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Home My WebLink About10-0283GoLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF RLED-Ot F' uE OF T!-•"- 11 R-H r)7 C'N??TARY 2010 JAN -3 PPS 3: 4 3 `t1W _ ?JV aY DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR THE BENEFIT OF HSI ASSET SECURITIZATION CORPORATION AND HSI ASSET SECURITIZATION CORPORATION TRUST 2007-HE2 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. DONALD BARBARO Mortgagor and Record Owner 4440 Sears Run Drive Mechanicsburg, PA 17050 Defendant IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 10' oI83 iVi l??'M CIVIL ACTION: MOI?TCAGE RQI LOSURF NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 4gO?•? P D fi? Ce 51a qS7 M4 aZs(003$ CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243- 9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://wWW.Dhfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://www.Dhiladelphiafed.org/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionggoldbecklaw com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 8991517C. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR THE BENEFIT OF HSI ASSET SECURITIZATION CORPORATION AND HSI ASSET SECURITIZATION CORPORATION TRUST 2007-HE2, 7105 Corporate Drive, PTX C-35 Plano, TX 75024. 2. The names and addresses of the Defendant is DONALD BARBARO, 4440 Sears Run Drive, Mechanicsburg, PA 17050, who is the mortgagor and record owner of the mortgaged premises hereinafter described. 3. On September 29, 2006 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR DECISION ONE MORTGAGE COMPANY, LLC., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book#:1968, Page 4477. The mortgage has been assigned to: DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR THE BENEFIT OF HSI ASSET SECURITIZATION CORPORATION AND HSI ASSET SECURITIZATION CORPORATION TRUST 2007-HE2 by assignment of Mortgage. Plaintiff is the real party in interest pursuant to a purchase or transfer of the mortgage obligation from the last record holder and an Assignment of Mortgage to Plaintiff has been and/or will be lodged for recording with the Recorder of Deeds in the ordinary course of business. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for May 04, 2008 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ....................................................................... Interest from 04/04/2008 through 10/22/2009 at 9.7900%........ Per Diem interest rate at $37.08 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph .... Late Charges from 05/04,/2008 to 10/22/2009 ........................... Monthly late charge amount at $60.13 Costs of suit and Title Rearch Monthly Escrow amount $416.57 ......... $138,254.05 ...........$21,024.36 ...$6,912.70 ...$1,082.34 ...... $900.00 $168,173.45 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriffs Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendant in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant has received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendant have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $168,173.45, together with interest at the rate of $37.08, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. By: LDBECK McCAFFERTY & McKEEVER Y: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION 1, Be emin Hllis , as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date:_?n?D 8109n Hillis-Asst. Secretary #89915FC - DONALD BAR13ARO 4440 Sears Run Drive Mechanicsburg, PA 17050 Prepared By and Return To: Referral Department GOLDBECK McCAFFERTY & McKEEVER Mellon Independence Center - Suite 5000 701 Market Street Philadelphia, PA 19106-1532 215-825-6344 GMM File Number: 89915FC Parcel ID#: 10-18-1314-04 ASSIGNMENT OF MORTGAGE MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR DECISION ONE MORTGAGE COMPANY, LLC (Assignor), for and inconsideration of the sum of Ten Dollars ($10.00) and other good and valuable consideration, the receipt of which is acknowledged, does grant, bargain, sell, assign and transfer to DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR THE BENEFIT OF HSI ASSET SECURIIIZATION CORPORATION AND HSI ASSET SECURIIIZATION CORPORATION TRUST 2007-HE2. DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR THE BENEFIT OF HSI ASSET SECURITIZATION CORPORATION AND HSI ASSET SECURITIZATION CORPORATION TRUST 2007-HE2 (Assignee), all of its right, title and interest, as holder oi, in, and to the following described mortgage, the property described and the indebtedness secured by the mortgage: Executed DONALD BARBARO , Mortgagor(s); to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR DECISION ONE MORTGAGE COMPANY, LLC. Bearing date of September 29,2006; Amount Secured: $139,506.00; Recorded on October 10, 2006; in Book#:1968, Page 4477; in the Recorder of Deeds Office of Cumberland County, Commonwealth of Pennsylvania ("Mortgage") Property: 4440 Sears Ran Drive, Mechaniesberg, PA 17050 AS FURTHER DESCRIBED IN EXHIBIT "A", ATTACHED AND INCORPORATED INTO THIS ASSIGNMENT. Together with the note or obligation described in the Mortgage endorsed to the Assignee, ("Note") and all moneys due and to become due on the Note and Mortgage, with interest. Assignee its successors, legal representatives and assigns shall hold all rights under the Note and Mortgage forever, subject however, to the right and equity of redemption, if any, of the maker(s) of the Mortgage, their heirs and assigns forever. Assignor, by its appropriate attorney in fact, has executed and sealed with its corporate seal this Assignment of Mortgage on this 31 day of December. 2009. MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR DECISION ONE MORTGAGE COMPANY, LLC By: Gary ff squire of Goldbeck McCafferty & McKeever as Attorney in Fact for Mortgage Electronic Registration Systems, Inc. organized and existing under the laws of the United States of America by the Agreement for Signing Authority dated November 2, 2009 COMMONWEALTH OF PENNSYLVANIA : SS COUNTY OF PHILADELPHIA On this 21 day of December_ 2009, before me, a Notary Public in and for the County and State aforesaid, the undersigned officer, personally appeared Gary E. McCafferty of Goldbeck McCafferty & McKeever, known to me or satisfactorily proven to be the Attorney in Fact on behalf of Mortgage Electronic Registration Systems, Inc. organized and existing under the laws of the United States of America noted above and acknowledged that, being authorized to do so, executed the foregoing instrument for the purposes therein contained by signing the name of Mortgage Electronic Registration Systems, Inc. organized and existing under the laws of the United States of America as an Attorney in Fact for Mortgage Electronic Registration Systems, Inc. organized and existing under the laws of the United States of America. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. L4 o lic My commission expires: I hereby certify the address of the Assignee is: Comm OF A NOTARIAL SEAL MARTIN S. BAIR, NafarlrPubit: City of PNKW Phis Ct> Common March 3, 13 Case #: 89915FC Eyhibit.3 LEGAL DESCRIPTION ALL THAT CERTA j tract of land situate in Hampden Township, Cumberland County, Pennsylvania, known as 4440 Sears Run Drive, bounded and described as follows'- BEGINNING at a point in the center of a public road, which point is 608 feet, more or less, East from the Western side of the bride at Sister's Run and which point is marked by a pin; the," Northwardly along lands now or formerly of Wiiilam H. Morgan et ux and lands now or formcr$ of jobs E. Cline, 210.5 feet to Wbhe Pine at private road; thence Eastwardly along said private road 109.2 feet to as iron 1W thence Southwardly along lands now or formerly of Mrs. Harry Essick and now or formerly of Robert Waiver 196.0 feet to a point in the center of said public road; thence Westwardly along the center of said public road 143.0 feet to the place of Beginning- BEING THE SAME PREMISES which Mel Martinez, Secretary of Housing and Urbana Development of February 6,2003 in the Office of the Washington, D.C., by Deed dated January 21, 2003 andrceo ? in Record Book 255, Page 3323, Recorder of Deeds in and for Cumberland County, e? granted and conveyed unto Donald Barbaro. Parcel No.- 10-18-1314-011 I Certify this to be recorded In Cumberland County PA ,.. Recorder of Deeds Ey,ohibit (B ®Countrywide° NOME LOANS PO Box 9048 Temecula, CA 92589-9048 Send Payments To: PO Box 660694 Dallas, TX 75266-0694 Send Correspondence to: PO Brno 5170, MS SV314B Simi Valley, CA 93065 2210086746 Donald Barbaro 4440 SEARS RUN DR MECHANICSBURG, PA 1 7 050-2 555 000107-7 BLQPA1 PRESORT First-Class Mail U.S. Postage and Fees Paid WSO 1054-10 01 ® Countrywide- HOME LOANS P.O. Box 660694 Dallas, TX 75266-0694 Donald Barbaro 4440 SEARS RUN DR MECHANICSBURG, PA 17050-2555 Send Payments to: PO Box 660694 Dallas, 7X 75266-0694 07/07/2008 Account No.: 73649179 Property Address: 4440 Sears Run Drive Mechanicsburg, PA 1 70 50-2 555 Current Servicer: Countrywide Home Loans Servicing LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached panes. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save vour home. This Notice explains how the proararm works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counselina Aaencv. The names, addresses and phone numbers of Consumer Credit Counselina Agencies servina your County are listed at the end of this Notice. If you have any questions, You may call the Pennsylvania Housing Finance Anencv toll free at 1-800-342-2397. (Persons with impaired hearina can call 1-717-780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACON EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICAC16N OBTENGA UNA TRADUCC16N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NOMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRI=STAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL COAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Donald Barbaro PROPERTY ADDRESS: 4440 Sears Run Drive Mechanicsburo. PA 17050-2555 LOAN ACCT. NO.: 73649179 ORIGINAL LENDER: CURRENT LENDER/SERVICER: Countrywide Home Loans Servicina LP HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS . Make your check payable to Countrywide Home Loans • Write your account number on your check or money order • W rife in any additional amounts you are including (If total is rnore then 55000. please send certified (heck) • Dont attach your check to the payment coupon • Dont include correspondence . Don't send cash ON - Q. Please write your account number on all checks and correspondence. We may charge you a fee for any payment returned a rejected by your financial institution, subject to applicable law. Account Number: 73649179-6 Donald Barbaro Balance Due for charges listed above: $4,782.47 as of 7172008. 4440 Sears Run Drive Please update e-mail information on me reverse side of this coupon. Additional Principal BLQPAI Atlditlonal Eacmw Countrywide PO BOX 660694 one Dallas, TX 75266-0694 II...I.I.1...1.1.11...Mill ....I I..111...1..11.1,..1..1..1.111...1 Chxk Total 073649179600000478247000478247 IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT'), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty ;30) days from the date of this Notice. 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 THE NEXT 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 counselina 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.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. 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.) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 4440 Sears Run Drive Mechanicsburg, PA 17050-2555 IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due Monthly Charaes: 05/04/2008 $4,662.21 Late Charges: 05/04/2008 $120.26 Other Late Charges Total Late Charges: $0.00 Uncollected Costs: $0.00 Partial Payment Balance: ($0.00) TOTAL DUE: $4,782.47 YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable) 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 $4,782.47, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. E-mail use: Providing your e-mail address below will allow us to send you information on your account Account Number: 7MW 79 Donald Barbaro E-mail address How we poet your payrrtentw. AN accepted payments of principal and interest will be applied to the longest outstanding installment due, unless otherwise e)pressly prohibited or limited by law. If you submit an amount in addition In your scheduled monthly amount, we will apply your payments as fdbws: (i) to outstanding monthly payments of principal and interest, (ii) escrow deficiencies, (iii) late charges and other amounts you aye in connection with your loan and (N) bD reduce the outstanding principal balance of your ban. Please specify if you want an additional amount applied to future payments, rather than principal reduction. Postdated checkw. Countrywide's policy is to not accept postdated checks, unless specifically agreed to by a ban counselor or technician. Payments must be made either by cashier's check certified check or money order made payable and sent to: Countrywide at P.O. Box 660694, Dallas, TX 75266-0694. You can cure any other default by takina the following action within THIRTY (30) DAYS of the date of this letter. (Do not use if not applicable) 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. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any 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 Sheriff's 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 defauHed. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgage property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Countrywide Home Loans Servicing LP Address: P. O. Box 660694 Dallas, TX 75266-0694 Phone Number: 1-800-669-0102 Fax Number: 1-805-577-3432 Contact Person: MS PTX-36 Attention: Loan Counselor EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. DE 2210086746 Your loan is in default. Pursuant to your loan documents, Countrywide may, enter upon and conduct an inspection of your property. The purposes of such an inspection are to (i) observe the physical condition of your property, (ii) verify that the property is occupied and/or (iii) determine the identity of the occupant. If you do not cure the default prior to the inspection, other actions to protect the mortgagee's interest in the property (including, but not limited to, winterization, securing the property, and valuation services) may be taken. The costs of the above-described inspections and property preservation efforts will be charged to your account as provided in your security instrument. If you are unable to cure the default on or before August 6, 2008, Countrywide wants you to be aware of various options that may be available to you through Countrywide to prevent a foreclosure sale of your property. For example: Repayment Plan: It is possible that you may be eligible for some form of payment assistance through Countrywide. Our basic plan requires that Countrywide receive, up front, at least 1/2 of the amount necessary to bring the account current, and that the balance of the overdue amount be paid, along with the regular monthly payment, over a defined period of time. Other repayment plans also are available. • Loan Modification: Or, it is possible that the regular monthly payments can be lowered through a modification of the loan by reducing the interest rate and then adding the delinquent payments to the current loan balance. This foreclosure alternative, however, is limited to certain loan types. • Sale of Your Property: Or, if you are willing to sell your home in order to avoid foreclosure, it is possible that the sale of your home can be approved through Countrywide even if your home is worth less than what is owed on it. • Deed-in-Lieu: Or, if your property is free from other liens or encumbrances, and if the default is due to a serious financial hardship which is beyond your control, you may be eligible to deed your property directly to the Noteholder and avoid the foreclosure sale. If you are interested in discussing any of these foreclosure alternatives with Countrywide, you must contact us immediately. If you request assistance, Countrywide will need to evaluate whether that assistance will be extended to you. In the meantime, Countrywide will pursue all of its rights and remedies under the loan documents and as permitted by law, unless it agrees otherwise in writing. Failure to bring your loan current or to enter into a written agreement by August 6, 2008 as outlined above will result in the acceleration of your debt. Time is of the essence- If you have any questions concerning this notice, please contact Loan Counseling Center immediately at 1-800-669-0102. I CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 717.334.1518 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 Community Action Commissior of Captial Region 1514 Derry Street Harrisburg, PA 17104 717232.9757 Loveship, Inc. Maranatha PHFA 2320 North 5th Street 43 Philadelphia Avenue 211 North Front Street Harrisburg, PA 17110 Waynesboro, PA 17268 Harrisburg, PA 17110 717.232.2207 717.762.3285 717.780.3940 800.342.2397 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor FILED-0 iCjE OF 7HE PPP ,, 6;11)N0TARY 2010 JAIN 13 All 10: 26 Deutsche Bank National Trust Company Case Number vs. Donald A Barbaro 2010-283 SHERIFF'S RETURN OF SERVICE 01/11/2010 04:19 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on January 11, 2010 at 1619 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Donald A. Barbaro, by making known unto himself personally, at 4440 Sears Run Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 January 12, 2010 SO ANSWERS, O Y R ANDERSON, SHERIFF By Deputy Sheriff F TE c- :o`l. li In the Court of Common Pleas of Cumberland County DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR THE BENEFIT OF HSI ASSET SECURITIZATION CORPORATION AND HSI ASSET SECURITIZATION CORPORATION TRUST 2007-HE2 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. DONALD BARBARO (Mortgagor(s) and Record Owner(s)) 4440 Sears Run Drive Mechanicsburg, PA 17050 Defendant(s) PRAECIPE FOR JUDGMENT No. 10-283 CIVIL TERM ILI M p THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against DONALD BARBARO by default for want of an Answer. Assess damages as follows: Debt Interest from 2/20/2010 to Date of Sale per diem at $37.08 Total (Assessment of Damages attached) $174,529.85 I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default oc d at least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 By: GOLDBECK NWg#WWW CKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff AND NOW N0,6 AD tp , Judgment is entered in favor of DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR THE BENEFIT OF HSI ASSET SECURITIZATION CORPORATION AND HSI ASSET SECURITIZATION CORPORATION TRUST 2007-HE2 and against DONALD BARBARO by default for want of an Answer and damn es assessed in the of $174,529.85 as per the above certification. Prothonotary ?I¢.oo P.p P`r"11? CIC ? 51$?OD ? a.3sorq Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR THE BENEFIT OF HSI ASSET SECURITIZATION CORPORATION AND HSI ASSET SECURITIZATION CORPORATION TRUST 2007-HE2 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff No. 10-283 CIVIL TERM VS. DONALD BARBARO (Mortgagors and Record Owner(s)) 4440 Sears Run Drive Mechanicsburg, PA 17050 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Proth otary By: If you have any questions concerning the above, please contact: Michael T. McKeever Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 89915FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: February 2, 2010 TO: DONALD BARBARO BARBARO,DONALD 4440 Sears Run Drive Mechanicsburg, PA 17050 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR THE BENEFIT OF HSI ASSET SECURITIZATION CORPORATION AND HSI ASSET SECURITIZATION CORPORATION TRUST 2007-HE2 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. DONALD BARBARO (Mortgagor(s) and Record Owner(s)) 4440 Sears Run Drive Mechanicsburg, PA 17050 TO: DONALD BARBARO 4440 Sears Run Drive Mechanicsburg, PA 17050 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 10-283 CIVIL TERM IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, DONALD BARBARO, is about unknown years of age, that Defendant's last known residence is 4440 Sears Run Drive Mechanicsburg, PA 17050, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: Barb Hand GOLDBECK WCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D. 956129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR THE BENEFIT OF HSI ASSET SECURITIZATION CORPORATION AND HSI ASSET SECURITIZATION CORPORATION TRUST 2007- HE2 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. DONALD BARBARO (Mortgagor(s) and Record owner(s)) 4440 Sears Run Drive Mechanicsburg, PA 17050 Defendant(s) ORDER FOR JUDGMENT IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 10-283 CIVIL TERM Please enter Judgment in favor of DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR THE BENEFIT OF HSI ASSET SECURITIZATION CORPORATION AND HSI ASSET SECURITIZATION CORPORATION TRUST 2007-HE2, and against DONALD BARBARO for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the Unit of America) from the date of service of the Complaint, in the sum of $174,529.85. By: GO CCAFFERTY & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR THE BENEFIT OF HSI ASSET SECURITIZATION CORPORATION AND HSI ASSET SECURITIZATION CORPORATION TRUST 2007-HE2 7105 Corporate Drive PTX C-35 Plano, TX 75024 and that the name(s) and last kno address(es) of the Defendant(s) is/are DONALD BARBARO, 4440 Sears Run Drive Mechanicsburg, PA 1705 ; By: RD ?A I GOLDBECK MCC R MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance Interest from 04/04/2008 through 02/19/2010 Reasonable Attorney's Fee Late Charges Costs of Suit and Title Search Escrow Payments Due 4 X $416.57 $138,254.05 $25,473.96 $6,912.70 $1,322.86 $900.00 $1,666.28 $174,529.85 By: GOL CK M CAFFERTY & MCKEEVER Michael McKeev Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff AND NOW, this 451' day of Pi6 , 2010 damages are assessed as above. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff *o- rafuubt Jody S Smith ?d G4 ChiefDepuly ti t_ Edward L Schorpp ` Sofickor pasiGE OF T}--- SALAiFF Deutsche Bank National Trust Company Case Number vs. 2010-283 Donald A Barbaro SHERIFF'S RETURN OF SERVICE 01/11/2010 04:19 PM - Noah Cline„ Deputy Sheriff, who being duly swum according to law, states that on January 11, 2010 at 1819 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Donald A. Barbaro, by making known unto himseff personally, at 4440 Sears Run Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 January 12, 2010 SO ANSWERS, O R ANDERSON, SHERIFF By DeWty Sheriff ic] C unlySWa SWA Teaasak 4c PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 0 Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR THE BENEFIT OF HSI ASSET SECURITIZATION CORPORATION AND HSI ASSET SECURITIZATION CORPORATION TRUST 2007- HE2 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. DONALD BARBARO Mortgagor(s) and Record Owner(s) 4440 Sears Run Drive Mechanicsburg, PA 17050 Defendant(s) TO THE PROTHONOTARY: r N O cv N Cn r N ?r: 7l -1 f ss :al IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 10-283 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION Issue Writ of Execution in the above matter: O Amount Due *a4.oo Pp ATW 37 06) (?•00 v /if. .2 ---------------------------- Interest from 2/20/2010 to Date of Sale per diem at $37.08 (Costs to be added) $174,529.85 By: (Qw A GO K M AFFERTY & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff cr#slaloo R:r*aasol RE Or it H d W W z O w¢o H V ?OdH w C p? w ??00 y r d Qd o< o Uw HMO zWOO > ?W°7a?7w Q? a.-.?n.? 3 a Na ¢?00 Z o°v C U O ~ O `.4 o0 0 bA p ' ZW dWdd low ? W E. N W??HH C4 F H U U Q U v L ?U w y U ? o Q" ? M N ? d N ? I o Pte. 0 ?o O N ALL THAT CERTAIN tract of land situate in Hampden Township, Cumberland County, Pennsylvania, known as 4440 Sears Run Drive, bounded and described as follows: BEGINNING at a point in the center of a public road, which point is 608 feet, more or less, East from the Western side of the bridge at Sister's Run and which point is marked by a pin; thence Northwardly along lands now or formerly of William H. Morgan et ux and lands now or formerly of John E. Cline, 210.5 feet to White Pine at private road; thence Eastwardly along said private road 109.2 feet to an iron pin; thence Southwardly along lands now or formerly of Mrs. Harry Essick and now or formerly of Robert Weaver 196.0 feet to a point in the center of said public road; thence Westwardly along the center of said public road 143.0 feet to the place of Beginning. BEING THE SAME PREMISES which Mel Martinez, Secretary of Housing and Urban Development of Washington, D.C., by Deed dated January 21, 2003 and recorded February 6, 2003 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Record Book 255, Page 3323, granted and conveyed unto Donald Barbaro. BEING KNOWN AS: 4440 Sears Run Drive, Mechanicsburg, PA 17050 IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 4440 Sears Run Drive Mechanicsburg, PA 17050 SOLD as the property of DONALD BARBARO TAX PARCEL #10-18-1314-011 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO10-283 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Deutsche Bank National Trust Company, as trustee for the Benefit of HSI Asset Securitization Corporation and HSI Asset Securitization Corporation Trust 2007-HE2 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff (s) From Donald Barbaro (1) You are directed to levy upon the property of the defendant (s)and to sell see legal description . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $174,529.85 L.L. $.50 Interest from 02/20/2010 to Date of Sale per diem at $37.08 Atty's Comm % Due Prothy $2.00 Atty Paid $169.50 Plaintiff Paid Date: 2/25/2010 (Seal) Other Costs ?) X4 David . Buell, Protho tary By: REQUESTING PARTY: Name Michael T. McKeever, Esq. Address: Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market St. Philadelphia, PA 19106 Attorney for: Plaintiff Telephone: 215-627-1322 Deputy Supreme Court ID No. 56129 GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQ. ATTORNEY I.D. 456129 SUITE 5000 - MELLON INDEPENDENCE CENTER 70T MARKET STREET PHILADELPHIA, PA 19106-1532 (215)627-I322 ATTORNEY FOR PLAINTIFF DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR THE BENEFIT OF HSI ASSET SECURITIZATION CORPORATION AND HSI ASSET SECURITIZATION CORPORATION TRUST 2007-HE2 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff VS. DONALD BARBARO Mortgagor(s) and Record Owner(s) 4440 Sears Run Drive Mechanicsburg, PA 17050 Defendant(s) iLc[J E T147 cl? ,,_, ,Rv 2010 FF8 25 iN 11: 26 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 10-283 CIVIL TERM CERTIFICATION AS TO THE SALE OF REAL PROPERTY Plaintiff, by counsel, hereby certifies that it has complied with the provisions of Act 91 of 1983 and/or the real property in question is not subject to the Act. By: GOLDBECK kFFERTY & McKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. 456129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR THE BENEFIT OF HSI ASSET SECURTTIZATION CORPORATION AND HSI ASSET SECURITIZATION CORPORATION TRUST 2007-HE2 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. DONALD BARBARO (Mortgagor(s) and Record Owner(s)) 4440 Sears Run Drive Mechanicsburg, PA 17050 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 10-283 CIVIL TERM DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR THE BENEFIT OF HSI ASSET SECURITIZATION CORPORATION AND HSI ASSET SECURITIZATION CORPORATION TRUST 2007-HE2, Plaintiff in the above action, by and through an authorized employee of its attorneys, Goldbeck McCafferty & McKeever, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 4440 Sears Run Drive Mechanicsburg, PA 17050 1.Name and address of Owner(s) or Reputed Owner(s): DONALD BARBARO 4440 Sears Run Drive Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: DONALD BARBARO 4440 Sears Run Drive Mechanicsburg, PA 17050 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 , 'r- T' !: 7,%RY 2010 FEB 2 5 A19 11: 26 r1 r? !_i e;r, IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 4440 Sears Run Drive Mechanicsburg, PA 17050 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. F DATED: February 19, 2010 GOL BEC FFE TY EVER BY: Barb Hand 10-283 CIVIL TERM GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR THE BENEFIT OF HSI ASSET SECURITIZATION CORPORATION AND HSI ASSET SECURITIZATION CORPORATION TRUST 2007- HE2 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE vs. DONALD BARBARO Mortgagor(s) and Record Owner(s) 4440 Sears Run Drive Mechanicsburg, PA 17050 Defendant( Term No. 10-283 CIVIL TERM THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: BARBARO,DONALD DONALD BARBARO 4440 Sears Run Drive Mechanicsburg, PA 17050 Your house at 4440 Sears Run Drive, Mechanicsburg, PA 17050 is scheduled to be sold at Sheriffs Sale on Wednesday, June 02, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $174,529.85 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR THE BENEFIT OF HSI ASSET SECURITIZATION CORPORATION AND HSI ASSET SECURITIZATION CORPORATION TRUST 2007-HE2 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 10-283 CIVIL TERM To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR THE BENEFIT OF HSI ASSET SECURITIZATION CORPORATION AND HSI ASSET SECURITIZATION CORPORATION TRUST 2007-HE2, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: hqp://www.philadelphiafed.orglforeclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 10-283 CIVIL TERM CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 . 4W 10-283 CIVIL TERM Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.orWconsumers/homeowners/real.aWx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionggoldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 89915FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. At. I- THAI. CERTAIN tract of land sitc:ate in Hampden Tm nship_ Cumberland County, Pennsylvania, known as 44-10 Sears Run Drke_ hounded and de,crihcd as follows: BEGINNING at a point in the center of,_r public road, %%hich point is 608 feet. more or less, East from the Western side of the bridge at Sisters Run and ky hich point is marked by a pin: thence North?ardk along lands nokk or formerly of William H. Morgan ei u_t and lands nova or formerly of John F. Cline. 210.5 feet to White Pine at private road: thence Easmardly along said private road 109? feet to an iron pin: thence South??ardly alone lands now or formery of Nlrs_ Ham Essick and nov, or formerly of Ruben Weavtr 196.0 feet to a point in the center ofsaid public road: thence Westwardly alone the center ofsaid public road 143.0 feet to the place of Bezinnin??. BEING THE SAME PRFNIIS1-.S which Met Martinez, Secretary of Housim-, and Urban Development of \Vashington, D.C.. b% Deed dated January 21 2003 and recorded February 6, 2003 in the Office of the Recorder of Deeds in and for Cumberland Count"'. Pennsylvania. in Record Book 255. Pare 3323. ?-,ranted and conveyed unto Donald Barbaro, BEING KNOWN AS: 4440 Sears Run Drive, Mechanicsburg. PA 17050 IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 4440 Sears Run Drive Mechanicsburg, PA 17050 SOLD as the property of DONALD BARBARO TAX PARCEL ;q 10-18-1314-011 SHERIFF'S OFFICE OF CUMBERLAND GOUNTY Ronny R Anuerson Sheriff Jody S Smith Chief Deputy ~~ i~~inif,eryr, ~~ ~d l~;i :- ~oio ~~~ ~s ~~ ~o~ 20 Edward t_ Schorpp Solicitor F - ~h ~(.'~1? ~ .~ .~ r,~, Deutsche Bank National Trust Company I Case Number vs. Donald A Barbaro 2010-283 SHERIFF'S RETURN OF SERVICE 04/05/2010 07:45 PM -Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on April 5, 2010 at 1945 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Donald A. Barbaro, located at 4440 Sears Run Drive, Mechanicsburg, Cumberland County, Pennsylvania according to law. 04!05/2010 07:45 PM -Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on april 5, 2010 at 1945 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Donald A. Barbaro, by making known unto, Donald Barbaro, personally, at 4440 Sears Run Drive, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 05/21/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ is returned STAYED, per letter of instruction from Atty Michael McKeever on 5/20/10 SHERIFF COST: $754.55 SO ANSWERS, ~~ May 21, 2010 RON R ANDERSON, SHERIFF ~. C~ ~.~~' . C'~. a~~~~'~ ~,,~~,~,,:,sa~.n ~~~ r ~~,~~Gt~,~ ,~,:~ t i~!I,~ } tile. 1~~.~rt ~~ ~i,,:'~cc~~t ~,u,>rne~ LD. ~~,(,1 '~) ~ '1 ~UIIC X000 i\1ellrn lndrpenden~c Center li I til~~rl:ci S1rCrl Philadclphia_ PA i ~? 1 Ub ~' i ` t; -, , _~ ~ -, -, '11tc~rnc~ for Plaintil~i~ 1 ~1~:1 il~SCl lt: B ~Nh 'v;~~IIOwAL I~I:I ~S~l~ COIv~1PANY.:1S I~Rt iS"I~t:l~: LOIZ ~I~I IL BV~:NI~.FI~I~ OF l IS1 :1SS1-a~ SECt`Rl~l~ll:l~f[t)N CC~IZPOR:1~1~(ON :AND fISI ASSE'h SLCURI~I~IIA~I~ION CORPORA"LION ~hRUS~I~?007-E1F.~ 710 Corp~~rate llrivc p ~ k ~~_; Plan~~_ "h~ 'S(I?4 Plaintiff vs. 1~ ll 11 t't ~1 !fZ~l~ (>F C0~1~9ON PLE;~S ;,i~t~u~nhcrland County ± ~I\ ll_ .~(' 1 ION - l.A~~' ACTION OI~ R1OKl GAGI FORLCLOSURE DONALD BARBARO (Mortgagor(s) and Record Owner(s)) 444() Sears Run Drive Mechanicsburg. PA 17050 No. ]0-?8> CIV1L ~11;RM Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 DI;U'hSC}III BANK N.A'I~IONAI. TRUS~I- COMPANY'. ;1S ~IlZLS fLF FOIZ ll I1~; [31~.N}:FI~h OI~ NSI ASSET SECL~R1~hlZA~I~ION CORPORATION AND liSl ASSI~:T SEClJR1~I-1ZAl~ION C(~RPOK,~.I~ION TRUS~h?007-HE2. Plaintiff in the above action. by and through an authorized emplo~ce of its attornevs_ (~uldheck I~1c<'ailertv & McKeever_ sets ti~rth as of the date the praccipe for the ~+rit of e~ecutirm was filed the fi~llu~~ in~~ inlorm.~tion concernin<~ the real property li~rited at 4440 Sears Kun Drive Merhanicsbur~~, PA 17050 1.Name and address of Uwncr(s) or Reputed Owner(s): DUNALDBARBARO 444(1 Sears Run Drive Mcchanicsbur<~, PA IiU50 .'. Name and address of Detcndant(s) in the jud~~rnent: DONALDI3ARBARO 4440 Sears Run Drive Mcchanicsbur~~, PA 17050 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA UI-:PAK"hMF.NT (~F pUBI.1C WGI.FARF: -Bureau of Child Support 1;nforcement Health and Welfare Bldg_ -Room 4,2 P.U. Box 26T } {arrisburg, PA 17105-2675 ~i,. ~ ._i'~i, i i~tun~~,m1 ~~It~rrs~~'rh~ ~._ =crier,+~~_~~~, ,I,i .~'~~~~~r~ ni~,n~~,i~~c~,fr~c~~r~t ~- Name and address cif ~~~~r~ <~±ii~r person ~.~hu has am record interest in ur record lien on the pr~~peri~ ,u~d whose interest nr,i~ b~~ .off<ct~~d h~ 1i,c s<<„ _ 6_ Name and address ~,fe~en uthc r ~erscm ~~f~~~inui~ the pli~iniifl has kno~~~led~~c ~~~hu has am_~ mcurd inter:; in the prupert~' which may hr aft~ctru h~ llic s~iic i. Name and address v~~ever~ other ~ersc~^ ~~1 whom the plaintitt has kne~~~led~~e ~iho has any intrrest in the pri~pert~ ~~hich may be atfect~~d h~ rho salr. f E~:~'~'"i~ti (>C~C'l~f':1N1 S -l~l-kU tiears Run L>rive (attach separate sheet ]fmure space is needed) 1 verify that the statenicnts made in this affidavit are true and correct to the best of my personal knowled~~e or information and belieL I understand that Fils~ statements herein are made subject to the penalties ot~ I g P i. C.S. section X904 relatin~~ to unsworn falsiticati~~n to authorities. J--- DATED: Februarv~ (9= 20 I 0 ~.,~.~_--' ,- -- ~' _- - - _ GOI~[ F3LC'k ~ FPER"l~Y LKEEVI.IZ [3Y: Barb Hand ifs-'~' (`1~ ~~~ l± ~ ' w !3`r": !~.licl~acl l_ M.Kcev~~r ~UII~ ~f~(1{)- f`~1~•Il~.m Irid~E~~n~irnce ~'rnte~ 1'I~:iladclE~hia, 1'~~ l4~iii(, .' 1 ~-3? ~-6 ~ 1 Anu~~~r~ (i,r I'I;iin~il`C Df.U~1SC'tff-: t3;~I~~h N;~"ffONAL"I~Kt1S~l~ C'OR1P,~NY, ;1S l Rl_!S~C[;l-: ]=0R ~1~F~E~: BF:Nf:1-1~I~ Ot~ f ISI :~SSE'1~ S}-C(IRl~I1LA"I~IUN CC)I~POK:1 f[ON AND f ISl ASST;"I~ SI:CliIZ1T17A~l~ION C(_)RPORA~IION (RI~Sl~~007 I i1:~ 710=~ C~~rPuratc Drier Plane. "(~X %50?4 IN ~I~1ll~_ ~~Ol!K"l~ ~>1~ C~C>>~9,ti9C)N }'L(~:.~5 01~ Cuml~crland (`~,unt~ ~~IVIL .1t`l~lO1~' - L,1~~' Plaintiff ~`S. DONALDBARBARO Mortgagor(s) and Record OH~ner(s) 4440 Sears Run Drive Mechanicshur~~, PA 17050 Dct~ndant(s ACIIUN (11- I~~OIl.I C~.~1Ci1-. FORECLOSURE-: berm No. 10-?K ~ CfVll. TERM 1~FIlS LAS' FIRM IS A DEBT C'OLLF.C7-OR ANU W E ARt~:.-~T7'E:1~1PT11`~G "I~O COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN AT"I~EMPT ~I~O COLLECT A llEBT. AN}' INFORMATION 067~AINh:U FROM YOU WILL, B1: USF.U FOR THAT PURPOSE. NO"TICE OF SHERIFF'S SALE OF RFAI YROPFRTY DONALD BARBARO =11-10 Sears Run Drive Mechanicsbur<~, PA 17050 Your house at 4440 Sears Run Drive, Mechanicsbur~~. PA I ?~»0 is ~chedultd to he sold at Sheriffs Sale on Wednesda~~. June 02, 2010, at 10:00 AM, in Commissioners Ilearin<~ Rm 2nd ~l. Courthouse to enforce the court judgment of $] 74,529.85 obtained by DEUTSCHE BANK NA1~lONAL TRUST COMPANY. AS TRUS'hEE FOR'THE BENEFIT OF HSl ASSET SECURI~i'17ATION CORPORATION AND HSI ASSET SECURI"i'IIA~I~ION CORPORATION 7RUS~T 2007-1~E2 a<~ainst you. ` NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PRFVENT THIS SHERIFF'S SALE 1(i-~'~;; (~i~~11. i1~R~'~1 ~lo present this Sheriff's Sa[e ~uu nui:,t t~ii~e inunc~iiat~~ actfon~ I. l~he >ale kill he cancelled il~~~u pa; [~~ 1 ~f J `i tiCl {f it \~I~; h:llli ~~i 1i lRl!S I C(?till'_'~,Nl ~~S ~[ Rl!S~I~F:I~_ FOR l~l~l l3l~:?~11~_Fl l t)F IIS1 -,.`;till S)~ l'Kl I~I% All(~'~ ~'(~kl'nK.1~l iON AND IISI ~1SSf~:I Sf Cl'R1 IIL:A IlON l~(~RPUIZ;1~Il~~;ti ! I:l ~Sl 't~u~-III.__ the i~ac{. p;nnicnu, late char~~e>_ i.~usts and reasunahle ath~rne~'s Ices due. l ~~ find out hu~~ much ~ nu nnr;t pay cell our ufiicr at ? 1 ~-g~~-h;~_ 9 or I -i;6i.--~ 1 ~-~ ~ . 1. ~. Yuu mar he able to slap the sale h~ iiin~ .1 l,ctiunn a;kin,~ thi~ (~~urt t~~~ >trfl.e car upon judgment, it [hr judgment ~~as impmperl~ entered. You tr~;~ ,,I>o asf. the ('~~urt t~~ p~~stpunc tlir sale for loud cause. -. You may also hr able to sto~~ the salr thrru_~h uth~~r Ie~~al procee~iin<~s_ =1. You nr+~~ need an attorne~~ to assert ~uu~ rights ~i he suonet _~ uu contact one. the more chance ~'ou ~~~ill have of stuppin~~ thc~ sale. (See ruxice helo~~ uu hu~~ t~~ uht<~in an ,iuornc~). YOU MA1' STIL1. HE Al3LF' TO tiAVE YOUR !'ROPER7~Y AND YOU IIAVE OTHER RICHTS_ F;VF,N IF THE. tiHF:RIFF'S tiAl F DOES NOT "hAKF: PI.AC'E. I . If the ShcrifYs Sale is not stopped, your propert}~ gill be su>Id ro the hi~~hest bidder. You may find out the price bid price by callin<~ the Slteriffof?17-?~1(1-6;90. 2. Y'ou rnav he able to petition the Court to set aside the salt if the bid price was grossl~~ inadequate compared to the value of your properi~~. ~_ l~he sale will ~~o throu~~h only if the bu~~er pa~~s the Sherit~f the Bull amount due in the sale. 7~o find out if this has happened, you ma~~ call the Sheritt of 717-?40-6,90. 4. if the amount due from the l3uver is nut paid to the Sheriff you will remain the owner ot~the pruper-t~~ as ifthe sale ne~~er happened. ~- You have a right to remain irr the pn>pertr until the Bull amount ciao is paid to the Sheritl and the Sheriff ~i~es a deed to the bu~cr.:1t that time_ the f~u~~~r ~na~ hrin~ les_r,il pn~cecdings to e~~ict you. 6. You n~a~ be entitled to a share ufthe munc_~ ~+iiicf; ~~~u paid ic~r your house. A schedule of distribution ofthe money bid 1<~ryour house ~~ill he filed b~~ the Sheriff ~~ithin thirty (30) days from the date ofthc SherifFs Sale. "[~hi< schedule ~~~ill stale ~~.ho ~tiill be rt~cei~~in~t that monut~. l~he n~tonev will be paid oni in accordance ~~ith this schedule unless exceptions (rrason~ why the prof~u~sed distribution is wrong) are filed ~a~ith the Sheriff~~~ithin ten (I O) dais after the schedule ufdistribution is filed. 7. You may also have other rights anti clcicmcs. ur ~tia~~s ut~~cttin~~ ~-our house back. ifs°ou act immediatelx~ alter the sale- 5. ti"ou irrn contact the F~~recl~_»ure Re,uurcc C~cntcr h(tj~__ ~~~~~~,~~hil_td~lohiaf~d.o~~fureclosur~_ YOll SHC)ULD "I~AKF "I-HIS PAPER TO YOt!R L:1 ~~ YI~:R X11 ONCf~:_ IF YOLi DC) N(9~1~ HAVE A I.AWYI:R OK CANNOT AFFORD ONE. GO l~U UK ~fELEPifONF ~i~IiE OFFICE L[S"hED [3ELOW "FO FIND OU"l~ WHFRI~: YC)11 CAN Gl~l~ LEGAL. I1LLP. LEGAL SFRVICF:S 1NC K Irvine Row Carlisle, PA 1701 717-~a ~-9400 (_'l ~1~113F~:R1_:1N1) ('CCUV'~Il' l3.1K ~~S(>(~1:1~IlON Lit~~rt~ 1~~ntir r fZesourcc~ available for (lu~ncu~~ Hers in l~orcclosure ~('"h wt)ti~ r I;~~cn thc~u~h _~~uur Tender (ancl cur rli~nt) has li)erl yin _~cti«n ~,f~'\1~~rt~~a~~c I~~~rcclo~;ur~ a~~ainst ~c~u_ c~,u still n~~t~ h~ able to ~,~1~1~_ `~~Ul ~{Z }1O'~11~ 1~[ZUIv9 1~O1ZI~C1,(~S~1Rt~:. 1 ). Call an attorne.~. for referrals to a qualif~cd attorney cell either ofihc ti>ll~>~~~~in~~ numbers: 7] 7-~~;-9~}OO ~~r ?). Call the Consumer Crcclit C~~~uusclin~~ ;~~~c°nc~ pit I-8O0-')89-2??7 1i~r lice counsclin~~. ~)~ Visit 1~11D-S ~~ehsitc~~~~~~_}1ud.~o~~ for flclh for llorneo~~ncrs I~acin~~ the. Loss of ~1hcir I~omcs. - --- - - ` 4). Pennsylvania Itousin~~ finance :~genc~ also offers other loan programs that may assist homeo~~-Hers in default. Please Sec the PI IFA ~:cbsite http://w~~-~~.phfa.or«/consumers/homeowners/rcal.a~. ~). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or }-Tome Retention options. 6). Call or contact our office to request the amount to bring the account current. or payoff the mortgage or request a Loan Workout / (tome Ketention Package. Call our toll tree number at 1-466-413-2 ~ 11 or via email at liomeretcntion!a)~~oldbccklaw.com. Call Seth at 21 ~-825-6329 or tax ? I S-82ti-6429. "I~he figure and/or packa~~e you requested will be mailed to the address that you request or taped if you leave a message with that information. The attorney in char~~c ofo~~r iirm~s 1 lomeo~~~ner Retention DeparU»ent is David Fein who can be reached at ? 1 ~-82~-6 ~ 18 or Faa: 21 ~-825-6418. Please reference our ~lttornc~~ File Nuil~hcr o1~8991 ~l~C_ Para intornricion cn espanol pucdc cunununicarsc coo Loretta a1 21 ~-825-6344. ELI. "I~F1.1~~ CFRl~-11?v tract rf land situate in I lampd~n l i~~inshi~,. C~innherland Count~~. Pcnns~l~~ania_ kno~~~n ^~ -1-i-i(1 Seam Run ~)f iAe_ F~nUll(IC(j of-~j (~~':,C7l tie(': ;I< tn~~~?N ~ f31:(~1NN1'~JG at a point in ~hr center nl~a puhlfe road_ ~+tiich p~~int is 61iS feet. niure or Icss. Fast tram the ~~~estern si~(e of the l~nd_c a~ Si~tei ~s Kan and ~~hfch paint is marked i~~ t~ pin: thence North~~,anil~ along lands no~c or tornier)~ of ~~ illiatn H. Murcan rt u~ anal lands nou~ or formerly of John f (~hne. ~ Ill. teet tip ~~hitr Pine at private read: thrnec E:ast~wrdly alom~ said private ruail IU~)_~ irct tv an iron pin; thence ~ou[h~4ar~il~. ~.lun,~ .ands nor ~~~ ~urnn.rl~ ,,1 ti'irs. li;irn l~:tsick and nm~ or tormerl~ of Robert '~l~cavcr I~~(~ (~ leer Iu a point in the center of said puhhc n~ad: thc-nee blesn~ardi~. ~ilon<_~ the center of said public read l~} ~.0 feet to the glare o L3e~innin~. I31:IN( ,1 ~I}: S~1h1E; }'KF~1ISLS ~~hich 41x1 :ti9artinez. ~ccrctar~ ~~(llousin~ and L~rhan L>evelopment ul~~l~ashin°toii. I>.C_ h~ Ih~cd dated Januirv ? I, `?00~ and recorded Fehrua~~~ 6 ~pQ; in the <)fiice ofihe Recorder of feeds in and for C'urnEierland Counn~, Pennsvlvani~~. in Record 13~,uk ';~. Pa~~e "~;, <<ranted quid c~m~~~e~ed unto - fonald F3arharo. [3EWG hNOw~N ~1S_-~-~~}O Sr~ir~ Run Uritie. [~1ech~u~icsbur~~_ P,1 I iO~O IMPROVEMENhS consist of a residential dwelling. HEING PRI~MISIS: ~ 4 4 0 ,e~,r:. IZun I)r ~ vE, Mc~c}~~:r,i __-k,ura, i~~"_ ~ 70`>0 SOLD as the property of DON.n1.I) 13AR(3AR0 TAX PnRCI~I. # 1O-l 8-1 ~ 14-0 l 1 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO10-283 Civil CI`dIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Deutsche Bank National Trust Company, as trustee for the Benefit of HSI Asset Securitization Corporation and HSI Asset Securitizat:ion Corporation Trust 2007-HE2 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff (s) From Donald Barbaro (1) You are directed to levy upon the property of the defendant (s)and to sell see legal description . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $174,529.85 L.L. $.50 Interest from 02!2012010 to Date of Sale per diem at $37.08 Atty's Comm % Due Prothy $2.00 Atty Paid $169.50 Plaintiff Paid Other Costs Date: 2/25/20] 0 (Seal) REQUESTING PARTY: Name Michael T. McKeever, Esq. Address: Goldbeck McCafferty & McKeever v Davi uell, Proth otary By: Deputy Suite 5000 -Mellon Independence Center 701 Market St. Philadelphia, PA 19106 Attorney for: Plaintiff Telephone : 215-627-1322 Supreme Court ID No. 56129 On March 22, 2010 the Sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA, Known and numbered, 4440 Sears Run Drive, Mechanicsburg more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 22, 2010 By: r~ Real Estate oordinator r-=: ~~ ~ ~ - uA ,ir O PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1.784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 16, April 23, and Apri130, 2010 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in. the foregoing statements as to time, place and character of publication are true. ~~ ire Marie Cove ,Editor SWZ7RN TO AND SUBSCRIBED before me this 30 da of Aril 201() ~ ~- Notary NOTARI AL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commiaaion Expires Apr 28, 2014 wit xo. 2olo-2s3 civil Deutsche Bank National Trust Company as Trustee under Pooling and Servicing Agreement dated as of May 1, 2007 Securitized Asset Backed Receivables LLC Trust 2007-BR3 vs. Donald A Barbaro Atty: Michael McKeever ALL THAT CERTAIN tract of land situate in Hampden Township, Cumberland County, Pennsylvania, known as 4440 Sears Run Drive, bounded and described as follows: BEGINNING at a point in the center of a public road, which point is 608 feet, more or less, East from the Western side of the bridge at Sis- ter's Run and which point is marked by a pin; thence Northwardly along lands now or formerly of William H. Morgan et ux and lands now or formerly of John E. Cline, 110.5 feet to White Pine at private road; thence Eastwardly along said private road 109.2 feet to an iron pin; thence Southwardly along lands now or for- merly of Mrs. Harry Essick and now or formerly of Robert Weaver 196.0 feet to a point in the center of said public road; thence Westwardly along the center of said public road 143.0 feet to the place of Beginning. BEING THE SAME PREMISES which Mel Martinez, Secretary of Housing and Urban Development of Washington, D.C., by Deed dated January 21, 2003 and recorded February 6, 2003 in the Office of the Recorder of Deeds in and for Cumber- land County, Pennsylvania, in Record Book 255, Page 3323, granted and conveyed unto Donald Barbaro. PARCEL #: 10-18-1314-011. BEING KNOWN AS: 4440 Sears Run Drive, Mechanicsburg, PA 17050. r . - r~::, ', i ,,~ -~ .,. ,. The Patriot-News Co. 2Q20 Technology Pkwy • Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 Ile ~latriot-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 a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday! Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to 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 in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 04/16/10 04/23/10 ~.._~ -~" ~ 04/30/10 Sworn to n subscribed before ire th~8 day of May, 2010 A.D. -- ~_ Notary Public COMMpNyy~-~ ~ PENNSYLVgNIq Sheme L K! Seal Lower Paxton 'Notary PubNc MY CQmm1 TWP•, DauPMn County Member, Penn ~~ Noy' 26, 2011 sVlyarNa ~sociatlon of No taxies Writ tro. 2010-283 Civil Tsrm Deutsctw Bank tratlonal Trust .Company . as Trustee under Pooling and Servicing Agreement dated as of May 1,2007 Securitized Asset Backed Receivables LLC Trust 2007-BR3 vs. Donald A Barbaro Arty: Michael Mckeever ALL THAT CERTAIN tract of land situate in Hampden Township, Cumberland County, Pennsylvania, known as 4440 Sears Run Drive, bounded and described as follows: BEGINNING at a point in the center of a public road, which point is 608 feet,"more or less, East from the Western side of the bridge at Sister's Run and which,point is marked by a pin; thence Northwatd-y along lands now or formerly of William H. Morgan et uz and lands now or formerly of John E. Cline, 210.5 feet to White Pine at private road; thence Eastwardly along said private road 109.2 feet to an iron pin; thence Southwardly along lands now or formerly of Mrs.-hairy Essick and now or formerly of Robert Weaver 196.0 feet to a point in the center of"said public road; thence Westwardly along the center of said public road 143.0 feet to the place of Beginning. BEING THE SAME PREMISES, which Mel Martinez, Secretary of Housing and' Urban Development of Washington, D.C., by Deed dated January 21,2003 and recorded February 6, 2003 in the Office of the Recorder of Deeds in and for Cumberland County. ,Pennsylvania, in Record Book 255, Page 3323, granted and conveyed unto Donald Barbaro. PARCEL #:10.18-1314-011 BEING KNOWN AS: 4440 Sears Run Drive, Mechanicsburg, PA 17050 KML LAW GROUP, P.C. T E ARC HONQTAFfi• Suite 5000 - BNY Mellon Independence Center 701 Market Street 2FE82 A IMf Q: ; j 1 Philadelphia, PA 19106 curseLa?ao eouNTr 215-627-1322 Attorney for Plaintiff PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR THE BENEFIT OF HSI ASSET SECURITIZATION CORPORATION AND HSI ASSET SECURITIZATION CORPORATION TRUST 2007-HE2 Plaintiff vs. DONALD BARBARO (Mortgagor(s) and Record Owner(s)) 4440 Sears Run Drive Mechanicsburg, PA 17050 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 10-283 CIVIL TERM PRAECII'E FOR VOLUNTARY SUBSTITUTION OF PLAINTIFF UNDER Pa.R.C.P. 2352 TO THE PROTHONOTARY: Kindly file of record the Praecipe of BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP, FKA COUNTRYWIDE HOME LOANS SERVICING LP for Voluntary Substitution under Pa.R.C.P. 2352 due to Assignment of Mortgage and attached Statement of Material Facts in Support of Voluntary Substitution, Verification, Certification of Service. The address for the new Plaintiff is 7105 Corporate Drive, PTX C-35, Plano TX, 75024. By: L AW GROUP, P.C. ichael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristin Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff ,so f a'? -? d71c?a P_L.J-71 0?/ KML LAW GROUP, P.C. Suite 5000 - BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR THE BENEFIT OF HSI ASSET SECURITIZATION CORPORATION AND HSI ASSET SECURITIZATION CORPORATION TRUST 2007-HE2 Plaintiff vs. DONALD BARBARO (Mortgagor(s) and Record Owner(s)) 4440 Sears Run Drive Mechanicsburg, PA 17050 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 10-283 CIVIL TERM STATEMENT OF MATERIAL FACTS IN SUPPORT OF VOLUNTARY SUBSITTUTION UNDER Pa.R.C.P. 2352 BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP, FKA COUNTRYWIDE HOME LOANS SERVICING LP, by counsel, hereby voluntarily substitutes itself as Plaintiff in the above-captioned matter and in support thereof represents as follows: 1. The above-captioned Action of Mortgage Foreclosure relates to a property located at 4440 Sears Run Drive Mechanicsburg, PA 17050 ("Property"). 2. Plaintiff holds a mortgage on the Property which is recorded at Mortgage Book4:1968, Page 4477 in the Office of the Recorder of Deeds for Cumberland County. 3. The original Plaintiff in this action is DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR THE BENEFIT OF HSI ASSET SECURITIZATION CORPORATION AND HSI ASSET SECURITIZATION CORPORATION TRUST 2007-HE2. 4. BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP, FKA COUNTRYWIDE HOME LOANS SERVICING LP is the successor in interest to the Plaintiff by an assignment of mortgage recorded in land records of Cumberland County on February 10, 2012 in Instrument # 201204152 and is hereby voluntarily substituted as Plaintiff in the above-captioned matter. Respectfully s By:_K_)PV1 KML LAW GROUP, P.C. ichael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff KML LAW GROUP, P.C. SUITE 5000 - BNY MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 215-627-1322 ATTORNEY FOR PLAINTIFF DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR THE BENEFIT OF HSI ASSET SECURITIZATION CORPORATION AND HSI ASSET SECURITIZATION CORPORATION TRUST 2007- HE2 vs. Plaintiff DONALD BARBARO (Mortgagor(s) and Record Owner(s)) 4440 Sears Run Drive Mechanicsburg, PA 17050 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 10-283 CIVIL TERM CERTIFICATE OF SERVICE Doris Guzman, hereby certifies that he/she did serve true and correct copies of Praecipe for Voluntary Substitution and a 1 s pporting papers attached hereto upon Defendant, by first class mail, postage pre-paid, on 1i1?1 ?I v ?'l' DONALD BARBARO 4440 Sears Run Drive Mechanicsburg, PA 17050 By:KML Laf )(? _? G (Y)w w Group, P.C. Doris Guzman, Legal Assistant Dguzman@kmllawgroup.com 215-825-6402 (Direct Phone) KML LAW GROUP, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff CI THFILED-OFFICE RAR .y: 2011 JUL -3 AM 10: 34 CllM BLAND CouNTY P NNSYLVANIA BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP, FKA COUNTRYWIDE HOME LOANS SERVICING LP Plaintiff vs. DONALD BARBARO (Mortgagor(s) and Record owner(s)) 4440 Sears Run Drive Mechanicsburg, PA 17050 Defendant(s) No. 10-283 CIVIL TERM PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY: Kindly vacate the judgment upon payment of your By: 4 KML L O P.C. Michae McK ver Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff a R.se?d a?'1 .?# a77Soy IN THE COURT OF COMMON PLEAS of Cumberland County KML LAW GROUP, P.C. SUITE 5000 - BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP, FKA COUNTRYWIDE HOME LOANS SERVICING LP Plaintiff vs. DONALD BARBARO (Mortgagor(s) and Record Owner(s)) Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 10-283 CIVIL TERM CERTIFICATE OF SERVICE Angela M. Smith , hereby certifies that he/she did serve true and correct copies of Praecipe to Vacate Judgment and all supporting papers attached hereto upon Defendant, by first class mail, postage pre-paid, on , T-,j/ /0? _- DONALD BARBARO 4440 Sears Run Drive Mechanicsburg, PA 17050 By: KML LAVA' ROUP, P.C. Angela M. Smith , Legal Assistant asmith@kmllawgroup.com 215-825-6325 (Direct Phone) KML LAW GROUP, P.C. FILED-OFFICE Suite 5000 - BNY Mellon Independence C&&HE PROTHONOTAAR'1, 701 Market Street Philadelphia, PA 19106-1532 2012 JUL - 3 AM 10: 3 4 215-627-1322 CUMBERLAND COUNTY BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP, FKA COUNTRYWIDE HOME LOANS SERVICING LP IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. s DONALD BARBARO (Mortgagor(s) and Record owner(s)) 4440 Sears Run Drive Mechanicsburg, PA 17050 Defendant(s) No. 10-283 CIVIL TERM PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended without prejudice upon payment of your costs only. KML LAW GROUP, P.C. FWA GOIt.DBFICK XcC. By: umsmy I& Mid 1 I eever Pa. [D 56129 _Jay E Kivi Pa. ID 26769 Lisa ee P . ID 78020 Kristina Murtha Pa. ID 61858 Thomas Puleo Pa. ID 27615 David Fein Pa. ID 82628 Andrew Gornall Pa. ID 92382 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff & McKEEVER KML LAW GROUP, P.C. Suite 5000 - BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP, FKA COUNTRYWIDE HOME LOANS SERVICING LP Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW DONALD BARBARO (Mortgagor(s) and Record Owner(s)) ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 10-283 CIVIL TERM CERTIFICATE OF SERVICE Angela M. Smith , hereby certifies that he/she did serve true and correct copies of Praecipe to Discontinue and End and all supporting papers attached hereto upon Defendant, by first class mail, postage pre-paid, on J z DONALD BARBARO 4440 Sears Run Drive Mechanicsburg, PA 17050 KML LAW GROUP, P.C. F/K/A GOLDBECK McCAFFER Y & McKEEVER By: gela M. Smith, Legal Assistant asmith@kmllawgroup.com 215-825-6325 (Direct Phone)