Trustee for the
Certificateholders of the MLMI Trust,Mortgage Loan Number 2009-07116
Asset-Backed Certificates,Series 2006-MLN1
Plaintiff
V.
Matthew J.Gilbert and Beth A.Gilbert
Defendants
AFFIDAVIT OF LAST-KNOWN MAILING ADDRESS OF DEFENDANTS
COMMONWEALTH OF PENNSYLVANIA:
SS.
COUNTY OF PHILADELPHIA:
The undersigned attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby
deposes and says that the last-known mailing addresses of the Defendants are:
Matthew J.Gilbert
123 Holly Drive
Mechanicsburg,Pennsylvania 17055
Beth A.Gilbert
123 Holly Drive
Mechanicsburg,Pennsylvania 17055
McCABE,W SBERG AND CO AY,P.C.
SWORN AND SUBSCRIBED
BY: u/2
BEFORE ME THIS 11 to DAY [ ] Terrence J.McCabe,Esq. [` Marc S. W sberg,Esq.
[ ]Edward D.Conway,Esq. [ ]Margaret Gairo,Esq.
OF �is��s'1 ,2014 [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq.
n [ ]Marisa J.Cohen,Esq. [ ] Christine L.Graham,Esq.
Brian T.LaManna,Esq. [ ]Ann E. Swartz,Esq.
NOTARY PUBLIC [ ]Joseph F.Riga,Esq. [ ]Joseph I.Foley,Esq.
COMMONWEALTH OF PENNSYLVANIA [ ]Celine P.DerKrikorian,Esq. [ ]Jennifer L.Wunder,Esquire
NOTANAL SEAL [ ]Lena Kravets,Esquire
DEAN R.JACOBS,-A.,Notary Public Attorneys for Plaintiff
City of Philadelphia,, ila.County
My Commission Expires June 27,2017
VERIFICATION
The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action,
and that he/she is authorized to make this verification and that the foregoing facts based on the information from the
Plaintiffs representative,who is out of jurisdiction and not available to sign this verification at this time,are true and
correct to the best of his/her knowledge,information and belief and further states that false statements herein are
made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities.
McCABE,WEISBEPp AND C NWAY P.C.
BY: C'
[ ] Terrence J.McCabe,Esq. [ arc S.Weisber ,Esq.
[ ]Edward D.Conway,Esq. [ ]Margaret Gairo;Esq.
[ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq.
[ ]Marisa J.Cohen,Esq. [ ]Christine L.Graham,Esq.
[ ]Brian T.LaMantia,Esq. [ ]Ann E. Swartz,Esq.
[ ]Joseph F.Riga,Esq. [ ]Joseph I.Foley,Esq.
[ ]Celine P.DerKrikorian,Esq. [ ]Jennifer L.Wunder,Esquire
[ ]Lena Kravets,Esquire
Attorneys for Plaintiff
U.S.Bank,National Association,as Successor Trustee to Bank of America,N.A.,as Successor by Merger to Lasalle Bank,N.A.,
as Trustee for the Certificateholders of the MLMI Trust,Mortgage Loan Asset-Backed Certificates,Series 2006-MLN1 v.
Matthew J.Gilbert and Beth A.Gilbert
Cumberland County;Number: 2009-07116
U.S. BANK, NATIONAL ASSOCIATION,
AS SUCCESSOR TRUSTEE TO BANK
OF AMERICA, NATIONAL
ASSOCIATION, AS SUCCESSOR BY IN THE COURT OF COMMON PLEAS
MERGER TO LASALLE BANK, N.A. OF THE NINTH JUDICIAL DISTRICT
AS TRUSTEE FOR THE OF MLMI
TRUST, SERIES 2006-MLN1
Plaintiff
V.
MATTHEW J. GILBERT AND
BETH A. GILBERT
Defendants 2009-07116 CIVIL TERM
IN RE: PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT
BEFORE HESS, P.J., MASLAND, AND PLACEY, J.J.
ORDER OF COURT
AND NOW, this 4th day of April 2013, upon consideration of Plaintiffs Motion for
Summary Judgment and the accompanying memorandum, together with a review of the
Complaint, Defendant's answer that is a letter filed with the Court indicating an attempt
to participate in a "Home Affordable Modification Trial Period Plan"; and no brief or
response to this Motion, the Motion for Summary Judgment in Mortgage Foreclosure is
GRANTED.
Judgment is entered against Defendant's in the amount stated in Plaintiffs
Affidavit, $205,101.43, together with interest at a rate of$35.0678 per day from 17
August 2012 to the entry of judgment, plus costs and interest from the date of judgment
as provided by law.
BY THE COURT,
Thomas A. 1 cey C.P.J.
Distribution:
c
Marc S. Weisberg, Esq. rn Cp
Matthew J. Gilbert
Beth A. Gilbert '
Court Administrator �Cc
^r
r Cn -
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
Cumberland County Courthouse
Carlisle,Pennsylvania 17013
Prothonotary
To: Matthew J.Gilbert
123 Holly Drive
Mechanicsburg,Pennsylvania 17055
U.S.Bank,National Association,as Successor Trustee
to Bank of America,N.A.,as Successor by Merger to COURT OF COMMON PLEAS
Lasalle Bank,N.A.,as Trustee for the CUMBERLAND COUNTY
Certificateholders of the MLMI Trust,Mortgage Loan
Asset-Backed Certificates, Series 2006-MLN1
Plaintiff No.2009-07116
V.
Matthew J.Gilbert and Beth A.Gilbert
Defendants
NOTICE
Pursuant to Rule 236,you are hereby notified that a JUDGMENT h een a ed in bove proceed'
as indicated below.
Protho
X Judgment by Court Order oldl l-/u
Money Judgment
Judgment in Replevin
Judgment for Possession
If you have any questions concerning this Judgment,please call McCabe,Weisberg and Conway,
P.C.at(215)790-1010.
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
Cumberland County Courthouse
Carlisle,Pennsylvania 17013
Prothonotary
To: Beth A.Gilbert
123 Holly Drive
Mechanicsburg,Pennsylvania 17055
U.S.Bank,National Association,as Successor Trustee
to Bank of America,N.A.,as Successor by Merger to COURT OF COMMON PLEAS
Lasalle Bank,N.A.,as Trustee for the CUMBERLAND COUNTY
Certificateholders of the MLMI Trust,Mortgage Loan
Asset-Backed Certificates, Series 2006-MLN1
Plaintiff No.2009-07116
V.
Matthew J.Gilbert and Beth A.Gilbert
Defendants
NOTICE
Pursuant to Rule 236,you are hereby notified that a JUDGMENT has been entered in the above proceeding
as indicated below.
Prothonotary
.4
X Judgment by Court Order
Money Judgment
Judgment in Replevin
Judgment for Possession
If you have any questions concerning this Judgment,please call McCabe,Weisberg and Conway,
P.C.at(215)790-1010.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
CIVIL DIVISION
FILE NO.:2009-07116 Civil Term C_3
U.S.Bank,National Association,as Successor =' F
Trustee to Bank of America,N.A.,as Successor by AMOUNT DUE: $22�`T� �,
Merger to Lasalle Bank,N.A.,as Trustee for the a05,101.43 I—
Certificateholders of the MLMI Trust,Mortgage INTEREST:from 02/18/14
Loan Asset-Backed Certificates,Series 2006-MLN1 $3,946.16 at$36.88 e ~
V. ATTY'S COMW ,b �Il�1
.11n�teSA moo" `e
Matthew J.Gilbert and Beth A.Gilbert COSTS: 3S.0to1 — 19,7S a•�
aa-
TO THE PROTHONOTARY OF SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail installment sale,contract,or account based on
a confession of judgment,but if it does,it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as
amended;and for real property pursuant to Act 6 of 1974 as amended.
PRAECIPE FOR EXECUTION
Issue writ or execution in the above matter to the Sheriff of Cumberland County,for debt,interest and costs upon the
following described property of the defendant(s)
123 Holly Drive Mechanicsburg Pennsylvania 17055
(More fully described as attached)
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of CUMBERLAND County,for debt,interest and costs,as above,directing
attachment against the above-named gamishee(s)for the following property(if real estate,supply six copies of the
description;supply four copies of lengthy personalty list)
and all other property of the defendant(s)in the possession,custody or control of the said gamishee(s).
(Indicate)Index this writ against the garnishee(s)as a lis pendens against real estate of the defendant(s)
described in the attached exhibit.
eb �DATE: l ` I 1 BY:
U [ ]Terrence f McCabe,Esq. arc S.Weisberg,Esq.
�$ cs "\q Q [ ]Edward D.Conway,Esq. [ ]Margaret Gairo,Esq.
�l S3• DO C [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq.
[ ]Marisa J.Cohen,Esq. [ ]Kevin T.McQuail,Esq.
C D. Lt [ ]Christine L.Graham,Esq. [ ]Brian T.LaManna,Esq.
l 4 `1
[ ]Ann E.Swartz,Esq. [ ]Joseph F.Riga,Esq.
Ia 1 Joseph L Foley,Esq. [ ]Celine P.DerKrikorian,Esq.
- t ti Attorneys for Plaintiff
Address:123 S.Broad Street.Suite 1400
t ' CC> a aS—ZXU 1Z Philadelphia,PA 19109
' Attorney for:Plaintiff
�u Telephone:(215)790 1010
g^ upreme Court ID No. 17616
LEGAL DESCRIPTION
ALL THAT CERTAIN lot or piece of ground with the improvements thereon erected,situate in the Township of
Upper Ellen,County of Cumberland,and State of Pennsylvania,bounded and described as follows:
BEGINNING at a point in the southern line of Holly Drive(50 feet wide),which said point is in the division line
between lots Nos.76 and 77 on the hereinafter mentioned Plan of Lots;thence along the Southern line of Holly Drive,
North 65 degrees 24 minutes,40 seconds East,90.00 feet to a point in the division line between Lots Nos.77 and 78 on
said Plan;thence along the division line between Lots Nos.77 and 78, South 24 degrees 35 minutes 20 seconds East,
153.13 feet to a point;thence South 67 degrees 40 minutes 15 seconds West,90.07 feet to a point in the division line
between Lots Nos. 76 and 77 on said Plan,aforementioned;thence along the division line between Lots Nos.76 and 77,
North 24 degrees 35 minutes 20 seconds West, 149.58 feet to a point in the southern line of Holly Drive,aforementioned,
at the point and place of BEGINNING.
BEING Lot No.77,Section 5,Revised,of the Plan of Spring Run Acres,which Plan is recorded in the
Cumberland County Recorder's Office in Plan Book 20,Page 87.
HAVING THEREON ERECTED a brick and aluminum Dutch Colonial two-story dwelling known and numbered as 123
Holly Drive,Mechanicsburg,Pennsylvania.
UNDER AND SUBJECT,NEVERTHELESS,to easements,restrictions,reservations,conditions and rights-of-way of
record.
BEING the same premises which SHIRLENE L.ROSEMAN,WIDOW by deed dated May 5,2006 and recorded May 10,
2006 in the office of the Recorder in and for Cumberland County in Deed Book 274,Page 2333,granted and conveyed to
Matthew J.Gilbert and Beth A.Gilbert,husband and wife.
TAX MAP PARCEL NUMBER:42-28-2421-078
McCABE,WEISBERG AND CONWAY,P.C.
BY: TERRENCE J.McCABE,ESQUIRE-ID#16496 Attorneys for Plaintiff
MARC S.WEISBERG,ESQUIRE-ID#17616
EDWARD D.CONWAY,ESQUIRE -ID#34687
MARGARET GAIRO,ESQUIRE-ID# 34419 17
ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009
HEIDI R.SPIVAK,ESQUIRE-ID#74770
MARISA J.COHEN,ESQUIRE-ID#87830
KEVIN T.McQUAIL,ESQUIRE-ID#307169 -
CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 _ j5
BRIAN T.LaMANNA,ESQUIRE-ID#310321 t u
ANN E.SWARTZ,ESQUIRE-ID#201926 L
JOSEPH F.RIGA,ESQUIRE-ID#57716
JOSEPH I.FOLEY,ESQUIRE-ID#314675 .a f
CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673
�P
123 South Broad Street,Suite 1400
Philadelphia,Pennsylvania 19109
215 790-1010
U.S.Bank,National Association,as Successor Trustee CUMBERLAND COUNTY
to Bank of America,N.A.,as Successor by Merger to COURT OF COMMON PLEAS
Lasalle Bank,N.A.,as Trustee for the
Certificateholders of the MLMI Trust,Mortgage Loan
Asset-Backed Certificates, Series 2006-MLN1 NO: 2009-07116
Plaintiff
v.
Matthew J.Gilbert and Beth A.Gilbert
Defendants
AFFIDAVIT PURSUANT TO RULE 3129
The undersigned,attorney for Plaintiff in the above action,sets forth the following information concerning
the real property located at: 123 Holly Drive,Mechanicsburg,Pennsylvania 17055,as of the date the Praecipe for
the Writ of Execution was filed.A copy of the description of said property being attached hereto.
1. Name and address of Owners or Reputed Owners
Name Address
Matthew J.Gilbert 123 Holly Drive
Mechanicsburg,Pennsylvania 17055
Beth A.Gilbert 123 Holly Drive
Mechanicsburg,Pennsylvania 17055
2. Name and address of Defendants in the judgment:
Name Address
Matthew J.Gilbert 123 Holly Drive
Mechanicsburg,Pennsylvania 17055
Beth A.Gilbert 123 Holly Drive
Mechanicsburg,Pennsylvania 17055
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
Plaintiff herein
Restore Core 2322 North 7th Street
Harrisburg,Pennsylvania 17110
4. Name and address of the last recorded holder of every mortgage of record:
Name Address
Plaintiff herein
5. Name and address of every other person who has any record lien on the property:
Name Address
None
6. Name and address of every other person who has any record interest in the property which may be
affected by the sale:
Name Address
None
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:
Name Address
Tenants/Occupants 123 Holly Drive
Mechanicsburg,Pennsylvania 17055
Commonwealth of Pennsylvania Department of Public Welfare
Bureau of Child Support Enforcement
P.O.Box 2675
Harrisburg,PA 17105
ATTN:Dan Richard
Commonwealth of Pennsylvania 110 North P Street
Inheritance Tax Office Suite#204
Philadelphia,PA 19107
Commonwealth of Pennsylvania 6th Floor,Strawberry Square
Bureau of Individual Tax Department#280601
Inheritance Tax Division Harrisburg,PA 17128
Department of Public Welfare Willow Oak Building
TPL Casualty Unit Estate P.O.Box 8486
Recovery Program Harrisburg,PA 17105-8486
PA Department of Revenue Bureau of Compliance
P.O.Box 281230
Harrisburg,PA 17128-1230
PA Department of Revenue PO BOX 280948
Bureau of Compliance Harrisburg PA 17128-0948
Lien Section
Commonwealth of Pennsylvania Clearance Support Department 281230
Department of Revenue Bureau of Harrisburg,PA 17128-1230
Compliance ATTN: Sheriffs Sales
United States of America Internal Revenue Service
Technical Support Group
William Green Federal Building
Room 3259
600 Arch Street
Philadelphia,PA 19106
Domestic Relations P.O.Box 320
Cumberland County Carlisle,PA 17013
Tax Claim Bureau 1 Courthouse Square
Carlise,PA 17013
Commonwealth of PA Bureau of Compliance
Department of Revenue Department 280946
Harrisburg,PA 17128-0946
Attn: Sheriffs Sales
United States of America c/o United States Attorney for the
Middle District of PA
William J.Nealon Federal Bldg.
235 North Washington Avenue,Ste.311
Scranton,PA 18503
and
Harrisburg Federal Building&Courthouse
228 Walnut Street, Ste.220
Harrisburg,PA 17108-1754
United States of America c/o U.S.Dept of Justice,Room 5111
Atty General of the United States 950 Pennsylvania Avenue NW
Washington,DC 20530-0001
United States of America c/o U.S.Dept of Justice,Room 4400
Atty General of the United States 950 Pennsylvania Avenue NW
Washington,DC 20530-0001
8. Name and address of Attorney of record:
Name Address
None
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.
BY: N
q [ ]Terrence J.fAcCabe,Esq. [ arc S.Weisberg,Esq.
bJkTE [ ] Edward D.Conway,Esq. [ ] Margaret Gairo,Esq.
[ ] Andrew L.Markowitz,Esq. [ ] Heidi R.Spivak,Esq.
[ ] Marisa J.Cohen,Esq. [ ] Kevin T.McQuail,Esq.
[ ] Christine L.Graham,Esq. [ ] Brian T.LaManna,Esq.
[ ] Ann E.Swartz,Esq. [ ]Joseph F.Riga,Esq.
[ ]Joseph I.Foley,Esq. [ ] Celine P.DerKrikorian,Esq.
Attorneys for Plaintiff
LEGAL DESCRIPTION
ALL THAT CERTAIN lot or piece of ground with the improvements thereon erected,situate in the Township of
Upper Ellen,County of Cumberland,and State of Pennsylvania,bounded and described as follows:
BEGINNING at a point in the southern line of Holly Drive(50 feet wide),which said point is in the division line
between lots Nos.76 and 77 on the hereinafter mentioned Plan of Lots;thence along the Southern line of Holly Drive,
North 65 degrees 24 minutes,40 seconds East,90.00 feet to a point in the division line between Lots Nos.77 and 78 on
said Plan;thence along the division line between Lots Nos.77 and 78,South 24 degrees 35 minutes 20 seconds East,
153.13 feet to a point;thence South 67 degrees 40 minutes 15 seconds West,90.07 feet to a point in the division line
between Lots Nos.76 and 77 on said Plan,aforementioned;thence along the division line between Lots Nos.76 and 77,
North 24 degrees 35 minutes 20 seconds West, 149.58 feet to a point in the southern line of Holly Drive,aforementioned,
at the point and place of BEGINNING.
BEING Lot No. 77,Section 5,Revised,of the Plan of Spring Run Acres,which Plan is recorded in the
Cumberland County Recorder's Office in Plan Book 20,Page 87.
HAVING THEREON ERECTED a brick and aluminum Dutch Colonial two-story dwelling known and numbered as 123
Holly Drive,Mechanicsburg,Pennsylvania.
UNDER AND SUBJECT,NEVERTHELESS,to easements,restrictions,reservations,conditions and rights-of-way of
record.
BEING the same premises which SHIRLENE L.ROSEMAN,WIDOW by deed dated May 5,2006 and recorded May 10,
2006 in the office of the Recorder in and for Cumberland County in Deed Book 274,Page 2333,granted and conveyed to
Matthew J.Gilbert and Beth A.Gilbert,husband and wife.
TAX MAP PARCEL NUMBER:42-28-2421-078
McCABE,WEISBERG AND CONWAY,P.C.
BY: TERRENCE J.McCABE,ESQUIRE-ID#16496 Attorneys for Plaintiff r
MARC S.WEISBERG,ESQUIRE-ID#17616 ��
EDWARD D.CONWAY,ESQUIRE -ID#34687
MARGARET GAIRO,ESQUIRE-ID# 34419
ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009
HEIDI R.SPIVAK,ESQUIRE-ID#74770
MARISA J.COHEN,ESQUIRE-ID#87830
KEVIN T.McQUAIL,ESQUIRE-ID#307169
CHRISTINE L.GRAHAM,ESQUIRE-ID#309480
BRIAN T.LaMANNA,ESQUIRE-ID#310321
ANN E.SWARTZ,ESQUIRE-ID#201926
JOSEPH F.RIGA,ESQUIRE-ID#57716
JOSEPH I.FOLEY,ESQUIRE-ID#314675
CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673
123 South Broad Street,Suite 1400
Philadelphia,Pennsylvania 19109
(215)790-1010
CIVIL ACTION LAW
U.S.Bank,National Association,as Successor Trustee COURT OF COMMON PLEAS
to Bank of America,N.A.,as Successor by Merger to
Lasalle Bank,N.A.,as Trustee for the CUMBERLAND COUNTY
Certificateholders of the MLMI Trust,Mortgage Loan
Asset-Backed Certificates,Series 2006-MLN1
Number 2009-07116
V.
Matthew J.Gilbert and Beth A.Gilbert
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Matthew J.Gilbert Beth A.Gilbert
123 Holly Drive 123 Holly Drive
Mechanicsburg,Pennsylvania 17055 Mechanicsburg,Pennsylvania 17055
Your house(real estate)at 123 Holly Drive,Mechanicsburg,Pennsylvania 17055 is scheduled to be sold
at Sheriffs Sale on June 4,2014 at 10:00 a.m.in the Commissioner's Hearing Room located on the 2nd Floor of the
Cumberland County Courthouse, 1 Courthouse Square,Carlisle,Pennsylvania 17013 to enforce the court judgment
of$224,353.65 obtained by U.S.Bank,National Association,as Successor Trustee to Bank of America,N.A.,as
Successor by Merger to Lasalle Bank,N.A.,as Trustee for the Certificateholders of the MLMI Trust,Mortgage Loan
Asset-Backed Certificates,Series 2006-MLN1 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:
1. The sale will be canceled if you pay to U.S.Bank,National Association,as Successor Trustee to
Bank of America,N.A.,as Successor by Merger to Lasalle Bank,N.A.,as Trustee for the
Certificateholders of the MLMI Trust,Mortgage Loan Asset-Backed Certificates,Series
2006-MLN1 the back payments,late charges,costs,and reasonable attorney's fees due. To fmd
out how much you must pay,you may call McCabe,Weisberg and Conway,P.C.,Esquire at(215)
790-1010.
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 the following notice 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 Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find
out the price bid by calling McCabe,Weisberg and Conway,P.C.,Esquire at(215)790-1010.
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 on the sale. To find
out if this has happened,you may call McCabe,Weisberg and Conway,P.C.at(215)790-1010.
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 real estate. A schedule of
distribution of the money bid for your real estate will be filed by the Sheriff within thirty(30)days
of the 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 schedule of
distribution is wrong)are filed with the Sheriff within ten(10)days after the posting of the
schedule of distribution.
7. You may also have other rights and defenses,or ways of getting your real estate 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,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,Pennsylvania 17013
(800)990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
32 South Bedford Street
Carlisle,Pennsylvania 17013
(800)990-9108
LEGAL DESCRIPTION
ALL THAT CERTAIN lot or piece of ground with the improvements thereon erected,situate in the Township of
Upper Ellen,County of Cumberland,and State of Pennsylvania,bounded and described as follows:
BEGINNING at a point in the southern line of Holly Drive(50 feet wide),which said point is in the division line
between lots Nos.76 and 77 on the hereinafter mentioned Plan of Lots;thence along the Southern line of Holly Drive,
North 65 degrees 24 minutes,40 seconds East,90.00 feet to a point in the division line between Lots Nos.77 and 78 on
said Plan;thence along the division line between Lots Nos.77 and 78, South 24 degrees 35 minutes 20 seconds East,
153.13 feet to a point;thence South 67 degrees 40 minutes 15 seconds West,90.07 feet to a point in the division line
between Lots Nos.76 and 77 on said Plan,aforementioned;thence along the division line between Lots Nos.76 and 77,
North 24 degrees 35 minutes 20 seconds West, 149.58 feet to a point in the southern line of Holly Drive,aforementioned,
at the point and place of BEGINNING.
BEING Lot No. 77,Section 5,Revised,of the Plan of Spring Run Acres,which Plan is recorded in the
Cumberland County Recorder's Office in Plan Book 20,Page 87.
HAVING THEREON ERECTED a brick and aluminum Dutch Colonial two-story dwelling known and numbered as 123
Holly Drive,Mechanicsburg,Pennsylvania.
UNDER AND SUBJECT,NEVERTHELESS,to easements,restrictions,reservations,conditions and rights-of-way of
record.
BEING the same premises which SHIRLENE L.ROSEMAN,WIDOW by deed dated May 5,2006 and recorded May 10,
2006 in the office of the Recorder in and for Cumberland County in Deed Book 274,Page 2333,granted and conveyed to
Matthew J.Gilbert and Beth A.Gilbert,husband and wife.
-TAX MAP PARCEL NUMBER:42-28-2421-078
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 09-7116 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION—LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due U.S. BANK,NATIONAL ASSOCIATION,AS
SUCCESSOR TRUSTEE TO BANK OF AMERICA,N.A.,AS SUCCESSOR BY MERGER TO
LASALLE BANK,N.A.,AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF THE MLMI
TRUST,MORTGAGE LOAN ASSET-BACKED CERTIFICATES,SERIES 2006-MLNI
Plaintiff(s)
From MATTHEW J. GILBERT AND BETH A. GILBERT
(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 gamishee(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: $205,101.43 L.L.: $.50
Interest FROM 8/18/12 TO 2/17/14 PER DIEM THEREAFTER$35.0678-$19,252.22
INTEREST FROM 2/18/14-$3,946.16 AT$36.88
Atty's Comm: Due Prothy: $2.25
Atty Paid: $216.00 Other Costs:
Plaintiff Paid:
Date: 2/21/14
David D.Buell,Prothonotary
(Seal) By:
Deputy
REQUESTING PARTY:
Name: MARC S.WEISBERG,ESQUIRE
Address: MCCABE,WEISBERG AND CONWAY,P.C.
123 S. BROAD STREET,SUITE 1400, PHILADELPHIA,PA 19109
Attorney for: PLAINTIFF
Telephone: 215-790-1010
Supreme Court ID No. 17616
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009
HEIDI R. SPIVAK, ESQUIRE - ID # 74770
MARISA J. COHEN, ESQUIRE - ID # 87830
CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480
BRIAN T. LAMANNA, ESQUIRE - ID # 310321
ANN E. SWARTZ, ESQUIRE - ID # 201926
JOSEPH F. RIGA, ESQUIRE - ID # 57716
JOSEPH I. FOLEY, ESQUIRE - ID # 314675
CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673
JENNIFER L. WUNDER, ESQUIRE - ID # 315954
LENA KRAVETS, ESQUIRE - ID # 316421
CAROL A. DiPRINZIO, ESQUIRE - ID # 316094
123 South Broad Street, Suite 1400
Philadelphia, Pennsylvania 19109
(215) 790-1010
U.S. Bank, National Association, as Successor Trustee
to Bank of America, N.A., as Successor by Merger to
Lasalle Bank, N.A., as Trustee for the
Certificateholders of the MLMI Trust, Mortgage Loan
Asset - Backed Certificates, Series 2006 -MLNI
Plaintiff
v.
Matthew J. Gilbert and Beth A. Gilbert
Defendant
114 fill
FENNSYLVNNI
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Number 2009 -07116
AFFIDAVIT OF SERVICE
The undersigned attorney for the Plaintiff in the within matter, hereby certifies that on the 8th day of April,
2014, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent
lienholder(s) as set forth in Amended Affidavit Pursuant to 3129 which is attached hereto.
A copy of the Notice of Sheriff's Sale and certificate of mailing is also attached hereto and made a part
hereof.
SWORN AND SUBSCRIBED
NOTARY PUBLIC
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
ANDREW SWITKAY, Notary Public
City of Philadelphia, Phila, Coun.
y Commission Exsires March 15, 2
McCABE, WE B_ G & CO
BY:
[ ] Terrence J. McCabe, Esquire Or [ ] Marc S. Weisberg, Esquire
[ ] Edward D. Conway, Esquire [ ] Margaret Gairo, Esquire
[ ] Andrew L. Markowitz, Esquire [ ] Heidi R. Spivak, Esquire
[ ] Marisa J. Cohen, Esquire [ ] Christine L. Graham, Esquire
[ ] Brian T. LaManna, Esquire [ ] Ann E. Swartz, Esquire
[ ] Joseph F. Riga, Esquire [ ] Joseph I. Foley, Esquire
[ ] Celine P. DerKrikorian, Esquire [ ] J Ifer L. Wunder, Esquire
[ ] Lena Kravets, Esquire [ Carol A. DiPrinzio, Esquire
Attorneys for Plaintiff
AY, P.C.
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009
HEIDI R. SPIVAK, ESQUIRE - # 74770
MARISA J. COHEN, ESQUIRE - ID # 87830
CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480
BRIAN T. LAMANNA, ESQUIRE - ID # 310321
ANN E. SWARTZ, ESQUIRE - ID # 201926
JOSEPH F. RIGA, ESQUIRE - ID # 57716
JOSEPH I. FOLEY, ESQUIRE - ID # 314675
CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673
JENNIFER L. WUNDER, ESQUIRE - ID # 315954
LENA KRAVETS, ESQUIRE - ID # 316421
CAROL A. DiPRINZIO, ESQUIRE - ID # 316094
123 South Broad Street, Suite 1400
Philadelphia, Pennsylvania 19109
215 790-1010
U.S. Bank, National Association, as Successor Trustee
to Bank of America, N.A., as Successor by Merger to
Lasalle Bank, N.A., as Trustee for the
Certificateholders of the MIMI Trust, Mortgage Loan
Asset-Backed Certificates, Series 2006-MLN1
Plaintiff
v.
Matthew J. Gilbert and Beth A. Gilbert
Defendants
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NO: 2009-07116
AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1
The undersigned attorney for Plaintiff in the above action sets forth the following information concerning
the real property located at 123 Holly Drive, Mechanicsburg, Pennsylvania 17055-5527, as of the date the Praecipe
for the Writ of Execution was filed. A copy of the description of said property is attached hereto.
1.
Name and address of Owners or Reputed Owners
Name
Matthew J. Gilbert
Beth A. Gilbert
Address
123 Holly Drive
Mechanicsburg, Pennsylvania 17055-5527
123 Holly Drive
Mechanicsburg, Pennsylvania 17055-5527
2. Name and address of Defendants in the judgment:
File #62297
Page 1
Name Address
Matthew J. Gilbert 123 Holly Drive
Mechanicsburg, Pennsylvania 17055
Beth A. Gilbert 123 Holly Drive
Mechanicsburg, Pennsylvania 17055
3. Name and last known address of every judgment creditor whose judgment is a record lien on the
real property to be sold:
Name
Plaintiff herein
Restore Core
Address
2322 North 7th Street
Harrisburg, Pennsylvania 17110
4. Name and address of the last recorded holder of every mortgage of record:
Name Address
Plaintiff herein
5. Name and address of every other person who has any record lien on the property:
Name Address
None
6. Name and address of every other person who has any record interest in the property which may be
affected by the sale:
Name Address
None
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:
Name Address
Tenants /Occupants 123 Holly Drive
Mechanicsburg, Pennsylvania 17055 -5527
Commonwealth of Pennsylvania
Commonwealth of Pennsylvania
Inheritance Tax Office
Department of Public Welfare
Bureau of Child Support Enforcement
P.O. Box 2675
Harrisburg, PA 17105
ATTN: Dan Richard
110 North 8`h Street
Suite #204
Philadelphia, PA 19107
File #62297
Page 2
Commonwealth of Pennsylvania
Bureau of Individual. Tax
Inheritance Tax Division
Department of Public Welfare
TPL Casualty Unit Estate
Recovery Program
PA Department of Revenue
PA Department of Revenue
Bureau of Compliance
Lien Section
Commonwealth of Pennsylvania
Department of Revenue Bureau of
Compliance
United'States of America
Domestic Relations
Cumberland County
Tax Claim Bureau
Commonwealth of PA
Department of Revenue
United States of America
United States of America c/o
Atty General of the United States
United States of America c/o
Atty General of the United States
8. Name and address of Attorney of record:
6th Floor, Strawberry Square
Department #280601
Harrisburg, PA 17128
Willow Oak Building
P.O. Box 8486
Harrisburg, PA 17105 -8486
Bureau of Compliance
P.O. Box 281.230
Harrisburg, PA 17128 -1230
PO BOX 280948
Harrisburg PA 17128 -0948
Clearance Support Department 281230
Harrisburg, PA 17128 -1230
ATTN: Sheriff's Sales
Internal Revenue Service
Technical Support Group
William Green Federal Building
Room 3259
600 Arch Street
Philadelphia, PA 19106
P.O. Box 320
Carlisle, PA 17013
1 Courthouse Square
Carlise, PA 17013
Bureau of Compliance
Department 280946
Harrisburg, PA 17128 -0946
Attn: Sheriffs Sales
c/o United States Attorney for the
Middle District of PA
William J. Nealon Federal Bldg.
235 North Washington Avenue, Ste. 311
Scranton, PA 18503
and
Harrisburg Federal Building & Courthouse
228 Walnut Street, Ste. 220
Harrisburg, PA 17108 -1754
U.S. Dept. of Justice, Rm 4400
950 Pennsylvania Avenue, NW
Washington, DC 20530
U.S. Dept. of Justice, Rm 5111
950 Pennsylvania Avenue, NW
Washington, DC 20530
File #62297
Page 3
Name Address
None
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 of18 Pa.C.S.
Section 4904 relating to unsworn falsification to authorities.
DATE
McCA E, WEISB J& C�NWAY, P.C.
BY:
[ ] Terrence J. McCabe, Esquire
[ ] Edward D. Conway, Esquire
[ ] Andrew L. Markowitz, Esquire
[ ] Marisa J. Cohen, Esquire
[ ] Brian T. LaManna, Esquire
[ 1 Joseph F. Riga, Esquire
[ ] Celine P. DerKrikorian, Esquire
[ ] Lena Kravets, Esquire
Attorneys for Plaintiff
] Marc S. Weisberg, Esquire
[ 1 Margaret Gairo, Esquire
[ ] Heidi R. Spivak, Esquire
[ ] Christine L. Graham, Esquire
[ ] Ann E. Swartz, Esquire
[ ] Joseph I. Foley, Esquire
[ ] JeifL. Wunder, Esquire
[t1iro1 A. DiPrinzio, Esquire
Re: U.S. Bank, National Association, as Successor Trustee to Bank of America, N.A., as Successor by Merger to
Lasalle Bank, N.A., as Trustee for the Certificateholders of the MLMI Trust, Mortgage Loan Asset-Backed
Certificates, Series 2006-MLN1 v. Matthew J. Gilbert. et al.
Cumberland County; Number: 2009-07116
File #62297
Page 4
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009
HEIDI R. SPIVAK, ESQUIRE - ID # 74770
MARISA J. COHEN, ESQUIRE - ID # 87830
CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480
BRIAN T. LAMANNA, ESQUIRE - ID # 310321
ANN E. SWARTZ, ESQUIRE - ID # 201926
JOSEPH F. RIGA, ESQUIRE - ID # 57716
JOSEPH I. FOLEY, ESQUIRE - ID # 314675
CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673
JENNIFER L. WUNDER, ESQUIRE - ID # 315954
LENA KRAVETS, ESQUIRE - ID # 316421
CAROL A. DiPRINZIO, ESQUIRE - ID # 316094
123 South Broad Street, Suite 1400
Philadelphia, Pennsylvania 19109
(215) 790-1010
U.S. Bank, National Association, as Successor Trustee
to Bank of America, N.A., as Successor by Merger to
Lasalle Bank, N A , as Trustee for the
Certificateholders of the MLMI Trust, Mortgage Loan
Asset - Backed Certificates, Series 2006 -MLN1
Plaintiff
Matthew J. Gilbert and Beth A. Gilbert
Defendants
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Number 2009 -07116
DATE: April 8, 2014
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
OWNERS: Matthew J. Gilbert and Beth A. Gilbert
PROPERTY: 123 Holly Drive, Mechanicsburg, Pennsylvania 17055 -5527
IMPROVEMENTS: Residential Dwelling
JUDGMENT AMOUNT: $224,353.65
The above - captioned property is scheduled to be sold pursuant to the judgment of the court caption above at the
Sheriffs Sale on June 4, 2014 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the
Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you
may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by
the sale. You may wish to attend the sale to protect your interests.
A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty (30) days
after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten
(10) days after the filing of the schedule.
If you have any questions regarding the type of lien or the effect of the Sheriffs Sale upon your lien, we urge you to
CONTACT YOUR OWN ATTORNEY as WE ARE NOT PERMITTED TO GIVE YOU LEGAL ADVICE.
Name and Address of Sender
McCabe, Weisberg and Conway, P.C.
123 S. Broad St., Suite 2080
Philadelphia, PA 19109
ATTN: S. Gorman - 62297
Check type of mail
O Certified
O COD
Delivery Confirmation
O Express Mail
Cl Insured
or service:
Recorded Delivery (International)
O Registered
O Return Receipt for Merchandise
O Signature Confirmation
U.S POSTAGE)), PITNEY BOWES
02
ZIP try109 $ 020.4 0
Line
Article Number
Postage - - ...
- "'r"4APR
08. 201
4.
ii
U.S. Bank, National Association, as
Successor Trustee to Bank of America,
N.A., as Successor by Merger to
Lasalle Bank, N.A., as Trustee for the
Certificateholders of the MLMI Trust,
Mortgage Loan Asset - Backed
Certificates, Series 2006 -MLN1
Plaintiff
v.
Matthew J. Gilbert and Beth A.
Gilbert
Defendants
Restore Core STATio
2322 North 7th Street < S�
Harrisburg, Pennsylvania 17110
y%
q�kIPHIN,
r
<,
a@
`
✓
.-
�.-
2
Tenants /Occupants
123 Holly Drive
Mechanicsburg, Pennsylvania 17055 -5527
3
Tax Claim Bureau
1 Courthouse Square,
Carlise, PA 17013
4
Commonwealth of Pennsylvania
Department of Public Welfare
Bureau of Child Support Enforcement
P.O. Box 2675
Harrisburg, PA 17105
ATTN: Dan Richard
5
Commonwealth of Pennsylvania
Inheritance Tax Office
110 North 8th Street
Suite #204
Philadelphia, PA 19107
6
Commonwealth of Pennsylvania
Bureau of Individual Tax
Inheritance Tax Division
6th Floor, Strawberry Square
Department #280601
Harrisburg, PA 17128
7
'
Department of Public Welfare
TPL Casualty Unit Estate
Recovery Program
Willow Oak Building
P.O. Box 8486
Harrisburg, PA 17105 -8486
8
PA Department of Revenue
Bureau of Compliance
P.O. Box 281230
Harrisburg, PA 17128 -1230
9
PA Department of Revenue
Bureau of Compliance
Lien Section
PO BOX 280948
Harrisburg PA 17128 -0948
10
Commonwealth of Pennsylvania Department of
Revenue Bureau of Compliance
Clearance Support Department 281230
Harrisburg. PA 17128 -1230
ATTN: Sheriff's Sales
11
United States of America
Internal Revenue Service
Technical Support Group
William. Green Federal Building
Room 3259
600 Arch Street
Philadelphia, PA 19106
12
Domestic Relations Cumberland County
P.O. Box 320
Carlisle, PA 17013
13
Commonwealth of PA
Department of Revenue
Bureau of Compliance
Department 280946
Harrisburg, PA 17128 -0946
Attn: Sheriff's Sales
14
United States of America
c/o United States Attorney for the
Middle District of PA
William J. Nealon Federal Bldg
235 North Washington Avenue, Ste. 311
Scranton, PA 18503
_
_._
____. -- _
_. --
15
United States of America
c/o United States Attorney for the
2010 -5387 District of PA
Harrisburg Federal Building & Courthouse
228 Walnut Street, Ste. 220
Harrisburg, PA 17108 -1754
16
United States of America c/o
Atty General of the United States
U.S. Dept of Justice, Room 5111
950 Pennsylvania Avenue NW
Washington, DC 20530 -0001
17
United States of America c/o
Atty General of the United States
U.S. Dept of Justice, Room 4400
950 Pennsylvania Avenue NW
Washington, DC 20530 -0001
Total Number of Pieces
Total Number of Pieces
Listed by Sender
Received at Post Office
17
TiivIcCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009
HEIDI R. SPIVAK, ESQUIRE - ID # 74770
MARISA J. COHEN, ESQUIRE - ID # 87830
CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480
BRIAN T. LAMANNA, ESQUIRE - ID # 310321
ANN E. SWARTZ, ESQUIRE - ID # 201926
JOSEPH F. RIGA, ESQUIRE - ID # 57716
JOSEPH I. FOLEY, ESQUIRE - ID # 314675
CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673
JENNIFER L. WUNDER, ESQUIRE - ID # 315954
LENA KRAVETS, ESQUIRE - ID # 316421
CAROL A. DiPRINZIO, ESQUIRE - ID # 316094
123 South Broad Street, Suite 1400
Philadelphia, Pennsylvania 19109
(215) 790-1010
U.S. Bank, National Association, as Successor Trustee
to Bank of America, N.A., as Successor by Merger to
Lasalle Bank, N.A., as Trustee for the
' Certificateholders of the MLMI Trust, Mortgage Loan
Asset -Backed Certificates, Series 2006-MLN1
Plaintiff
v.
Matthew J. Gilbert and Beth A. Gilbert
Defendant
U�f�ER _7 4M1/ 40
AND
PENNSYLVA
NIA COLI,
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Number 2009-07116
Y
AFFIDAVIT OF SERVICE
The undersigned attorney for the Plaintiff in the within matter, hereby certifies that on the 2nd day of May,
2014, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent
lienholder(s) as set forth in Amended Affidavit Pursuant to 3129 which is attached hereto.
A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part
hereof.
SWORN AND SUBSCRIBED
BEFORE ME THIS 2 DAY
OF AA , 2014
McCABE, WEISBE CO,
BY:
[ ] Terrence J. McCabe, Esquire
[ ] Edward D. Conway, Esquire
[ ] Andrew L. Markowitz, Esquire
] Marisa J. Cohen, Esquire
[ ] Brian T. LaManna, Esquire
[ ] Joseph F. Riga, Esquire
[ ] Celine P. DerKrikorian, Esquire
[ ] Lena Kravets, Esquire
Attorneys for Plaintiff
AY, P.C.
NOT RYJUBL
i. r:• :ct�i LTH FPE.NNSYLVANi .
NOTARIAL SEAL,
Kimberly Lynn McCloskey, t'otary Public
City of Philadelphia, Phila. County
My Commission Expires September 7, 21116
Marc S. Weisberg, Esquire
] Margaret Gairo, Esquire
] Heidi R. Spivak, Esquire
] Christine L. Graham, Esquire
] Ann E. Swartz, Esquire
] Joseph I. Foley, Esquire
] ifer L. Wunder, Esquire
Carol A. DiPrinzio, Esquire
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009
HEIDI R. SPIVAK, ESQUIRE - ID # 74770
MARISA J. COHEN, ESQUIRE - ID # 87830
CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480
BRIAN T. LAMANNA, ESQUIRE - ID # 310321
ANN E. SWARTZ, ESQUIRE - ID # 201926
JOSEPH F. RIGA, ESQUIRE - ID # 57716
JOSEPH I. FOLEY, ESQUIRE - ID # 314675
CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673
JENNIFER L. WUNDER, ESQUIRE - ID # 315954
LENA KRAVETS, ESQUIRE - ID # 316421
CAROL A. DiPRINZIO, ESQUIRE - ID # 316094
123 South Broad Street, Suite 1400
Philadelphia, Pennsylvania 19109
(215) 790-1010
U.S. Bank, National Association, as Successor Trustee
to Bank of America, N.A., as Successor by Merger to
Lasalle Bank, N.A., as Trustee for the
Certificateholders of the MLMI Trust, Mortgage Loan
Asset -Backed Certificates, Series 2006-MLN1
Plaintiff
v.
Matthew J. Gilbert and Beth A. Gilbert
Defendants
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NO: 2009-07116
AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1
The undersigned attorney for Plaintiff in the above action sets forth the following information concerning
the real property located at 123 Holly Drive, Mechanicsburg, Pennsylvania 17055-5527, as of the date the Praecipe
for the Writ of Execution was filed. A copy of the description of said property is attached hereto.
1.
Name and address of Owners or Reputed Owners
Name
Matthew J. Gilbert
Beth A. Gilbert
Address
123 Holly Drive
Mechanicsburg, Pennsylvania 17055-5527
123 Holly Drive
Mechanicsburg, Pennsylvania 17055-5527
2. Name and address of Defendants in the judgment:
File #62297
Page 1
Name Address
Matthew J. Gilbert 123 Holly Drive
Mechanicsburg, Pennsylvania 17055
Beth A. Gilbert 123 Holly Drive
Mechanicsburg, Pennsylvania 17055
3. Name and last known address of every judgment creditor whose judgment is a record lien on the
real property to be sold:
Name
Plaintiff herein
Restore Core
Address
2322 North 7th Street
Harrisburg, Pennsylvania 17110
4. Name and address of the last recorded holder of every mortgage of record:
Name Address
Plaintiff herein
5. Name and address of every other person who has any record lien on the property:
Name Address
None
6. Name and address of every other person who has any record interest in the property which may be
affected by the sale:
Name Address
SPRING RUN ACRES 109 E ELMWOOD AVE
MECHANICSBURG PA 17055
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:
Name Address
Tenants/Occupants 123 Holly Drive
Mechanicsburg, Pennsylvania 17055-5527
Commonwealth of Pennsylvania
Department of Public Welfare
Bureau of Child Support Enforcement
P.O. Box 2675
Harrisburg, PA 17105.
ATTN: Dan Richard
File #62297
Page 2
Commonwealth of Pennsylvania
Inheritance Tax Office
Commonwealth of Pennsylvania
Bureau of Individual Tax
Inheritance Tax Division
Department of Public Welfare
TPL Casualty Unit Estate
Recovery Program
PA Department of Revenue
PA Department of Revenue
Bureau of Compliance
Lien Section
Commonwealth of Pennsylvania
Department of Revenue Bureau of
Compliance
United States of America
Domestic Relations
Cumberland County
Tax Claim Bureau
Commonwealth of PA
Department of Revenue
United States of America
United States of America c/o
Atty General of the United States
110 North 8th Street
Suite #204
Philadelphia, PA 19107
6th Floor, Strawberry Square
Department #280601
Harrisburg, PA 17128
Willow Oak Building
P.O. Box 8486
Harrisburg, PA 17105-8486
Bureau of Compliance
P.O. Box 281230
Harrisburg, PA 17128-1230
PO BOX 280948
Harrisburg PA 17128-0948
Clearance Support Department 281230
Harrisburg, PA 17128-1230
ATTN: Sheriffs Sales
Internal Revenue Service
Technical Support Group
William Green Federal Building
Room 3259
600 Arch Street
Philadelphia, PA 19106
P.O. Box 320
Carlisle, PA 17013
1 Courthouse Square
Carlise, PA 17013
Bureau of Compliance
Department 280946
Harrisburg, PA 17128-0946
Attn: Sheriffs Sales
c/o United States Attorney for the
Middle District of PA
William J. Nealon Federal Bldg.
235 North Washington Avenue, Ste. 311
Scranton, PA 18503
and
Harrisburg Federal Building & Courthouse
228 Walnut Street, Ste. 220
Harrisburg, PA 17108-1754
U.S. Dept. of Justice, Rm 4400
950 Pennsylvania Avenue, NW
Washington, DC 20530
File #62297
Page 3
United States of America c/o
Atty General of the United States
8. Name and address of Attorney of record:
Name
None
U.S. Dept. of Justice, Rm 5111
950 Pennsylvania Avenue, NW
Washington, DC 20530
Address
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.
cS(' Z -Z
DATE
McCABE, WEISBE ; _. _: CO
BY:
AY, P.C.
[ ] Terrence J. McCabe, Esquire
[ ] Edward D. Conway, Esquire
[ ] Andrew L. Markowitz, Esquire
[ ] Marisa J. Cohen, Esquire
[ ] Brian T. LaManna, Esquire
[ ] Joseph F. Riga, Esquire
[ ] Celine P. DerKrikorian, Esquire
[ ] Lena Kravets, Esquire
Attorneys for Plaintiff
Marc S. Weisberg, Esquire
Margaret Gairo, Esquire
Heidi R. Spivak, Esquire
Christine L. Graham, Esquire
Ann E. Swartz, Esquire
Jose . Foley, Esquire
J nifer L. Wunder, Esquire
Carol A. DiPrinzio, Esquire
Re: U.S. Bank, National Association, as Successor Trustee to Bank of America, N.A., as Successor by Merger to
Lasalle Bank, N.A., as Trustee for the Certificateholders of the MLMI Trust, Mortgage Loan Asset -Backed
Certificates, Series 2006-MLN1 v. Matthew J. Gilbert. et al.
Cumberland County; Number: 2009-07116
File #62297
Page 4
-McGABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009
HEIDI R. SPIVAK, ESQUIRE - ID # 74770
MARISA J. COHEN, ESQUIRE - ID # 87830
CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480
BRIAN T. LAMANNA, ESQUIRE - ID # 310321
ANN E. SWARTZ, ESQUIRE - ID # 201926
JOSEPH F. RIGA, ESQUIRE - ID # 57716
JOSEPH I. FOLEY, ESQUIRE - ID # 314675
CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673
JENNIFER L. WUNDER, ESQUIRE - ID # 315954
LENA KRAVETS, ESQUIRE - ID # 316421
CAROL A. DiPRINZIO, ESQUIRE - ID # 316094
123 South Broad Street, Suite 1400
Philadelphia, Pennsylvania 19109
(215) 790-1010
U.S. Bank, National Association, as Successor Trustee
to Bank of America, N.A., as Successor by Merger to
Lasalle Bank, N.A., as Trustee for the
Certificateholders of the MLMI Trust, Mortgage Loan
Asset -Backed Certificates, Series 2006-MLN1
Plaintiff
v.
Matthew J. Gilbert and Beth A. Gilbert
Defendants
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Number 2009-07116
DATE: May 2, 2014
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
OWNERS: Matthew J. Gilbert and Beth A. Gilbert
PROPERTY: 123 Holly Drive, Mechanicsburg, Pennsylvania 17055-5527
IMPROVEMENTS: Residential Dwelling
JUDGMENT AMOUNT: $224,353.65
The above -captioned property is scheduled to be sold pursuant to the judgment of the court caption above at the
Sheriffs Sale on June 4, 2014 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the
Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you
may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by
the sale. You may wish to attend the sale to protect your interests.
A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty (30) days
after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten
(10) days after the filing of the schedule.
If you have any questions regarding the type of lien or the effect of the Sheriffs Sale upon your lien, we urge you to
CONTACT YOUR OWN ATTORNEY as WE ARE NOT PERMITTED TO GIVE YOU LEGAL ADVICE.
Name and Address of Sender
McCabe, Weisberg and Conway, P.C.
123 S. Broad St., Suite 2080
Philadelphia, PA 19109
ATTN: S. Gorman - 62297
Check type of mail or service:
O Certified 0 Recorded Delivery (International)
O COD 0 Registered
0 Delivery Confirmation 0 Return Receipt for Merchandise
❑ Express Mail 0 Signature Confirmation
O Insured
Line
Article Nranber
Postage
U.S. Bank, National Association, as Successor
Trustee to Bank of America, N.A., as
Successor by Merger to Lasalle Bank, N.A.,
as Trustee for the Certificateholders of the
MLMI Trust, Mortgage Loan Asset -Backed
Certificates, Series 2006-MLN1
Plaintiff
v.
Matthew J. Gilbert and Beth A. Gilbert
Defendants
SPRING RUN ACRES
109 E ELMWOOD AVE
MECHANICSBURG PA 17055
U.S. POSTAGE» PITNEY BOWES
Z1P 19109 $ 001.200
02 1st
000137.7494 MAY. 02. 2014
Total Number of Pieces
Listed by Sender
1
Total Num er of Pieces
Received a Post Office
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
ZfJJU J -6 (;;*t : 2`3
CUMDEPL.ND COUNT`
PENNSYLVANIA
US Bank Trust National Association
vs.
Matthew J. Gilbert (et al.)
Case Number
2009-7116
SHERIFF'S RETURN OF SERVICE
03/24/2014 05:50 PM - Deputy Ryan Burgett, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the
above titled action, upon the property located at 123 Holly Drive, Upper Allen - Township, Mechanicsburg,
PA 17055, Cumberland County.
03/24/2014 05:50 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, by making known its contents and at the same
time personally handing a true copy to a person representing themselves to be the Defendant, to wit:
Matthew J. Gilbert at 123 Holly Drive, Upper Allen Township, Mechanicsburg, PA 17055, Cumberland
County.
03/24/2014 05:50 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, by making known its contents and at the same
time personally handing a true copy to a person representing themselves to be Matthew Gilbert,
husband, who accepted as "Adult Person in Charge" for Beth A. Gilbert at 123 Holly Drive, Upper Allen
Township, Mechanicsburg, PA 17055, Cumberland County.
06/02/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed",
per letter of instruction from Attorney.
SHERIFF COST: $975.05 SO ANSWERS,
June 03, 2014 RONR ANDERSON, SHERIFF
(c) CountySude Sheriff, 't eleosoft, Inc,
A 3pz 973
On February 27, 2014 the Sheriff levied upon the
defendant's interest in the real property situated in
Upper Allen Township, Cumberland County, PA,
Known and numbered as 123 Holly Drive, Mechanicsburg,
as Exhibit "A" filed with this writ
and by this Reference incorporated herein.
Date: February 27, 2014
By:
e)L
Real Estate Coordinator
1
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 18, April 25 and May 2, 2014
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.
Marie Coyne, Lisa y , E itor
SWORN TO AND SUBSCRIBED before me this
2 day of May, 2014
Notary
COMMONWEALTH OF PENNSYLVANIA
1
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BORO., CUMBERLAND CNTY
My Commission Expires Apr 28. 2018
LX1II 16 CUMBERLAND LAW JOURNAL 04/18/14
Writ No. 2009-7116 Civil Term
U.S. Bank Trust
National Association
vs.
Matthew J. Gilbert
Beth A. Gilbert
Atty.: Marc Weisberg
ALL THAT CERTAIN lot or piece of
ground with the improvements there-
on erected, situate in the Township of
Upper Ellen, County of Cumberland,
and State of Pennsylvania, bounded
and described as follows:
BEGINNING at a point in the
southern line of Holly Drive (50 feet
wide), which said point is in the divi-
sion line between lots Nos. 76 and 77
on the hereinafter mentioned Plan of
Lots; thence along the Southern line
of Holly Drive, North 65 degrees 24
minutes, 40 seconds East, 90.00 feet
to a point in the division line between
Lots Nos. 77 and 78 on
said Plan; thence along the divi-
sion line between Lots Nos. 77 and
78, South 24 degrees 35 minutes 20
seconds East, 153.13 feetto a point;
thence South 67 degrees 40 minutes
15 seconds West, 90.07 feet to a point
in the division line between Lots Nos.
76 and 77 on said Plan, aforemen-
tioned; thence along the division line
between Lots Nos. 76 and 77, North
24 degrees 35 minutes 20 seconds
West, 149.58 feet to a point in the
southern line of Holly Drive, afore-
mentioned, at the point and place of
BEGINNING.
BEING Lot No. 77, Section 5,
Revised, of the Plan of Spring Run
Acres, which Plan is recorded in the
Cumberland County Recorder's Of-
fice in Plan Book 20, Page 87.
HAVING THEREON ERECTED a
brick and aluminum Dutch Colonial
two-story dwelling known and num-
bered as 123 Holly Drive, Mechanics-
burg, Pennsylvania.
UNDER AND SUBJECT, NEVER-
THELESS, to easements, restrictions,
59
reservations, conditions and rights-
of-way of record.
BEING the same premises which
SHIRLENE L. ROSEMAN, WIDOW
by deed dated May 5, 2006 and re-
corded May 10, 2006 in the office of
the Recorder in and for Cumberland
County in Deed Book 274, Page 2333,
granted and conveyed to Matthew J.
Gilbert and Beth A. Gilbert, husband
and wife.
TAX MAP PARCEL NUMBER: 42-
28-2421-078.
The Patriot -News Co.
202Q Technology Pkwy
Suite 300
Mechanicsburg, PA 17050
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
he patriot News
Now you know
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 the Assistant Controller 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 2020 Technology Pkwy, Suite 300, in the
Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday
Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, 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/ Community Weekly 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 verify 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
.4011- ISI d I=I.I,tAi HZ isci iuphin in Miscellaneous Book "M", Volume 14, Page 317.
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division line between lots Nos. 76 and
77 on the hereinafter mentioned Plan
of Lots; thence along the Southern 1
line of Holly Drive, North 65 degrees
24 minutes, 40 seconds East, 90.00
feet to a point in the division line
between Lots Nos. 77 and 78 on said II
Plan; thence along the division line
between Lots Nos. 77 and 78, South
24 degrees 35 minutes 20 seconds
East, 153.13 feet to a point; thence
Small 67 decrees 40 minutes 15
I
This ad ran on the date(s) shown below:
04/13/14
04/20/14
04/27/14
Sworn a d subscribed before me t ' 0 ay of May, 2014A.D.
1
...„..,
COMMONWEALTH OF PENNSYLVANIA
Notarlat Seal
Holly Lynn Wold, Notary Public
V!astengton Tao., D uphIn County
My Camra SsIoa Expires Dec. 12, 2016
MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIEC