HomeMy WebLinkAbout10-0285 QsD
UDREN LAW OFFICES, P.C. ATT IFF
4 ?
MARK J. UDREN, ESQUIRE - ID #04302 v
STUART WINNEG, ESQUIRE - ID #45362 2010 JAN ! I AM 11. 04
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437 fPLi
LOUIS A. SIMONI, ESQUIRE - ID #200869
ADAM L. KAYES, ESQUIRE - ID #86408
MARGUERITE L. THOMAS, ESQUIRE - ID #204460
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Wells Fargo Bank, N.A., as €COURT OF COMMON PLEAS
Trustee for MASTR Asset Backed :CIVIL DIVISION
Securities Trust 2004-OPT2
P.O. Box 961730 `Cumber land County
Irving, TX 75063
Plaintiff
V.
Stephen E. Myers
Michelle M. Myers NO. ,_-
468 Wolfs Bridge Road
Carlisle, PA 17013
Defendant(s)
COMPLAINT IN 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 TARE 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
14 2.6 0 -, CL1 .?/
(2K.xt 19-M3.s
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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.
LAWYERS REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
800-990-9108
AVISO
Le han demandado a usted en la corte. Si usted quiere defenderse
de estas demandas expuestas en las paginas siguientes, usted tiene
veinte (20) dias de plazo al partir de la fecha de la demanda y la
notificacion. Hace falta ascentar 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 avisado que si usted no se dafiende, la corte tomara medidas y
puede continuar la demanda en contra suya sin previo aviso o
notification. Ademas, la corte puede decidir a favor del
demandante y requiere que usted cumpla con todas las provisiones de
esta demanda. Usted puede perder dinero o sus propiedades u otros
derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO
O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN
PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
800-990-9108
NOTICE
The amount of your debt is as stated in the attached document. The name of the creditor
to whom the debt is owed is as named in the attached document. Unless you notify us within
30 days after receipt of this Notice and the attached document that the validity of the stated
debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify
us in writing of a dispute within the 30 day period, we will obtain verification of the debt or
a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not
an admission of liability on your part. Also, upon your written request within the 30 day
period, we will provide you with the name and address of the original creditor if different from
the current creditor.
If you notify us in writing within the 30 day period as stated above, we will cease collection
of your debt, or any disputed portion of it, until we obtain the information that is required
and mail it to you. Once we have mailed to you the required information, we will then
continue the collection of your debt.
This law firm is deemed to be a debt collector and this Notice and the attached document is
an attempt to collect a debt, and any information obtained will be used for that purpose.
UDREN LAW OFFICES, P.C.
/s/ Mark J. Udren, Esquire
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill, NJ 08003-3620
(856) 669-5400
C
1. Plaintiff is the Corporation designated as such in the
caption on a preceding page. Plaintiff is the legal holder of the
Mortgage that is the subject of this action. Current assignments of
mortgage of record are as follows.
Assignor: Option One Mortgage Corp.
Assignments of Record to: Wells Fargo Bank, N.A., as Trustee for
MASTR Asset Backed Securities Trust 2004-OPT2
Recording Date: 7/17/06 Book: 728 Page: 3997
2. Defendant(s) is the individual designated as such on the
caption on a preceding page, whose last known address is as set
forth in the caption, and unless designated otherwise, is the real
owner(s) and mortgagor(s) of the premises being foreclosed.
3. On or about the date appearing on the Mortgage
hereinafter described, at the instance and request of Defendant(s),
Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned
to the Defendant(s) the sum appearing on said Mortgage, which
Mortgage was executed and delivered to Plaintiff as security for
the indebtedness. Said Mortgage is incorporated herein by
reference in accordance with Pa.R.C.P. 1019 (g).
The information regarding the mortgage being foreclosed is as
follows:
MORTGAGED PREMISES: 68 Wolfs Bridge Road
MUNICIPALITY/TOWNSHIP/BOROUGH: Middlesex Township
COUNTY: Cumberland
DATE EXECUTED: 6/9/04
DATE RECORDED: 6/16/04 BOOK: 1869 PAGE: 4636
The legal description of the mortgaged premises is attached hereto
and made part hereof'.
4. Said Mortgage is in default because the required payments
have not been made as set forth below, and by its terms, upon
breach and failure to cure said breach after notice, all sums
secured by said mortgage, together with other charges authorized by
said Mortgage itemized below, shall be immediately due.
5. After demand, the Defendant(s) continues to fail or
C
refuses to comply with the terms of the mortgage as follows:
(a) by failing or refusing to pay the installments of
principal and interest when due in the amounts indicated
below;
(b) by failing or refusing to pay other charges, if any,
indicated below.
6. The following amounts are due on the said Mortgage as of
12/30/09:
Principal of debt due $83,872.53
Unpaid Interest at 3.00%
from 6/1/09 to 12/30/09
(the per diem interest accruing on
this debt is $6.89 and that sum
should be added each day after 12/30/09) 1,464.89
Title Report 325.00
Court Costs (anticipated, excluding
Sheriff's Sale costs) 280.00
Escrow Overdraft/(Balance)
(The monthly escrow on this account
is $117.28 and that sum should
be added on the first of each
month after 12/30/09) 72.89
Late Charges
(monthly late charge of $16.98
should be added in accordance
with the terms of the note
each month after 12/30/09) 118.86
Recoverable Balance 341.99
Attorneys Fees (anticipated and actual
to 50 of principal) 4,193.63
TOTAL $90,669.79
7. The attorney's fee set forth above are in conformity with
the mortgage documents and Pennsylvania law, and will be collected
in the event of a third party purchaser at Sheriff's Sale. If the
0
mortgage is reinstated prior to the sale, reasonable attorney's
fees will be charged in accordance with the reduction provisions of
Act 6, if applicable.
8. The combined notice specified by the Pennsylvania
Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983
and Notice of Intention to Foreclose under Act 6 of 1974 has been
sent to each defendant, via certified and regular mail, in
accordance with the requirements of those acts, on the date
appearing on the copy attached hereto as Exhibit "A", and made part
hereof, and defendant(s) have failed to proceed within the time
limits, or have been determined ineligible, or Plaintiff has not
been notified in a timely manner of Defendant(s) eligibility.
WHEREFORE, the Plaintiff demands judgment, in rem, against
the Defendant(s) herein in the sum of $90,669.79 plus interest,
costs and attorneys fees as more fully set forth in the Complaint,
and for foreclosure and sale of the Mortgaged premises.
UDREN LAW OFFICES, P.C.
BY J,4 (M VAIL L4 A41fWj U/y
Attorneys for Plaintiff
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
LOUIS A. SIMONI, ESQUIRE
ADAM L. KAYES, ESQUIRE
MARGUERITE L. THOMAS, ESQUIRE
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October 1, 2009
7104 5400 2100 2415 9812
0 80 3 fi7 1 6 8
1?I
Michelle M Myers
468 Wolf Bridge Rd
Carlisle, PA 17013-8837
October 1, 2009 A C T 91 NOTI E
TAICKM161 A I TO A E YOUR
HOME FRT6%N 701&-AC?YLOSURE
This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature
of the default is provided in the attached pages.
IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE THREE
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) maybe able to help to save your home. This notice
explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY
WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency.
The name, address, and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice.. If you
have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-341-2397. (Persons with impaired hearing can
call (717) 780-1869).
This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency
may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find
a lawyer.
LA NOTIFICACIO'N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN
SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIO'N OBTENGA UNA TRADUCCIO'N
INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL
NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRE'STAMO 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.
HOMEOWNER'S NAME(S): Michelle M Myers
PROPERTY ADDRESS: 468 Wolfs Bridge Rd
Carlisle, PA 17013
LOAN ACCT. NO.: 0013577143
ORIGINAL LENDER: OPTION ONE MORTGAGE CORPORATION
CURRENT LENDER/SERVICER: American Home Mortgage Servicing, Inc.
EXHIBIT A
Page two
0013577143
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAYBE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE
ASSISTANCE:
* IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
* IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS,
AND
* IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA
HOUSING
FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your
mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must
arrange and attend a "face-to-face" meeting with one of the 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.
CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies
listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting.
The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the
property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to face meeting. Advise
your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this
Notice (see following pages for specific information about the nature of your default). You have the right to apply for
financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and
file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit
counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the
program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To
temporarily stop the lender from filing a foreclosure action, your application MUST be 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 SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A
COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN
APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE
TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS
EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE."
YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE
APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF
YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE
FORECLOSURE WILL BE STOPPED.
AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the
Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days
to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against
you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing
Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTL Y PROTECTED BY THE FILING OFA PETITION IN BANKRUPTCY, THE
FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLYAND SHOULD NOT BE
CONSIDERED AS ANATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for
Emergency Mortgage Assistance.)
C-
Page three
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:
468 Wolfs Bridge Rd, Carlisle, PA 17013
IS SERIOUSLY IN DEFAULT because:
0013577143
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are
now past due:
(a) Monthly payments from 07/01/2009:
(b) Late charge(s):
(c) Other charge(s): NSF and Advances
(d) Less: Credit Balance
(e) Total amount required as of 09/30/2009:
$1,200.80
$67.92
$341.99
$0.00
$1,610.71
HOW TO CURE THE DEFAULT - You may cure this default within THIRTY (30) DAYS from the date of this Notice BY
PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $1,610.71, PLUS ANY MORTGAGE
PAYMENTS AND LATE CHARGES (and other 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:
American Home Mortgage Servicing, Inc.
1525 S. Beltline Rd. Coppell, TX 75019
IF YOU DO NOT CURE THE DEFAULT- If you do not cure the default within THIRTY (30) DAYS of date of this Notice,
the lender intends to exercise its right 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) DAYperiod, 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) DAYperiod 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 writing by the lender and by performing any other requirements under the
mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position
as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the
mortgaged property could be held would be approximately five (5) 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.
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Page four 0013577143
HOW TO CONTACT THE LENDER
Name of Lender: American Home Mortgage Servicing, Inc.
Address: 1525 S. Beltline Rd. Coppell, TX 75019
Telephone Number: 1-866-612-3730
Fax Number: 1-866-497-1263
Contact Person: Trivonda Porter, Sara Haliko and Selena Moore
E-mail Address: Trivonda.porter@ahmsi3.com, Sara.haliko@ahmsi3.com,
selena.moore@ahrisi3.com
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 Sheriff s 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 not 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.
YOUMAYALSO 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.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
CAN BE FOUND ON PAGES S-7.
American Home Mortgage Servicing, Inc. is attempting to collect a debt, and any information obtained will be used
for that purpose.
Federal law gives you thirty days after you receive this letter to dispute the validity of this debt or any part of it.
Unless you dispute the debt within that 30 day period, we will assume that it is valid. If you notify us in writing at the
address below within the thirty day period that the debt, or any portion thereof, is disputed, we will:
1) Provide to you verification of the debt or a copy of any judgment entered against you.
2) Provide to you the name and address of your original creditor, if the original creditor is different from the
current creditor.
Sincerely,
American Home Mortgage Servicing, Inc.
American Home Mortgage Servicing, Inc. 1525 S. Beltline Rd. Coppell, TX 75019, 1-866-612-3730
0
" Indicates Counties Serviced
Acorn Housing Corporation
846 North Broad Street
Philadelphia, PA 19130
(215) 765-1221
'Bucks, Chester, Delaware, Montgomery
Philadelphia
Action Housing Inc
425 6th Avenue, Suite 950
Pittsburgh, PA 15219
(412) 281-2102
'Allegheny, Beaver, Butler, Fayette, Greene,
Washington, Westmoreland
Adams County Interfaith Housing Authority
40 E High Street
Gettysburg, PA 17325
(717)334.1518
'Adams, Cumberland, Franklin, York
Advocates for Financial Independence
1806 S Broad Street, Suite 1B
Philadelphia, PA 19145
(215) 389-2810
'Philadelphia
Advocates for Financial Independence
202 East Hinkley Avenue
Ridley Park, PA 19078
(215) 389-2810
'Delaware
Allegheny County Acorn
5907 Penn Avenue, Suite 300
Pittsburgh, PA 15206
(412) 441-6551
'Allegheny
American Credit Counseling Institute
21 S Church Street
West Chester, PA 19380
(888) 212-6741
'Chester
American Credit Couseling Institute
526-528 Dekalb Street
Norristown, PA 19401
(610) 971-2210
(888) 212-6741
'Montgomery, Delaware
American Credit Counseling Institute
530 W Street Road, Suite 201
Warminster, PA 18974
(215) 444-9429
(888) 212-6741
'Bucks, Montgomery, Philadelphia
American Credit Counseling Institute
937 North Hanover Street
Pottstown, PA 19460
(888) 212-6741
'Barks, Bucks, Montgomery
American Credit Counseling Institute
229 East Chestnut Street
Coatesville, PA 19320
(888) 212-6741
`Chester, Lancaster
American Financial Counseling Services
871 N. Easton Road
Glenside, PA 19038
(267) 228-7903
`Mifflin
American Financial Counseling Services
405 West Germantown Pike
Norristown, PA 19403
(267) 228-7903
'Mifflin, Montgomery
American Financial Counseling Services
2880 Bergey Road Suite 4
Hatfield, PA 19440
(267) 228-7903
`Barks, Chester, Montgomery
American Financial Counseling Services
175 Strafford Avenue, Suite One
Wayne, PA 19087
(610) 971-2210
(888) 212-6741
'Bucks, Chester, Delaware, Mongomery,
Philadelphia
American Financial Counseling Services
906 Penn Avenue
Wyomissing, PA 19610
(267) 228-7903
(800) 490-3039
'Barks
American Financial Counseling Services
871 N. Easton Road
Glenside, PA 19038
(267) 228-7903
'Montgomery
American Financial Counseling Services
1917 Welsh Road
Philadelphia, PA 19115, PA 19610
(267) 228-7903
'Bucks, Montgomery, Philadelphia
American Red Cross - Hanover Chapter
529 Carlisle Street
Hanover, PA 17331
(717)637-3768
'Adams, Franklin, York
American Red Cross of Chester
1729 Edgemont Avenue
Chester, PA. 19013
(610) 874-1484
'Chester. Delaware
APM
2147 Nortt Sixth Street
Philadelphia, PA 19122
(215) 235-6788
'Chester, Delaware, Philadelphia, Bucks
Armstrong CO Community Action Agency
124 Armsdale Road, Suite 211
Kittanning, PA 16201
(724) 548-3405
'Armstrong
Base, Inc.
447 South Prince Street
Lancaster, PA 17603
(717) 392-5467
'Lancaster
Blair County Community Action Agency
2100 6th Avenue, Suite 102
P.O. Box 1833
Altoona, PA 16602
(814)946.3651
'Blair
Booker T. Washington Center
1720 Holland Street
Erie, PA 16503
(814) 453-5744
'Crawford, Erie, Warren
Bucks County Housing Group
200 West Bridge Street
Morrisville, PA 19067
(866) 866-0280
'Bucks
Bucks County Housing Group
2324 Second Street Pike, Suite 17
Wdghtstown, PA 18940
(866)866.0280
'Bucks
Bucks County Housing Group
470 Old Dublin Pike
Doylestown, PA 18901
(866) 866-0280
'Bucks
Bucks County Housing Group
349 Durham Road
Penndel, PA 19047
(866) 866-0280
'Bucks
Bucks County Housing Group
515 West End Blvd
Quakertown, PA 18951
(866) 866-0280
'Bucks
Budget Counseling Center
247 North Fifth Street
Reading, PA 19601
(610) 375-7866
'Barks, Chester, Schuylkill
Carroll Park Community Council, Inc.
5218 Master Street
Philadelphia, PA 19131
(215) 877-1157
'Chester, Delaware, Philadelphia
Catholic Social Services
Saint Catherine Manor
5 Knox Road
Scranton, PA 18505
(570) 558-3019
'Wyoming, Wayne, Bucks, Lackawanna,
Monroe, Philadelphia
CCCS of Delaware Valley
1230 New Rodgers Road, Suite F1
Bristol, PA 19007
(215) 563-5665
'Bucks
CCCS of Delaware Valley
1777 Sentry Parkway W, Suite 200
Blue Bell, PA 19422
(215) 563-5665
'Montgomery
CCCS of Delaware Valley
280 North Providence Road
Media, PA 19063
(215) 563-5665
'Chester
CCCS of Delaware Valley
Marshal Building
790 E Market St, Suite 170
West Chester, PA 19382
(215) 563-5665
'Chester, Bucks
CCCS of Delaware Valley
Catholic Social Services Building
7340 Jackson Street
Philadelphia, PA 19136
(215) 563-5665
'Bucks, Philadelphia
CCCS of Delaware Valley
One Cherry Hill, Suite 215
Cherry Hill, PA 08002
(215) 563-5665
'Philadelphia
CCCS of Lehigh Valley
3671 Crescent Court East
Whitehall, PA 18052
(610) 821-4011
(800) 837-9815
'Berks. Bucks, Carbon, Lancaster, Lehigh,
Northhampton, Schuylkill
CCCS of Northeastern PA
201 Basin Street, Suite 6
Williamsport, PA 17701
(570) 323-6627
'Centre, Clinton, Lycoming, Northumberland,
Union
CCCS of Northeastern PA
202 W Hamilton Avenue
State College, PA 16801
(814) 238-3668
'Blair, Centre, Clearfield, Clinton, Huntingdon,
Juniata, Mifflin
CCCS of Northeastern PA
401 Laurel Street
Pittston, PA 18640
(570) 602-2227
'Bradford, Carbon, Columbia, Lackawanna,
Lycoming, Monroe, Montour, Northumberland,
Pike, Sullivan, Tioga, Union, Wayne, Wyoming
CCCS of Northeastern PA
411 Main Street, Suite 104
Stroudsburg, PA 18360
(570) 420-8980
'Bradford, Carbon, Monroe, Pike, Wayne
CCCS of Western PA
1 North Gate Square #2
Garden Center Dr
Greensburg, PA 15601
(888) 511-2227
'Fayette, Greene, Indiana, Somerset,
Washington, Westmoreland
CCCS of Western PA
55 Clover Hill Road
Dallastown, PA 17313
(888) 511-2227
'Fulton, Crawford, Lancaster
C,
* Indicates Counties Serviced
CCCS of Western PA
2000 Linglestown Road
Harrisburg, PA 17102
(888) 511-2227
'Adams, Cumberland, Dauphin, Franklin, Perry,
Synder, York
CCCS of Western PA
312 Chestnut Street, Suite 227
Meadville, PA 16335
(888) 511-2227
'Lawrence
CCCS of Western PA
41 East Chestnut Street
Washington, PA 15301
(888) 511-2227
'Westmoreland
CCCS of Western PA
4402 Peach Street
Erie, PA 16509
(888) 511-2227
'Crawford, Ede, Warren
CCCS of Western PA
524 Franklin Avenue
Aliquippa, PA 15001
(888) 511-2227
*Cambria
CCCS of Western PA
917 A Logan Boulevard
Altoona, PA 16602
(888) 511-2227
'Armstrong, Bedford, Blair, Cambria, Centre,
Clearfield, Huntingdon, Juniata, Mifflin, Union
CCCS of Western PA
Pullman Commerce Center
112 Hollywood Dr
Butler, PA 16001
(888) 511-2227
'Butler, Clarion, Jefferson, Mercer, Venango
CCCS of Western PA
River Park Commons
2403 Sidney Street
Pittsburgh, PA 15203
(888) 511-2227
'Allegheny
Center for Family Services, Inc.
213 Center Street
Meadville, PA 16335
(814) 337-8450
'Columbia, Venango
Centro Pedro Clever, Inc
627 West Ede Avenue
Philadelpia, PA 19140
(215) 227-7111
'Philadelphia
Chester Community Improvement Project
412 Avenue of the States
P.O. Box 541
Chester, PA 19016
(610) 876-8663
'Chester, Delaware, Montgomery, Philadelphia
Comm. On Econ Opportunity of Luzeme Co.
163 Amber Lane
Wilkes-Barre, PA 18702
(570) 826-0510
'Carbon, Luzeme, Schuylkill, Wyoming
Community Action Commission of Capital
Region
1514 Derry Street
Harrisburg, PA 17094
(717) 232-9757
'Cumberland, Dauphin, Franklin, Perry, Synder
Community Action Committee of the Lehigh
Valley
1337 East Fifth Street
Bethlehem, PA 18015
(610) 6915620
'Barks, Carbon, Lehigh, Monroe,
Northhampton
Community Action Development Comm
CADCOM
113 E Main Street
Norristown, PA 19401
(610) 2775363
'Montgomery
Community Action Southwest
150 W Beau Street, Suite 304
Washington, PA 15301
(724) 225-9550
'Monroe
Community Action Southwest
58 E Greene Street
Waynesburg, PA 15370
(724) 852-2893
'Allegheny, York, Fayette, Greene,
Washington Westmoreland
Comm. on Eoon. Opportunity of Luzeme
County
163 Amber Lane
WilkesBarre, PA 18702
(570) 826-0510
(800) 822-0359
'Wyoming
Congreso
216 West Somerset Street
Philadelphia, PA 19133
(215) 763-8870
'Philadelphia
Council of Spanish Speaking Organization
705-09 North Franklin St
Philadelphia, PA 19123
(215) 627-3100
'Philadelphia
Credit Counseling Center
832 Second Street Pike
Richboro, PA 18954
(215) 3961880
'Bucks
Diversified Community Service
Dixon House
1920 South 20th Street
Philadelphia, PA 19145
(215) 336-3511
'Bucks, Chester, Delaware, Philadelphia
Fair Housing Partnership of Greater Pittsburgh,
Inc.
2640 Libedty Ave., Suite 205
Pittsburgh, PA 15222
(412) 391-2535
'Allegheny
Fayette Co. Community Action Agency Inc
137 North Beeson Avenue
Uniontown, PA 15401
(724) 437-6050
'Fayette, Somerset
FOB CDC
1201 West Only Avenue
Philadelphia, PA 19141
(215) 549-8755
'Bucks, Chester, Delaware, Philadelphia
Garfield Jubilee Associates
5138 Penn Avenue
Pittsburgh, PA 15224
(412) 665-5200
'Allegheny
Germantown Settlement
5538 Wayne Avenue Bldg C
Philadelphia, PA 19144
(215) 849-3104
'Bucks, Chester, Delaware, Montgomery,
Philadelphia
Greater Ede Commun. Action Committee
18 West 9th Street
Erie, PA 16501
(814) 459-4581
'Crawford, Erie, Venango, Warren
HACE
167 W Allegheny Ave., 2nd Floor
Philadelphia, PA 19140
(215) 426-8025
'Bucks, Chester, Delaware, Philadelphia
Hispanic Alliance for Community Advancement
2740 North Front Street
Philadelphia, PA 19133
(215) 667-8932
'Monroe
Housing Assoc. of Delaware Valley
668 North Watts Street
Philadelphia, PA 19123
(215) 978-0224
'Philadelphia, Monroe
Housing Opportunities of Beaver Co.
320 College Avenue, Unit 1
Beaver, PA 15009
(724) 728-7511
'Beaver, Lawrence
Housing Partnership of Chester County
41 West Lancaster Avenue
Downingtown, PA 19335
(610) 5161522
'Chester, Delaware, Montgomery
Indiana Co. Community Action Frog.
827 Water Street Box 187
Indiana, PA 15701
(724) 465-2657
'Armstrong, Cambria, Clearfield, Indiana,
Jefferson, Westmoreland
Intercultural Family Services Inc.
4225 Chestnut Street
Philadelphia, PA 19104
(215) 386-1298
'Philadelphia
Korean Comm. Develop. Services Center
6055 North 5th Street
Philadelphia, PA 18505
(215) 276-8830
'Philadelphia
Lawrence County Social Services, Inc.
241 West Grant Street
P.O. Box 189
New Castle, PA 16103
(724) 658-7258
'Lawrence
Liberty Resources
714 Market Street, Suite 100
Philadelphia, PA 19106
(215) 6342000
'Philadelphia
Loveship, Inc.
2320 North 5th Street
Harrisburg, PA 1711
(717) 232-2207
'Cumbedand, Dauphin, Perry
Lycom-Clntn Co Comm fo Comm Action
2138 Lincoln Street
P.O. Box 3568
Williamsport, PA 17703
(570)326.0587
'Centre, Clinton, Lycoming, Union
Maranatha
43 Philadelphia Avenue
Waynesboro, PA 17268
(717) 762-3285
'Adams, Cumberland, Franklin, Fulton, Perry
Media Fellowship House
302 South Jackson Street
Media, PA 19063
(610) 565-0434
'Chester, Delaware
Mon Valley Unemployment Committee
1800 West SL, 3rd Floor
Homestead, PA 15120
(412) 462-9962
'Allegheny, Washington, Westmoreland
Mt. Airy, USA
6703 Germantown Ave., Suite 200
Philadelphia, PA 19119
(215) 8446021
'Philadelphia
Nazareth Housing Services
301 Bellevue Road
Pittsburgh, PA 15229
(412) 931-6996
'Allegheny
* Indicates Counties Serviced
Neighborhood Housing Services of Reading
213 N 5th St., Suite 1030
Reading, PA 19601
(610) 372-8433
'Barks
Neighborhood Housing Services, Inc.
710 5th Avenue, Suite 1000
Pittsburgh, PA 15219
(412) 281-9773
'Allegheny
New Kensignton Community Development
2515 Frankford Avenue
Philadelphia, PA 19125
(215) 427-0350
'Warren
The NORCAM Group
4200 Crawford Avenue Suite 200
Northern Cambria, PA 15714
(814) 948-4444
'Cambria, Clearfield
Northern Tier Community Action Corp.
135 West 4th Street
P.O. Box 389
Emporium, PA 15834
(814)4861161
'Cameron, Elk, Mcksan, Potter
Northwest Counseling Service
5001 North Broad Street
Philadelphia, PA 19141
(215) 324-7500
'Bucks, Chester, Delaware, Montgomery,
Philadelphia
Nueva Esperanza
4261 North 5th Street
Philadelphia, PA 19140
(215) 324-0746
'Philadelphia
Opportunity Inc.
301 East Market Street
York, PA 17403
(717) 424-3645
'Montgomery
The Partnership CDC
4020 Market Street, Suite 100
Philadelphia, PA 19104
(215) 662-1612
'Monroe
Pennsylvania Housing Finance Agency
2275 Swallow Hill Rd., Bldg 200
Pittsburgh, PA 15220
(412) 429-2842
'Allegheny
PHFA
211 North Front Street
Harrisburg, PA 17110
(800-) 342-2397
'Cumbedand, Dauphin
Philadelphia Council for Comm. Advmnt.
100 N 17th St, Suite 600
Philadelphia, PA 19103
(215) 567-7803
(800) 930-4663
'Chester, Delaware, Montgomery, Philadelphia
Philadelphia Senior Center
509 South Broad Street
Philadelphia, PA 19147
(215) 546-5879
'Philadelphia
Schuylkill Community Action
225 N. Centre Street
Pottsville, PA 17901
(570) 622-1995
'Barks, Carbon, Lebanon, Lehigh, Luzeme,
Northumberland, Schuylkill
Shenango Valley Urban League, Inc.
601 Indiana Avenue
Farrell, PA 16121
(724) 981-5310
'Crawford, Lawrence, Mercer
South Philadelphia H.O.M.E.S.
1444 Point Breeze Avenue
Philadelphia, PA 19146
(215) 334-4430
'Philadelphia
Southwest Community Development Corp.
6368 Paschall Avenue
Philadelphia, PA 19142
(215) 729-0800
'Montgomery
St. Martin Center
1701 Parade Street
Erie, PA 16503
(814) 452-6113
'Crawford, Erie. Venango, Warren
Tableland Services Inc.
535 East Main Street
Somerset, PA 15501
(814) 445-9628
'Cambria, Fayette, Somerset, Westmoreland
Tabor Community Services
308 E King Street, Suite 1
Lancaster, PA 17602
(717) 397-5182
(800) 788-5062
'Chester, Lancaster, Lebanon
The Trehab Center of Northeastern PA
10 Public Avenue
P.O. Box 366
Montrose, PA 18801
(570) 278-3338
(800) 982-4045
'Susquehanna
The Trehab Center of Northeastern PA
115 SR 92S
Tuckhannock, PA 18657
(570) 836-6840
(800) 982-4045
'Wyoming
The Trehab Center of of Northeastern PA
1225 Main Street
Honesdale, PA 18431
(570) 253-8941
(800) 982-4045
'Bradford, Sullivan, Susquehanna, Tioga,
Wayne, Wyoming
The Trehab Center of Northeastern PA
144 E East Avenue
Wellsboro, PA 16901
(570) 724-5252
(800) 982-0045
'Tioga
The Trehab Center of Northeastern PA
Gartman Street
P.O. Box 389
Dushore, PA 18614
(570) 928-9667
(800) 982-4045
'Sullivan
The Trehab Center of Northeastern PA
The Enterprise Center
703 S. Elmer Ave., Suite M-6
Sayre, PA 18840
(570) 888-0412
(800) 982-4045
'Bradford
United Communties Southeast Philadelphia
2029 South 8th Street
Philadelphia, PA 19148
(215) 467-8700
'Philadelphia
United Neighborhood Centers of Northeastern
PA
425 Alder Street
Scranton, PA 18505
(570) 346-0759
'Lackawanna, Wyoming, Wayne, Luzeme
Urban League of Philadelphia
1818 Market Street
Philadelphia, PA 19103
(215) 561-6070
'Bucks, Delaware, Philadelphia
Urban League of Philadelphia
610 Wood Street
Pittsburgh, PA 15229
(412) 931-6996
'Allegheny
Voices for Independence
1107 Payne Avenue
Ede, PA 16503
(814) 874-0064
(800) 838-9890
'Erie
Warren-Forest Counties Economic Opportunity
Council
1209 Pennsylvania Ave W.
P.O. Box 547
Warren, PA 16365
(814) 726-2400
'Forest, Waren
West Oak Lane CDC
6259 Limekiln Pike
Philadelphia, PA 1914
(215) 224-0880
'Monroe
C
AH 1 M401
?r
October 1, 2009
7104 5400 2100 2415 9829
I Stephen E Myers
468 Wolf Bridge Rd
Carlisle, PA 17013-8837 A October 1, 2HOM009
This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature
of the default is provided in the attached pages.
IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE THREE
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) maybe able to help to save your home. This notice
explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY
WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency.
The name, address, and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you
have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can
call (717) 780-1869).
This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency
may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find
a lawyer.
LA NOTIFICACIO'N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN
SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIO'N OBTENGA UNA TRADUCCIO'N
INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL
NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRE'STAMO 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.
HOMEOWNER'S NAME(S): Stephen E Myers
PROPERTY ADDRESS: 468 Wolfs Bridge Rd
Carlisle, PA 17013
LOAN ACCT. NO.: 0013577143
ORIGINAL LENDER: OPTION ONE MORTGAGE CORPORATION
CURRENT LENDER/SERVICER: American Home Mortgage Servicing, Inc.
0
Pagetwo
0013577143
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAYBE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE
ASSISTANCE:
* IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
* IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS,
AND
* IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA
HOUSING
FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your
mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must
arrange and attend a "face-to-face" meeting with one of the 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.
CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies
listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting.
The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the
property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to face meeting. Advise
your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this
Notice (see following pages for specific information about the nature of your default). You have the right to apply for
financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and
file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit
counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the
program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To
temporarily stop the lender from filing a foreclosure action, your application MUST be 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 SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A
COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN
APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE
TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS
EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE."
YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE
APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF
YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE
FORECLOSURE WILL BE STOPPED.
AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the
Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days
to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against
you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing
Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTL Y PROTECTED BY THE FILING OFA PETITION IN BANKRUPTCY, THE
FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLYAND SHOULD NOT BE
CONSIDERED AS ANATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for
Emergency Mortgage Assistance.)
C
Page three
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:
468 Wolfs Bridge Rd, Carlisle, PA 17013
IS SERIOUSLY IN DEFAULT because:
0013577143
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are
now past due:
(a) Monthly payments from 07/01/2009:
(b) Late charge(s):
(c) Other charge(s): NSF and Advances
(d) Less: Credit Balance
(e) Total amount required as of 09/30/2009:
$1,200.80
$67.92
$341.99
$0.00
$1,610.71
HOW TO CURE THE DEFAULT - You may cure this default within THIRTY (30) DAYS from the date of this Notice BY
PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $1,610.71, PLUS ANY MORTGAGE
PAYMENTS AND LATE CHARGES (and other 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:
American Home Mortggage Servicingg,, Inc.
1525 S. Beltline Rd. Copp ell, TX T5019
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of date of this Notice,
the lender intends to exercise its right 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.ifyou cure the default within the THIRTY (30) DAYperiod, 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) DAYperiod 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 writing by the lender and by performing any other requirements under the
mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position
as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the
mortgaged property could be held would be approximately five (5) 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.
C.
Page four 0013577143
HOW TO CONTACT THE LENDER
Name of Lender: American Home Mortgage Servicing, Inc.
Address: 1525 S. Beltline Rd. Coppell, TX 75019
Telephone Number: 1-866-612-3730
Fax Number: 1-866-497-1263
Contact Person: Trivonda Porter, Sara Haliko and Selena Moore
E-mail Address: Trivonda.porter@ahmsi3.com, Sara.haliko@ahmsi3.com,
selena.moore@ahmsi3.com
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 not 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.
YOUMAYALSO 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.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
CAN BE FOUND ON PAGES S-7.
American Home Mortgage Servicing, Inc. is attempting to collect a debt, and any information obtained will be used
for that purpose.
Federal law gives you thirty days after you receive this letter to dispute the validity of this debt or any part of it.
Unless you dispute the debt within that 30 day period, we will assume that it is valid. If you notify us in writing at the
address below within the thirty day period that the debt, or any portion thereof, is disputed, we will:
1) Provide to you verification of the debt or a copy of any judgment entered against you.
2) Provide to you the name and address of your original creditor, if the original creditor is different from the
current creditor.
Sincerely,
American Home Mortgage Servicing, Inc.
American Home Mortgage Servicing, Inc. 1525 S. Beltline Rd. Coppell, TX 75019, 1-866-612-3730
C'
" Indicates Counties Serviced
Acorn Housing Corporation
846 North Broad Street
Philadelphia, PA 19130
(215) 765-1221
'Bucks, Chester, Delaware, Montgomery,
Philadelphia
Action Housing Inc
425 6th Avenue, Suite 950
Pittsburgh, PA 15219
(412) 281-2102
'Allegheny, Beaver, Butler, Fayette, Greene,
Washington, Westmoreland
Adams County Interfaith Housing Authority
40 E High Street
Gettysburg, PA 17325
(717) 334-1518
'Adams, Cumberland, Franklin, York
Advocates for Financial Independence
1806 S Broad Street, Suite 1 B
Philadelphia, PA 19145
(215) 389-2810
'Philadelphia
Advocates for Financial Independence
202 East Hinkley Avenue
Ridley Park, PA 19078
(215) 389-2810
'Delaware
Allegheny County Acorn
5907 Penn Avenue, Suite 300
Pittsburgh, PA 15206
(412) 441-6551
'Allegheny
American Credit Counseling Institute
21 S Church Street
West Chester, PA 19380
(888) 212-6741
'Chester
American Credit Couseling Institute
526-528 Dekalb Street
Norristown, PA 19401
(610) 971-2210
(888) 212-6741
'Montgomery, Delaware
American Credit Counseling Institute
530 W Street Road, Suite 201
Warminster, PA 18974
(215) 444-9429
(888) 212-6741
'Bucks, Montgomery, Philadelphia
American Credit Counseling Institute
937 North Hanover Street
Pottstown, PA 19460
(888) 212-6741
'Barks, Bucks, Montgomery
American Credit Counseling Institute
229 East Chestnut Street
Coatesville, PA 19320
(888) 212-6741
'Chester. Lancaster
American Financial Counseling Services
871 N. Easton Road
Glenside, PA 19038
(267) 228-7903
'Mifflin
American Financial Counseling Services
405 West Germantown Pike
Norristown, PA 19403
(267) 228-7903
'Mifflin, Montgomery
American Financial Counseling Services
2880 Bergey Road Suite 4
Hatfield, PA 19440
(267) 228-7903
'Barks, Chester, Montgomery
American Financial Counseling Services
175 Strafford Avenue, Suite One
Wayne, PA 19087
(610) 971-2210
(888) 212-6741
'Bucks, Chester, Delaware, Mongomery,
Philadelphia
American Financial Counseling Services
906 Penn Avenue
Wyomissing, PA 19610
(267) 228-7903
(800) 490-3039
'Berks
American Financial Counseling Services
871 N. Easton Road
Glenside, PA 19038
(267) 228-7903
'Montgomery
American Financial Counseling Services
1917 Welsh Road
Philadelphia, PA 19115, PA 19610
(267) 228-7903
'Bucks, Montgomery, Philadelphia
American Red Cross - Hanover Chapter
529 Carlisle Street
Hanover, PA 17331
(717) 637-3768
'Adams, Franklin, York
American Red Cross of Chester
1729 Edgemont Avenue
Chester, PA 19013
(610) 874-1484
'Chester, Delaware
APM
2147 Nortt Sixth Street
Philadelphia, PA 19122
(215) 235-6788
'Chester, Delaware, Philadelphia, Bucks
Armstrong CO Community Action Agency
124 Armsdale Road, Suite 211
Kittanning, PA 16201
(724) 548-3405
'Armstrong
Base, Inc.
447 South Prince Street
Lancaster, PA 17603
(717) 392-5467
'Lancaster
Blair County Community Action Agency
2100 6th Avenue, Suite 102
P.O. Box 1833
Altoona, PA 16602
(814) 946-3651
'Blair
Booker T. Washington Center
1720 Holland Street
Erie, PA 16503
(814) 453-5744
'Crawford, Ede, Warren
Bucks County Housing Group
200 West Bridge Street
Morrisville, PA 19067
(866) 866-0280
'Bucks
Bucks County Housing Group
2324 Second Street Pike, Suite 17
Wrightstown, PA 18940
(866) 866-0280
'Bucks
Bucks County Housing Group
470 Old Dublin Pike
Doylestown, PA 18901
(866) 866-0280
'Bucks
Bucks County Housing Group
349 Durham Road
Penndel, PA 19047
(866) 866-0280
'Bucks
Bucks County Housing Group
515 West End Blvd
Quakertown, PA 18951
(866) 866-0280
'Bucks
Budget Counseling Center
247 North Fifth Street
Reading, PA 19601
(610) 375-7866
'Barks, Chester, Schuylkill
Carroll Park Community Council, Inc.
5218 Master Street
Philadelphia, PA 19131
(215) 877-1157
'Chester, Delaware, Philadelphia
Catholic Social Services
Saint Catherine Manor
5 Knox Road
Scranton, PA 18505
(570) 558-3019
'Wyoming, Wayne, Bucks, Lackawanna,
Monroe, Philadelphia
CCCS of Delaware Valley
1230 New Rodgers Road, Suite F1
Bristol, PA 19007
(215)563.5665
'Bucks
CCCS of Delaware Valley
1777 Sentry Parkway W, Suite 200
Blue Bell, PA 19422
(215)563.5665
'Montgomery
CCCS of Delaware Valley
260 North Providence Road
Media, PA 19063
(215) 563-5665
'Chester
CCCS of Delaware Valley
Marshal Building
790 E Market St, Suite 170
West Chester, PA 19382
(215) 563-5665
'Chester, Bucks
CCCS of Delaware Valley
Catholic Social Services Building
7340 Jackson Street
Philadelphia, PA 19136
(215) 563-5665
'Bucks, Philadelphia
CCCS of Delaware Valley
One Cherry Hill, Suite 215
Cherry Hill, PA 08002
(215) 563-5665
'Philadelphia
CCCS of Lehigh Valley
3671 Crescent Court East
Whitehall, PA 18052
(610) 821-4011
(800) 837-9815
'Barks, Bucks, Carbon, Lancaster, Lehigh,
Northhampton, Schuylkill
CCCS of Northeastern PA
201 Basin Street, Suite 6
Williamsport, PA 17701
(570)323.6627
'Centre, Clinton, Lycoming, Northumberland,
Union
CCCS of Northeastern PA
202 W Hamilton Avenue
State College, PA 16801
(814) 238-3668
'Blair, Centre, Clearfield, Clinton, Huntingdon,
Juniata, Mifflin
CCCS of Northeastern PA
401 Laurel Street
Pittston, PA 18640
(570) 602-2227
'Bradford, Carton, Columbia, Lackawanna,
Lycoming, Monroe, Montour, Northumberland,
Pike, Sullivan, Tioga, Union, Wayne, Wyoming
CCCS of Northeastern PA
411 Main Street, Suite 104
Stroudsburg, PA 18360
(570) 420-8980
'Bradford, Carbon, Monroe, Pike, Wayne
CCCS of Western PA
1 North Gale Square #2
Garden Center Dr
Greensburg, PA 15601
(888) 511-2227
'Fayette, Greene, Indiana, Somerset,
Washington, Westmoreland
CCCS of Western PA
55 Clover Hi4 Road
Dallastown, PA 17313
(888) 511-2227
'Fulton, Crawford, Lancaster
C.
* Indicates Counties Serviced
CCCS of Western PA
2000 Linglestown Road
Harrisburg, PA 17102
(888) 511-2227
'Adams, Cumberland, Dauphin, Franklin, Perry,
Synder, York
Chester Community Improvement Project
412 Avenue of the States
P.O. Box 541
Chester, PA 19016
(610) 876-8663
'Chester, Delaware, Montgomery, Philadelphia
Diversified Community Service
Dixon House
1920 South 20th Street
Philadelphia, PA 19145
(215) 336-3511
'Bucks, Chester, Delaware, Philadelphia
Indiana Co. Community Action Frog.
827 Water Street Box 187
Indiana, PA 15701
(724) 465-2657
'Armstrong, Cambria, Clearfield, Indiana,
Jefferson, Westmoreland
CCCS of Western PA
312 Chestnut Street, Suite 227
Meadville, PA 16335
(888)511.2227
'Lawrence
CCCS of Western PA
41 East Chestnut Street
Washington, PA 15301
(888) 511-2227
'Westmoreland
CCCS of Western PA
4402 Peach Street
Ede, PA 16509
(888) 511-2227
'Crawford, Ede, Warren
CCCS of Western PA
524 Franklin Avenue
Aliquippa, PA 15001
(888) 511-2227
'Cambria
CCCS of Western PA
917 A Logan Boulevard
Altoona, PA 16602
(888) 511-2227
'Armstrong, Bedford, Blair, Cambria, Centre,
Clearfield, Hunfingdon, Juniata, Mifflin, Union
CCCS of Western PA
Pullman Commerce Center
112 Hollywood Dr
Butler, PA 16001
(888) 511-2227
'Butler, Clacton, Jefferson, Mercer, Venango
CCCS of Western PA
River Park Commons
2403 Sidney Street
Pittsburgh, PA 15203
(888) 511-2227
'Allegheny
Center for Family Services, Inc.
213 Center Street
Meadville, PA 16335
(814) 337-8450
'Columbia, Venango
Centro Pedro Clever, Inc
627 West Erie Avenue
Philadelpia, PA 19140
(215) 227-7111
'Philadelphia
Comm. On Econ Opportunity of Luzeme Co.
163 Amber Lane
Wilkes-Barre, PA 18702
(570) 826-0510
'Carbon, Luzeme, Schuylkill, Wyoming
Community Action Commission of Capital
Region
1514 Derry Street
Harrisburg, PA 17094
(717) 232-9757
'Cumberland, Dauphin, Franklin, Perry, Synder
Community Action Committee of the Lehigh
Valley
1337 East Fifth Street
Bethlehem, PA 18015
(610) 691-5620
'Barks, Carbon, Lehigh, Monroe,
Northhampton
Community Action Development Comm -
CADCOM
113 E Main Street
Norristown, PA 19401
(610) 277-6363
'Montgomery
Community Action Southwest
150 W Beau Street, Suite 304
Washington, PA 15301
(724) 225-9550
'Monroe
Community Acton Southwest
58 E Greene Street
Waynesburg, PA 15370
(724) 852-2893
'Allegheny, York, Fayette, Greene,
Washington. Westmoreland
Comm. on Econ. Opportunity of Luzeme
County
163 Amber Lane
WilkesBarre, PA 18702
(570) 826-0510
(800) 822-0359
'Wyoming
Congreso
216 West Somerset Street
Philadelphia, PA 19133
(215) 763-8870
'Philadelphia
Council of Spanish Speaking Organization
705-09 North Franklin St
Philadelphia, PA 19123
(215) 627-3100
'Philadelphia
Credit Counseling Center
832 Second Street Pike
Richboro, PA 18954
(215) 396-1880
'Bucks
Fair Housing Partnership of Greater Pittsburgh, Intercultural Family Services Inc.
Inc. 4225 Chestnut Street
2840 Libedty Ave., Suite 205 Philadelphia, PA 19104
Pittsburgh, PA 15222 (215) 386-1298
(412) 391-2535 'Philadelphia
'Allegheny
Fayette Co. Community Action Agency Inc
137 North Beeson Avenue
Uniontown, PA 15401
(724) 437-6050
'Fayette, Somerset
FOB CDC
1201 West Only Avenue
Philadelphia, PA 19141
(215) 549-8755
'Bucks, Chester, Delaware, Philadelphia
Garfield Jubilee Associates
5138 Penn Avenue
Pittsburgh, PA 15224
(412) 665-5200
'Allegheny
Germantown Settlement
5538 Wayne Avenue Bldg C
Philadelphia, PA 19144
(215)849.3114
'Bucks, Chester, Delaware, Montgomery,
Philadelphia
Greater Ede Commun. Action Committee
18 West 9th Street
Erie, PA 16501
(814) 459-4581
'Crawford, Erie, Venango, Warren
HACE
167 W Allegheny Ave., 2nd Floor
Philadelphia, PA 19140
(215) 426-8025
'Bucks, Chester, Delaware, Philadelphia
Hispanic Alliance for Community Advancement
2740 North Front Street
Philadelphia, PA 19133
(215) 667-8932
'Monroe
Housing Assoc. of Delaware Valley
658 North Watts Street
Philadelphia, PA 19123
(215) 978-0224
'Philadelphia, Monroe
Housing Opportunities of Beaver Co.
320 College Avenue, Unit 1
Beaver, PA 15009
(724) 728-7511
`Beaver, Lawrence
Housing Partnership of Chester County
41 West Lancaster Avenue
Downingtown, PA 19335
(610) 518-1522
'Chester, Delaware, Montgomery
Korean Comm. Develop. Services Center
6055 North 5th Street
Philadelphia, PA 18505
(215)276.8830
'Philadelphia
Lawrence County Social Services, Inc.
241 West Grant Street
P.O. Box 189
New Castle, PA 16103
(724) 658-7258
'Lawrence
Liberty Resources
714 Market Street, Suite 100
Philadelphia, PA 19106
(215) 634-2000
'Philadelphia
Loveship,Inc.
2320 North 5th Street
Harrisburg, PA 1711
(717) 232-2207
'Cumberland, Dauphin, Perry
Lycom-Clntn Co Comm fo Comm Action
2138 Lincoln Street
P.O. Box 3568
Williamsport, PA 17703
(570) 326-0587
'Centre, Clinton, Lycoming, Union
Maranatha
43 Philadelphia Avenue
Waynesboro, PA 17268
(717) 762-3285
'Adams, Cumberland, Franklin, Fulton, Perry
Media Fellowship House
302 South Jackson Street
Media, PA 19063
(610) 565-0434
'Chester, Delaware
Mon Valley Unemployment Committee
1800 West St., 3rd Floor
Homestead, PA 15120
(412) 462-9962
'Allegheny, Washington, Westmoreland
Mt. Airy, USA
6703 Germantown Ave., Suite 200
Philadelphia, PA 19119
(215) 8446021
'Philadelphia
Nazareth Housing Services
301 Bellevue Road
Pittsburgh, PA 15229
(412) 931-6996
'Allegheny
C.
* Indicates Counties Serviced
Neighborhood Housing Services of Reading
213 N 5th St., Suite 1030
Reading, PA 19601
(610) 372-8433
'Barks
Neighborhood Housing Services, Inc.
710 5th Avenue, Suite 1000
Pittsburgh, PA 15219
(412) 281-9773
'Allegheny
New Kensignton Community Development
2515 Frankford Avenue
Philadelphia, PA 19125
(215) 427-0350
'Warren
The NORCAM Group
4200 Crawford Avenue Suite 200
Northern Cambria, PA 15714
(814) 948-4444
'Cambria, Clearfield
Northern Tier Community Action Corp.
135 West 4th Street
P.O. Box 389
Emporium, PA 15834
(814)4861161
'Cameron, Elk, Mckean, Potter
Northwest Counseling Service
5001 North Broad Street
Philadelphia, PA 19141
(215) 324-7500
'Bucks, Chester, Delaware, Montgomery,
Philadelphia
Nueva Esperanza
4261 North 5th Street
Philadelphia, PA 19140
(215) 324-0746
'Philadelphia
Opportunity Inc.
301 East Market Street
York, PA 17403
(717) 424-3645
'Montgomery
The Partnership CDC
4020 Market Street, Suite 100
Philadelphia, PA 19104
(215) 662-1612
'Monroe
PHFA
211 North Front Street
Harrisburg, PA 17110
(800-)342-2397
'Cumbedand, Dauphin
Philadelphia Council for Comm. Advmnt.
100 N 17th St, Suite 600
Philadelphia, PA 19103
(215) 567-7803
(800) 930-4663
'Chester, Delaware, Montgomery, Philadelphia
Philadelphia Senior Center
509 South Broad Street
Philadelphia, PA 19147
(215)546.5879
'Philadelphia
Schuylkill Community Action
225 N. Centre Street
Pottsville, PA 17901
(570) 622-1995
'Barks, Carbon, Lebanon, Lehigh, Luzeme,
Northumberland, Schuylkill
Shenango Valley Urban League, Inc.
601 Indiana Avenue
Farrell, PA 16121
(724) 981-5310
'Crawford, Lawrence, Mercer
South Philadelphia H.O.M.E.S.
1444 Point Breeze Avenue
Philadelphia, PA 19146
(215) 334-4430
'Philadelphia
Southwest Community Development Corp.
6368 Paschall Avenue
Philadelphia. PA 19142
(215) 729-0800
'Montgomery
St. Martin Center
1701 Parade Street
Erie, PA 16503
(814) 452-6113
'Crawford, Erie, Venango, Warren
Tableland Services Inc.
535 East Main Street
Somerset, PA 15501
(814) 445-9628
'Cambria, Fayette, Somerset, Westmoreland
The Trehab Center of Northeastern PA
10 Public Avenue
P.O. Box 366
Montrose, PA 18801
(570) 278-3338
(800) 982-4045
`Susquehanna
The Trehab Center of Northeastern PA
115 SR 92S
Tuckhannock, PA 18657
(570) 836-6840
(800)982-4045
'Wyoming
The Trehab Center of of Northeastern PA
1225 Main Street
Honesdale, PA 18431
(570) 253-8941
(800) 982-4045
'Bradford, Sullivan, Susquehanna, Tioga,
Wayne, Wyoming
The Trehab Center of Northeastern PA
144 E East Avenue
Wellsboro, PA 16901
(570) 724-5252
(800) 982-4045
'Tioga
The Trehab Center of Northeastern PA
German Street
P.O. Box 389
Dushore, PA 18614
(570) 928-9667
(800) 982-4045
'Sullivan
The Trehab Center of Northeastern PA
The Enterprise Center
703 S. Elmer Ave., Suite M-6
Sayre, PA 18840
(570) 888-0412
(800) 9824045
'Bradford
United Communities Southeast Philadelphia
2029 South 8th Street
Philadelphia, PA 19148
(215) 467-8700
'Philadelphia
United Neighborhood Centers of Northeastern
PA
425 Alder Street
Scranton, PA 18505
(570) 346-0759
'Lackawanna, Wyoming, Wayne, Luzeme
Urban League of Philadelphia
1818 Market Street
Philadelphia, PA 19103
(215) 561-6070
'Bucks, Delaware, Philadelphia
Urban League of Philadelphia
610 Wood Street
Pittsburgh, PA 15229
(412) 931-6996
* Allegheny
Voices for Independence
1107 Payne Avenue
Ede, PA 16503
(814) 874-0064
(800) 838-9890
'Erie
Warren-Forest Counties Economic Opportunity
Council
1209 Pennsylvania Ave W.
P.O. Box 547
Warren, PA 16365
(814) 726-2400
'Forest, Waren
Pennsylvania Housing Finance Agency
2275 Swallow Hill Rd., Bldg 200
Pittsburgh, PA 15220
(412) 429-2842
'Allegheny
Tabor Community Services
308 E King Street Suite 1
Lancaster, PA 17602
(717) 397-5182
(800) 788-5062
'Chester, Lancaster, Lebanon
C
West Oak Lane CDC
6259 Limekiln Pike
Philadelphia, PA 1914
(215) 224-0880
'Monroe
V E R I F I C A T I O N
The undersigned, hereby states that he/she is the attorney for
the Plaintiff, a corporation unless designated otherwise; that
he/she is authorized to make this Verification and does so because
of the exigencies regarding this matter, and because Plaintiff must
verify much of the :information through agents, and because he/she
has personal knowledge of some of the facts averred in the
foregoing pleading; and that the statements made in the foregoing
pleading are true and correct to the best of his/her knowledge,
information and belief and the source of his information is public
records and reports of Plaintiff's agents. The undersigned
understands that this statement herein is made subject to the
penalties of 18 Pa.C.S. Section 4904 relating to unsworn
falsification to authorities.
UDREN LAW OFFICES, P.C.
BY : (J fM WZL6?U iTIVI (.Y./ / (f/l./
Attorneys for Plaintiff
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
LOUIS A. SIMONI, ESQUIRE
ADAM L. KAYES, ESQUIRE
MARGUERITE L. THOMAS, ESQUIRE
C.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff Ap
Jody S Smith +
Chief Deputy Z? Q JAN 21 AN 9' d4 2
Edward L Schorpp
n
Solicitor
Wells Fargo Bank, NA
vs. Case Number
.
Stephen E. Myers 2010-285
SHERIFF'S RETURN OF SERVICE
01/15/2010 04:15 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on January 15,
2010 at 1615 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Michelle M. Myers, by making known unto Stephen E. Myers, Husband of
defendant at 468 Wolfs Bridge Road, Carlisle, Cumberland County, Pennsylvania 17013 its contents and
at the same time handing to him personally the said true and correct copy of the same.
01/15/2010 04:15 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on January 15,
2010 at 1615 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Stephen E. Myers, by making known unto himself personally, at 468 Wolfs
Bridge Road, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time
handing to him personally the said true and correct copy of the same.
SHERIFF COST: $49.40 SO ANSWERS
January 20, 2010 Y R ANDERSON, SHERIFF
By_??
Deputy Sheriff
!ci CeuatySuitr Shenff, Telcoso?fj Ji :.
UDREN LAW OFFICES, P.C. ATTORNEY
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
LOUIS A. SIMONI, ESQUIRE - ID #200869
ADAM L. KAYES, ESQUIRE - ID #86408
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
FOR PLAINTIFF
Wells Fargo Bank, N.A., as :COURT OF COMMON PLEA
Trustee for MASTR Asset Backed :CIVIL DIVISION
Securities Trust 2004-OPT2 :Cumberland County
Plaintiff
v. ENO. 10-285
Stephen E. Myers
Michelle M. Myers
Defendant(s)
PRAECIPE TO SUBSTITUTE VERIFICATION
TO THE PROTHONOTARY:
N
o
`
,~- ~
~
r
~r ~~
r,~
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Kindly substitute the attached Verification for the
Verification attached to the Complaint in Mortgage Foreclosure
with regard to the captioned matter.
DATED: February 17, 2010
UDREN ~W ~'FI'L"L*~ , P . C .
BY : (~'aFZ~•
Attorneys aintiff
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
~LT7TJI S A . S IMONI , ESQUIRE
ADAM L. KAYES, ESQUIRE
V E R I F I C A T I O N
The undersigned, an officer of American Home Mortgage
Servicing, Inc. successor in interest to Option One Mortgage
Corporation, as attorney-in-fact for Plaintiff, and being
authorized to make this verification on behalf of the Plaintiff,
hereby verifies that the facts set forth in the foregoing Complaint
are taken from records maintained by Plaintiff in the ordinary
course of business and that those facts are true and correct to the
best of the knowledge, information and belief of the undersigned.
The undersigned understands that this Statement is made
subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date : ~Ia~U~ ~ ,~O /D ~~V
Name: ~
Carol White
Title: Assistant~ce Pres~~r~~-~~
Company: American Home Mortgage Servicing,
Inc. successor in interest to Option
One Mortgage Corporation, as
attorney-in-fact for We11s Fargo Bank,
N.A., as Trustee for MASTR Asset Backed
Securities Trust 2004-OPT2
Stephen E. Myers __
Michelle M. Myers
Loan #0013577143
MJU #09120657-1
(Cumberland County, Pennsylvania)
+ UDREN LAW OFFICES, P.C.
MARK J. UDREN, ESQUIRE - ID #04302
~STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
LOUIS A. SIMONI, ESQUIRE - ID #200869
ADAM L. KAYES, ESQUIRE - ID #86408
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Wells Fargo Bank, N.A., as
Trustee for MASTR Asset Backed `_
Securities Trust 2004-OPT2
P.O. Box 961730
Irving, TX 75063
Plaintiff
v.
Stephen E. Myers
Michelle M. Myers
468 Wolfs Bridge Road
Carlisle, PA 17013
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
NO. 10-285
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against the
Defendant(s) Stephen E. Myers and Michelle M. Myers for failure to file
an Answer to Plaintiff's Complaint within 20 days from service thereof
and for foreclosure and sale of the mortgaged premises, and assess
Plaintiff's damages as follows:
As set forth in Complaint $90,669.79
Interest Per Complaint 337.61
From 12/31/09 to 2/17/10
Late charges per Complaint 33.96
From 12/31/09 to 2/17/10
Escrow payment per Complaint 234.56
From 12/31/09 to 2/17/10
TOTAL 591,275.92
I hereby certify that (1) the addresses of the Plaintiff and Defendant
are as'shown above, and (2) that notice has been given in accordance
with Rule 237.1, a copy of which is attached hereto.
~ UDREN LA ~ P.C.
BY: ~
Attorneys o aintiff
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
LOUIS A. SIMONI, ESQUIRE
ADAM L. KAYES, ESQUIRE
DAMAGES ARE HEREBY ASSESSED AS INDICATED
DATE: o
PRO OT Y
UDREN LAW OFFICES, P.C.
MARK J. UDREN, ESQUIRE - ID #04302
STIIART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQIIIRE - ID #75850
CHANDRA M. ARXEMA, ESQUIRE - ID #x203437
LOIIIS A. SIMONI, ESQUIRE - ID #200869
ADAM L. RAPES, ESQUIRE - ID #8640$
MARGUERITE L. THOMAS, ESQUIRE - ID #204460
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY KILL, NJ 08003-3620
856-669-5400
pleadinga~udren.com
Wells Fargo Bank, N.A., as _COURT
Trustee for MASTR Asset Backed =CIVIL
Securities Trust 2004-OPT2
~ll.~f~-t~rr~C~
AT'4~ ~+~ ~ ;.jd~NT I F F
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•~a.
OF COMMON PLEAS
DIVISION
P.O. Box 961730 €Cumberland County
Irving, TX 75063
Plaintiff
v.
Stephen E. Myers
Michelle M. Myers
468 Wolfs Bridge Road
Carlisle, PA 17013
Defendant (s)
NO.
COMPLAINT IN 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
ntl'Znr ri rrl'itc imr~^rtani- f-r~ .r..,,
~J ~- .v yv~w.
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 SIRING A LAWYER. IF
~~
6~~ 2o(~s~- I Mtif ~-
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith ~$~~~t+.? a~' +~u~l~berfy~d
Chief Deputy
'`
Edward 1. Schorpp
Solicitor pt-ars °;~F r+,~ ~.ajr~
Wells Fargo Bank, NA
vs. Case Number
Stephen E. Myers 2010-265
SHERIFF'S RETURN OF SERVICE
01/15/2010 04:15 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on January 15,
2090 at 1615 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Michelle M. Myers, by making known unto Stephen E. Myers, Husband of
defendant at 468 Wolfs Bridge Road, Carlisle, Cumberland County, Pennsylvania 17013 its contents and
at the same time handing to him personally the said true and correct copy of the same.
01!15/2010 04:15 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on January 15,
2010 at 1615 hours, he served a true copy of the within Gomplaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Stephen E. Myers, by making known unto himself personally, at 468 Wolfs
Bridge Raad, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time
handing to him personally the said true and correct copy of the same.
SHERIFF COST: $49.40
January 20, 2010
SO ANSWERS
Y R ANDERSON, SHERIFF
.~~.~-~-
Deputy Shsriff
`~; C.~uat~,Sutlr. Sher~~f, l~aoso`!. Ind.
UDREN LAW OFFICES, P.C.
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARREMA, ESQUIRE - ID #203437
LOUIS A. SIMONI, ESQUIRE - ID #200869
ADAM L. KAYES, ESQUIRE - ID #86408
MARGUERITE L. THOMAS, ESQUIRB - ID #204460
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003
856-669-5400
~, _ eadi n~ sC~4udren om
Wells Fargo Bank, N.A., as Trustee for
MASTR Asset Backed Securities Trust 2004-
OPT2
Plaintiff
v.
Stepphen E. Myyers
MicIzelle M. Myers
Defendant(s)
TO: Stephen E. Myers
468 Wolfs Bridge Road
Carlisle, PA 17013
Date of Notice: February 5, 2010
IMPORTANT NOTICE
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 10-285
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS
FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST-YOU WITHOUT A
HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE
THIS 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
2 Liberty Avenue
Carlisle, PA 17013
800-990-9108
NOTIFICACION IMPORTANTE
USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA
DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMING DE
DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE
COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA DICTAR SENTENCIA EN SU
CONTRA USTED PUEDE PERDER BIENES Y OTROS DERECHOS, fMPORTANTES. DEBE LLEVAR
ESTA NbTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO
TIENE DINERO SUFICIENTE PARR TAL SERVICIO VAYA EN PERSONA O LLAME POR TELEFONO A
LA OFICINA, CUYA DIRECCION SE ENCUENTRA E~CRITA ABAJO PARR AVERIGUAR DONDE SE
PUEDE CONSEGUIR ASSISTENCIA LEGAL.
SERVICIO DE REFERENCIA LEGAL
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
800-990-9108
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS
DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE..
, J
RTT- m' TTT ESQUIRE
1 VL]iCT~7T-2-
LORRAII~~ ~DOYL ESQUIRE
/ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
LOUIS A. SIMONI, ESQUIRE
ADAM L. KAYES, ESQUIRE
MARGUERITE L. THOMAS, ESQUIRE
Woodcrest Cor orate Center
111 Woodcrest ~oad, Suite 200
Cherry Hill, New Jersey 08003-3620
UDREN LAW OFFICES, P.C.
MARK J. UDREN, ESQUIRB - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINS DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID'#75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
LOUIS A. SIMONI, ESQUIRE - ID #200869
ADAM L. KAYES, ESQUIRE - ID #86408
MARGUERITE L. THOMAS, ESQUIRE - ID #204460
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003
856-669-5400
~~,nQs(dludr n com
Wells Fargo Bank, N.A., as Trustee for
MASTR Asset Backed Securities Trust 2004- '-
OPT2
Plaintiff
v.
Stephen E. Myers
Michelle M. Myers
Defendant(s)
TO: Michelle M. Myers
468 Wolfs Bridge Road
Carlisle, PA 17013
Date of Notice: February 5, 2010
IMPORTANT NOTICE
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 10-285
YOU ARE IN. DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS
FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A
HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE
THIS 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
2 Liberty Avenue
Carlisle, PA 17013
800-990-9108
NOTIFICACION IMPORTANTE
USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA
DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMING DE
DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE
COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU
CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR
ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO
TIENE DINERO SUFICIENTE PARR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A
LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE
PUEDE CONSEGUIR ASSISTENCIA LEGAL.
SERVICIO DE REFERENCIA LEGAL
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
800-990-9108
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS
DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY
INFORMATION OBTAINED WILL BE USED FOR THAT pIIRPOSE.
.,
WINNEG, E
i/ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
LOUIS A. SIMONI, ES. UIRE
ADAM L. KAYES, ESQ IRE
MARGUERITE L. THOMAS, ESQUIRE
Woodcrest Co orate Center
111 Woodcrest ~oad, Suite 200
Cherry Hill, New Jersey 08003-3620
UDREN LAW OFFICES, P.C.
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M• ARKEMA, 85QUIRE - ID #203437
LOIIIS A. SIMONI, ESQUIRE - ID #200869
WOODCREST CORPORATE CENTER
7.11 WOODCREST ROAD, SUITE 200
CFIERRY HILL, NJ 08003-3620
856-482-6900
W 11
ATTORNEY FOR PLAINTIFF
e s Fargo Bank, N.A., as ;COURT OF COMMON PLEAS
Trustee for MASTR Asset Backed :CIVIL DIVISION
Securities Trust 2004-OPT2 ;Cumberland County
P.D. Box 961730
Trving,~ TX 75063 ;MORTGAGE FORECLOSURE
Plaintiff Q
Stephen E . Myers ` NO ` ~ ~ J ~ 8S
Michelle M. Myers
468 Wolfs Bridge Road
Carlisle, PA 17013
Defendant (s )
AFFIDAVIT OF NON-MILITARY SERVICE
STATE OF
COUNTY OF
SS
THE UNDERSIGNED being duly sworn, deposes and says that the
averments herein are based upon investigations made and records
maintained by Plaintiff herein and that the abave Defendant(s) are
not in the Military or Naval Service of the United States of
America or its Allies as defined in the Soldiers and Sailors Civil
Relief Act of 1940, as amended, and that the age and last known
residence and employment of each Defendant are as follows:
Defendant: Stephen E. Myers
Age= Over 18
Residence: As captioned above
Employment: Unknown
Defendant: Michelle M. Myers
Age: Over 18
Residence: As captioned above
Employment: Unknown
~/ '
Name : yn white
Title p
.......... ................................ .
.................... .
Company A~~~~~ ~}~~H~e Servicing,
Iric: successoz in interest to Optiori
One Mortgage Corporation, as
attorney-in-fact for Wells Fargo Bank,
N.A., as Trustee for MASTR Asset Backed
Securities Trust 2004-OPT2
Sworn to and subscribed
before me this ~jW~ day
of c`~NI.l3r~ 20 /~.
~q :~ h`TAItY ~,fiBLIO-STATE OF FLORIDA
" ~~-/~-i~L` ° _ Brenda L. Frazier
Notary Publi ~ ,,Commission#DD885641
~, ,,• Expires; APR. 30, 2013
BONDED'I'H12U ATLANTIC BOIv'DING CO., INC.
1~r ~~ ~C ~'~," i ~ ~~'P~ ~`~r
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UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LaRRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDR.A M. ARKEMA, ESQUIRE - ID #203437
LOUIS A. SIMONI, ESQUIRE - ID #200869
ADAM L. KAYES, ESQUIRE - ID #86408
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
Pleadings@udren.com
Wells Fargo Bank, N.A., as :COURT OF COMMON PLEAS
Trustee for MASTR Asset Backed :CIVIL DIVISION
Securities Trust 2004-OPT2 :Cumberland County
Plaintiff
v. :MORTGAGE FORECLOSURE
Stephen E. Myers =NO. 10-285
Michelle M. Myers
Defendant(s)
T0: Michelle M. Myers
468 Wolfs Bridge Road.
Carlisle, PA 17013
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you
are hereby notified that a Judgment has been entere ag inst you
in the above proceeding as indicated below. ~~1~~
Proth~nvt - ry
X Judgment by Default
Money Ju
Judgment
Judgment
Judgment
Judgment
Judgment
3gment
in Replevin
for Possession
on Award of Arbitration
on Verdict
on Court Findings
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL:
ATTORNEY Mark J. Udren, Esquire
At this telephone number: 856-669-5400
• •UDREZ? LAW OFFICES, P . C . ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #0430.2
STUART WINNEG, ESQUIRE - ID #45362
LORRIIINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHAN~RA M. ARKEMA, ESQUIRE - ID #203437
LOUIS A. SIMONI, ESQUIRE - ID #200869
ADAM L. KAYES, ESQUIRE - ID #86408
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Wells Fargo Bank, N.A., as :COURT OF COMMON PLEAS
Trustee for MASTR Asset Backed :CIVIL DIVISION
Securities Trust 2004-OPT2 :Cumberland County
P.O. Box 961730
Irving, TX 75053 :MORTGAGE FORECLOSURE
Plaintiff
v.
Stephen E. Myers NO. 10-285
Michelle M. Myers
468 Wolfs Bridge Road
Carlisle, PA 17013
Defendant(s)
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly erLter judgment in favor of the Plaintiff and against the
Defendant(s) Stephen E. Myers and Michelle M. Myers for failure to file
an Answer to Plaintiff's Complaint within 20 days from service thereof
and for foreclosure and sale of the mortgaged premises, and assess
Plaintiff's damages as follows:
As set forth in Complaint $90,669.79
Interest Per Complaint 337.61
From 12;31/09 to 2/17/10
Late charges per Complaint ?3.96
From 12%31/09 to 2%17%10
EscroN pay.~~ment per Complaint 234.50
From 12;31/09 to 2/17%10
TOTAL $91,27.92
I L'iE'reby certify that (1) the addresses of the Plaintiff and Defendant
• are Gs shown above, and (2) that notice has been given in accordance
with Rule ~37.i, a copy of which is attached hereto.
UDREN LP.6^~~ OEFICE;S , P . C .
.,• _ ~ .
BY : ~ x:~ - '. '
Attorneys for Plaintiff
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEM.A, ESQUIRE
~'OUIS P_. SIMONI, ESQUIRE
ADAM L. KAYES, ESQUIRE
DAMAGES ARE HEREBY ASSESSED AS
DATE : ~~/ 7~~(~
INDICAT
C
PRO P Y
' UDR~N LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
M1+RK J. UDREN, ESQUIRE - ID #04302
$TUART WINNEG, ESQUIRE - ID #45362
LaRRAINE DOYLE, ESQUIRE - ID #34576
AZAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
LOUIS A. SIMONI, ESQUIRE - ID #200869
ADAM L. KAYES, ESQUIRE - ID #86408
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
Pleadings~udren.com
Wells Fargo Bank, N.A., as :COURT OF COMMON PLEAS
Trustee for MASTR Asset Backed :CIVIL DIVISION
Securities Trust 2004-OPT2 :Cumberland County
Plaintiff
v. :MORTGAGE FORECLOSURE
Stephen E. Myers
Michelle M. Myers =NO. 10-285
Defendant(s)
TO: Stephen E. Myers
468 Wolfs Bridge Road
Carlisle, PA 17013
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you
are hereby notified that a Judgment has been en~e~ed against you
in the above proceeding as indicated below. c
Prvtnvnozary
X Judgment by Default
Money Jw
Judgment
Judgment
Judgment
Judgment
Judgment
3gment
in Replevin
for Possession
on Award of Arbitration
on Verdict
on Court Findings
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL:
ATTORNEY Mark J. Udren, Esquire
At this telephone number: 856-669-5400
UDREN~LAW OFFICES, P.C.
MARK J• UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRIIINE DOYLE, ESQUIRE - ID #34576
ALAN M• MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
LOU=S A. SIMONI, ESQUIRE - ID #200869
ADAM L. KAYES, ESQUIRE - ID #86408
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Wells Fargo Bank, N.A., as
Trustee for MASTR Asset Backed
Securities Trust 2004-OPT2
P.O. Box 961730
Irving, TX 75063
Plaintiff
AT'T'ORNEY FOR PLAINTIFF
:COURT OF COMMON PLEAS
:CIVIL DIVISION
:Cumberland County
:MORTGAGE FORECLOStJRE
zJ
Stephen E. Myers
Michelle M. Myers
468 Wolfs Bridge Road
Carlisle, PA 17013
Defendant (s )
:NO. 10-285
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against the
Defendant (s} Stephen E. Myers and Michelle M. Myers for failure to file
an Answer to Plaintiff's Complaint within 20 days from service thereof
and for foreclosure and sale of the mortgaged premises, and assess
Plaintiff's damages as follows:
As set forth in Complaint $90,669.79
Interest Per Complaint 337.61
From 12!31/09 to 2/17/10
Late charges per Complaint 33.95
From i2/31/09 to 2/17%10
Escrow pa-,rment per Complaint 234.55
rrom 12;31%09 to 2%17/10
TOTAL $91,275.~~
~I rie~-eby certify that (1) the addresses of the Plaintiff and Defendant
are as shown abo-~re, and (2) that notice has been given in accordance
'~li tri Rule ~ 7 1, a copy of which is attached hereto .
UDRE1`d LATrT OFFICES , P . C .
.. ~:.
BY E`- ~.
Attorne~rs for Plaintiff
MARK J. UDREN, ESQUIRE
STUART vTINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALP.N M. MINATO, ESQUIRE
CHANDRA M. ARK_EMA, ESQUIRE
LOUIS A. SIMONI, ESQUIRE
ADAM L. KAYES, ESQUIRE
DAMAGES ARE HEREBY ASSESSED AS
DATE : ~1i~/(~
INDICATE
PRO PR I
UDREN LAW OFFICES, P.C.
MARK J. UDREN, ESQUIRE -
STUART WINNEG, ESQUIRE -
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUI;
LOUIS A. SIMONI, ESQUIRE
ADAM L. KAYES, ESQUIRE -
ID #04302
ID #45362
- ID #34576
- ID #75860
[tE - ID #203437
- ID #200869
ID #86408
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Wells Fargo Bank, N.A., as
Trustee for MASTR Asset Backed €
Securities Trust 2004-OPT2
Plaintiff
v.
Stephen E. Myers ,
Michelle M. Myers
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
NO. 10-285
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Please issue Writ of Execution in the above matter:
Amount due
Interest From 2 18 10
to Date of Sale June 2, 2010
Ongoing Per Diem of 6.89
to actual date of sale including if sale is
held at a later date
(Costs to be added)
$91,275.92
723.45
UDRE I S, P.C.
BY: '
Attorneys for Plaintiff
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
wbOUIS A. SIMONI, ESQUIRE
ADAM L. KAYES, ESQUIRE
~I~CD~ ~~~r~:E
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UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
LOUIS A. SIMONI, ESQUIRE - ID #200869
ADAM L. KAYES, ESQUIRE - ID #86408
WOODCREST CORPORATE CENTER
~
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620 ~..
~'%~c~~
856-669-5400 -
pleadings@udren. com `~`'~'
~~
Wells Fargo Bank, N.A., as €COURT OF COMMON PLEA~r,-,
Trustee for MASTR Asset Backed :CIVIL DIVISION "c~~-4
Securities Trust 2004-OPT2 :Cumberland County
Plaintiff `
v. :MORTGAGE FORECLOSURE
Stephen E. Myers =_NO. 10-285
Michelle M. Myers
Defendant(s)
C E R T I F I C A T E
na
O :-.J
o ~'~
p ~t-
_ ~~
_ ~ ~
,J ~'y
-° -'
~. % ~~
rn
I hereby state that as the attorney for the Plaintiff in the
above-captioned matter and that the premises are not subject to
the provisions of Act 91 because it is:
( ) An FHA insured mortgage
( ) Non-owner occupied
( ) Vacant
( X ) Act 91 procedures have been fulfilled.
( ) Over 24 months delinquent.
This certification is made subject to the penalties of 18
Pa. C.S. Sec. 4904 relating to unsworn falsification to
authorities.
UDREN IC S, P.C.
BY: ~
Attorneys for Plaintiff
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
LOUIS A. SIMONI, ESQUIRE
ADAM L. KAYES, ESQUIRE
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
LOUIS A. SIMONI, ESQUIRE - ID #200869
ADAM L. KAYES, ESQUIRE - ID #86408
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Wells Fargo Bank, N.A., as =_COURT OF COMMON PLEAS
Trustee for MASTR Asset Backed :CIVIL DIVISION
Securities Trust 2004-OPT2 €Cumberland County
Plaintiff
v• =MORTGAGE FORECLOSURE
Stephen E. Myers NO. 10-285
Michelle M. Myers
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129.1
Wells Fargo Bank, N.A., as Trustee for MASTR
Securities Trust 2004-OPT2, Plaintiff in the
attorney, Mark J. Udren, ESQ., sets forth as
Praecipe for the Writ of Execution was filed
information concerning the real property loci
Bridge Road, Carlisle, PA 17013
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Asset Backed
above action, by its
of the date the
the following
~ted at: .468 Wolfs
1. Name and address of Owner(s) or reputed Owner(s):
Name Address
Stephen E. Myers 468 Wolfs Bridge Road
Carlisle, PA 17013
Michelle M. Myers 468 Wolfs Bridge Road
Carlisle, PA 17013
2. Name and address of Defendant(s) in the judgment:
Name Address
SAME AS #1 ABOVE
3. Name and address of every judgment creditor whose judgment is
a record lien on the real property to be sold:
Name Address
Capital One Bank 140 East Shore Dr.
Glen Allen, VA 23059
4. Name and address of
of record:
' Name
Wells Fargo Bank, N.A.,
as Trustee for MASTR
Asset Backed Securities
Trust 2004-OPT2
Pennsylvania Housing
Finance Agency (PHFA)
Address
P.O. Box 961730
Irving, TX 75063
211 North Front Street
Harrisburg, PA 17101
Option One Mortgage Corp. 3 Ada, Irvine, CA 92618
A CA Corp.
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 and whose interest may be affected by
the sale:
Name Address
Real Estate Tax Dept.
Domestic Relations Section
Commonwealth of PA,
Department of Revenue
1 Courthouse Sq.,
Carlisle, PA 17013
13 N. Hanover St.
Carlisle,. PA 17013
Bureau of Compliance, PO Box 281230
Harrisburg, PA 17128-1230
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 468 wolfs Bridge Road
Carlisle, PA 17013
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. sec. 4904 relating to
unsworn falsification to authorities.
DATED: February 17, 2010
the last recorded holder of every mortgage
UDRE ICE P.C.
. ~
BY:
Attorneys laintiff
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
UDREN LAW OFFICES, P.C.
MARK J. UDREN, ESQUIRE -
STUART WINNEG, ESQUIRE -
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUI:
LOUIS A. SIMONI, ESQUIRE
ADAM L KAYES ESQUIRE -
ATTORNEY
ID #04302
ID #45362
- ID #34576
- ID #75860
(tE - ID #203437
- ID #200869
ID #86408
FOR PLAINTIFF
WOODCREST CORPORATE CENTER 4=
~_ _'
111 WOODCREST ROAD, SUITE 200 `'~.~'
i-,,
CHERRY HILL, NJ 08003-3620 -=
856-669-5400 `~"~'`
pleadings@udren.com `'`
We 11 s Fargo Bank , N . A . , as COURT OF COMMON PLEAS': ~ ~'
Trustee for MASTR Asset Backed :CIVIL DIVISION ~=
Securities Trust 2004-OPT2 :Cumberland County "~
Plaintiff
v. =MORTGAGE FORECLOSURE
Stephen E. Myers ENO. 10-285
Michelle M. Myers
Defendant (s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Michelle M. Myers
468 Wolfs Bridge Road
Carlisle, PA 17013
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Your house (real estate) at 468 Wolfs Bridge Road
Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale
on June 2, 2010, at 10:00 A.M. in the Commissioners Hearing Room,
2nd Floor, Courthouse, Carlisle, PA, to enforce the court
judgment of $91,275.92, obtained by Plaintiff above (the
mortgagee) against you. If the sale is postponed, the property
will be relisted for the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment,
late charges, costs and reasonable attorney's fees. To find out how
much you must pay, you may call: (856) 669-5400.
2. You may be able to stop the sale by filing a petition asking the Court
to strike or open the judgment, if the judgment was improperly entered.
You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact
one, the more chance you will have of stopping the sale. (See notice on
page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold
to the highest bidder. ,You may find out the price bid by calling 856-669-
5400.
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
856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff, you
will remain the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount
due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that
time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for
your house. A schedule of distribution of the money bid for your house will
be filed by the Sheriff within 30 days after 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
distribution is wrong) are filed with the Sheriff within ten (10) days after
Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting
your home back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
800-990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
800-990-9108
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO10-285 Civil
CIVIL ACTION -LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due WELLS FARGO BANK, N.A., AS TRUSTEE FOR
MASTR ASSET BACKED SECURITIES TRUST 2004-OPT2 Plaintiff (s)
From STEPHEN E. MYERS AND MICHELLE M. MYERS
(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 $91,275.92
L.L. $.50
Interest FROM 2/18/10 TO DATE OF SALE 6/2/10 ONGOING PER DIEM OF $6.89 TO ACTUAL
DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE -- $723.45
Atty's Comm
Atty Paid $181.90
Plaintiff Paid
Date,: 02/17/2010
(Seal)
RF.QIIFST[NG PARTY:
Due Prothy $2.00
Other Costs TO BE ADDED
f
David .Buell, rothonotary
By:
Deputy
Name.:. LOUIS A. SIMONI, ESQUIRE
Address: WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
Attorney for: PLAINTIFF
Telephone: 856-669-5400
Supreme Court ID No. 200869
~• UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576 ~~~~' ~"'~i~.,~
ALAN M. MINATO, ESQUIRE - ID #75860 ~~~ ~~"~ +~`~~~~~ ~f)rrt`)'~~Y
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
LOUIS A. SIMONI, ESQUIRE - ID #200869 7Q~Q ~f~Y ~ ~ ~~ ~; L~
ADAM L. KAYES, ESQUIRE - ID #86408
MARGUERITE L. THOMAS, ESQUIRE - ID #204460 ~,L~~~_~`
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WOODCREST CORPORATE CENTER ,
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111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
Wells Fargo Bank, N.A., as Trustee for MASTR :COURT OF COMMON PLEAS
Asset Backed Securities Trust 2004-OPT2 :CIVIL DIVISION
Plaintiff :Cumberland County
v.
Stephen E. Myers
Michelle M. Myers ENO. 10-285
Defendant(s)
AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1
Plaintiff, by its/his/her Attorney hereby verifies that:
1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is
attached hereto as Exhibit "A", was sent to every recorded lienholder and every
other interested party known as of the date of the filing of the Praecipe for the
Writ of Execution, on the date(s) appearing on the attached Certificates of
Mailing.
2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and
certified mail on the date appearing on the attached Return Receipt, which was
signed for by Defendant(s) on the date specified on the said Return Receipt.
Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B"
3. If a Return Receipt is not attached hereto, then service was by personal
service on the date specified on the attached Return of Service, attached hereto
as Exhibit "B".
4. If service was by Order of Court, then proof of compliance with said Order
is attached hereto as Exhibit "B".
All Notices were served within the time limits set forth by Pa Rule C.P. 3129.
This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904
relating to unsworn falsification to authorities.
Dated: April 30, 2010
UDRE~iR~ O FF ICES P C~'`.~
BY : //
Attorneys for"Plaintiff
K J. UDREN, ESQUIRE
STUP,"f2T` VdINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE '~/
CHANDRA M. ARKEMA, ESQUIRE
LOUIS A. SIMONI, ESQUIRE
ADAM L. KAYES, ESQUIRE
MARGUERITE L. THOMAS, ESQUIRE
UDREN LAW OFFICES, P.C.
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
LOUIS A. SIMONI, ESQUIRE - ID #200869
ADAM L. KAYES, ESQUIRE - ID #86408
MARGUERITE L. THOMAS, ESQUIRE - ID #204460
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
Wells Fargo Bank, N.A., as Trustee for
MASTR Asset Backed Securities Trust
2004-OPT2
Plaintiff
v.
Stephen E. Myers
Michelle M. Myers
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 10-285
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
OWNER(S): Stephen E. Myers and Michelle M. Myers
PROPERTY: 468 Wolfs Bridge Road, Carlisle, PA 17013
improvements: RESIDENTIAL DWELLING
The above captioned property is scheduled to be sold at the Cumberland County
Sheriffs Sale on June 2. 2010, at 10:00 A.M., in the Commissioners Hearing Room,
2ND Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a
mortgage or judgment on the property which will be extinguished by the safe. 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 30 days after sale. Distribution will be made in accordance with the
schedule unless exceptions are filed thereto within 10 days after the filing of the
schedule.
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Edward L Schorpp
SOi1CltOr
~ott~tit~, at 4u,rr(,r~fT~j~
i:,
Wells Fargo Bank, NA
vs.
Stephen E. Myers (et al.)
Case Number
2010-285
SHERIFF'S RETURN OF SERVICE
03/30/2010 09:20 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on March
30, 2010 at 2115 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 Stephen E. Myers & Michelle M. Myers,
located at 468 Wolfs Bridge Road, Carlisle, Cumberland County, Pennsylvania according to law.
03/30/2010 09:20 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on 3/30/1C
at 2115 hours, he 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: Stephen E. Myers, by making known unto,
Stephen E. Myers, personally, at, 468 Wolfs Bridge Road, Carlisle, Cumberland County, Pennsylvania its
contents and at the same time handing to him personally the said true and correct copy of the same
03/30/2010 09:20 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on March
30, 2010 at 2115 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: Michelle M. Myers, by making known
unto, Michelle M. Myers, personally, at 468 Wolfs Bridge Road, Carlisle, Cumberland County,
Pennsylvania its contents and at the same time handing to her personally the said true and correct copy o1
the same.
SHERIFF COST: $1,263.92 SO ANSWERS,
~-~~
April 26, 2010 RON ~ R ANDERSON, SHERIFF
~~'~I~~~
(cl Counry8uite SheriYf, TetEOSOft, Inr.. ~ ~ ~ ~ ~ ~ ~ ~
U
. ~ ~ ,_.
SHERIFF'S OFFICE OF CUMBERLAND y
~?~ THc P~ t~ ~ ,~ ~,~,'tR~Y
Ronny R Anderson
Sheriff
Jody S Smith ~ati~~s~ at ~u,gbcrf~ry~ ZD~~ ,~~~ "4 ~~ ~~ ~~
Chief Deputy ~ ~'
Edward L Schorpp ~~ ~`"-~ ~ ~~~~~I'~+ ~~Y~.Vr'~'`~1!{l ~
SOI%C%t0~ t~CEC.~ r~ESr.ER1~F
Wells Fargo Bank, NA
vs. Case Number
Stephen E. Myers (et al.) 2010-285
SHERIFF'S RETURN OF SERVICE
03/30/2010 09:20 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on March
30, 2010 at 2115 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 Stephen E. Myers & Michelle M. Myers,
located at 468 Wolfs Bridge Road, Carlisle, Cumberland County, Pennsylvania according to law.
03/30/2010 09:20 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on 3/30/1C
at 2115 hours, he 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: Stephen E. Myers, by making known unto,
Stephen E. Myers, personally, at, 468 Wolfs Bridge Road, Carlisle, Cumberland County, Pennsylvania its
contents and at the same time handing to him personally the said true and correct copy of the same
03/30/2010 09:20 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on March
30, 2010 at 2115 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: Michelle M. Myers, by making known
unto, Michelle M. Myers, personally, at 468 Wolfs Bridge Road, Carlisle, Cumberland County,
Pennsylvania its contents and at the same time handing to her personally the said true and correct copy o1
the same.
06/01/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ is returned
STAYED, per letter of instruction from Attorney Udren pm 6/1/10
SHERIFF COST: $1,015.58
June 04, 2010
SO ANSWERS,
RON R ANDERSON, SHERIFF
.SD C.i Pd,
~-~ 7132 ~
~~3~7
(ca CountySuite Shentt, TeteosoR. litc.
;~_ ...:
'~ [TDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
L"3.ARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLF, ESQUIRE - ID #34576
AZAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
LOUIS A. SIMONI, ESQUIRE - ID #200869
ADAM L. KAYES, ESQUIRE - ID #86408
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Vdells Fargo Bank, N.A., as =COURT OF COMMON PLEAS
Trustee for MASTR Asset Backed =CIVIL DIVISION
Securities Trust 2004-OPT2 :Cumberland County
Plaintiff
v. :MORTGAGE FORECLOSURE
Stephen E. Myers €NO. 10-285
Michelle M. Myers
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129.1
Wells Fargo Bank, N.A., as Trustee for MASTR
Securities Trust 2004-OPT2, Plaintiff in the
attorney, Mark J. Udren, ESQ., sets forth as
Praecipe for the Writ of Execution was filed
information concerning the real property loc.
Bridge Road, Carlisle, PA 17013
Asset Backed
above action, by its
of the date the
the following
~ted at: 468 Wolfs
1. Name and address of Owner(s) or reputed Owner(s):
Name Address
Stephen E. Myers
Michelle M. Myers
468 Wolfs Bridge Road
Carlisle, PA 17013
468 Wolfs Bridge Road
Carlisle, PA 17013
2. Name and address of Defendant(s) in the judgment:
Name Address
SAME AS #1 ABOVE
3. Name and address of every judgment creditor whose judgment is
a record lien on the real property to be sold:
Name Address
Capital One Bank
140 East Shore Dr.
Glen Allen, VA 23059
~ 4, Name and address of the last recorded holder of every mortgage
~of record:
Name Address
Wells Fargo Bank, N.A., P.O. Box 961730
as Trustee for MASTR Irving, TX 75063
Asset Backed Securities
Trust 2004-OPT2
Pennsylvania Housing 211 North Front Street
Finance Agency (PHFA) Harrisburg, PA 17101
Option One Mortgage Corp. 3 Ada, Irvine, CA 92618
A CA Corp.
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 and whose interest may be affected by
the sale:
Name Address
Real Estate Tax Dept.
Domestic Relations Section
Commonwealth of PA,
Department of Revenue
1 Courthouse Sq.,
Carlisle, PA 17013
13 N. Hanover St.
Carlisle, PA 17013
Bureau of Compliance, PO Box 281230
Harrisburg, PA 17128-1230
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
468 Wolfs Bridge Road
Carlisle, PA 17013
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. sec. 4904 relating to
unsworn falsification to authorities.
DATED: February 17, 2010
UDREN.<'LAV~,'O~'~ICE~ , P . C .
rF ~
~!
B Y . F ~~~ •-• ~.. .
Attorneys`for"Plaintiff
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQtTIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
~ FJLR~N LAW OFFICES, P.C.
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DQYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
LOUIS A. SIMONI, ESQUIRE - ID #200869
ADAM L. KAYES, ESQUIRE - ID #86408
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
We11s Fargo Bank, N.A., as
Trustee for MASTR Asset Backed
Securities Trust 2004-OPT2
Plaintiff
v.
Stephen E. Myers
Michelle M. Myers
Defendant(s)
ATTORNEY FOR PLAINTIFF
3
:COURT OF COMMON PLEAS
-CIVIL DIVISION
:Cumberland County
'MORTGAGE FORECLOSURE
€NO. 10-285
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Stephen E. Myers
468 Wolfs Bridge Road
Carlisle, PA 17013
Your house (real estate) at 468 Wolfs Bridge Road, Carlisle, PA
17013 is scheduled to be sold at the Sheriff's Sale on June 2,
2010, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor,
Courthouse, Carlisle, PA, to enforce the court judgment of
$91,275.92, obtained by Plaintiff above (the mortgagee) against
you. If the sale is postponed, the property will be relisted for
the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To pre~rent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment,
late charges, costs and reasonable attorney's fees. To find out how
much you must pay, you may call: (855)-559-5400.
2. You may be able to stop the sale by filing a petition asking the Court
to strike or open the judgment, if the judgment was improperly entered.
You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact
one, the more chance you will have of stopping the sale. (See notice on
page two on how to obtain an attorney.)
~ YQ~U MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold
to the higl.e~t bidder. You may find out the price bid by calling 856-669-
5400.
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
856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff, you
will remain the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount
due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that
time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for
your house. A schedule of distribution of the money bid for your house will
be filed by the Sheriff within 30 days after 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
distribution is wrong) are filed with the Sheriff within ten (10) days after
Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting
your home back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
800-990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
800-990-9108
AI,L THOSE TWQ TRACTS OF GROUND WITH IMPROVEMENTS THEREON ERECTED
SITUATE'IN THE TOWNSHIP OF MIDDLESEX, CUMBERLAND COUNTY,
PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS:
TRACT NO.l
BEGINNING ON THE NORTH BY A PUBLIC ROAD LEADING FROM CARLISLE
SPRINGS TO MIDDLESEX ON THE EAST BY A TRACT NOW OR FORMERLY OF
FRED GILLIARD AND MADELLE GILLIARD, HIS WIFE ON THE SOUTH BY A
LOT NOW OR FORMERLY OF JOHN E. HEFFLEFINGER AND OMA A.
HEFFLEFINGER, HIS WIFE; AND ON THE WEST BY A LOT NOW OR FORMERLY
OF P.Q. SUNDAY.
CONTAINING 90 FEET, MORE OR LESS, FRONTAGE ON THE ROAD AND
EXTENDING IN DEPTH 133 FEET, WIDE A WIDTH OF 107 FEET ON THE
SOUTHERN BOUNDARY LINE.
TRACT NO. 2
BEGINNING ON THE NORTH BY A PUBLIC ROAD LEADING FROM CARLISLE
SPRINGS TO MIDDLESEX; ON THE EAST, SOUTH AND WEST BY LANDS NOW OR
FORMERLY OF JOHN E. HEFFLEFINGER AND OMA A. HEFFLEFINGER, HIS
WIFE.
CONTAINING 56 FEET, MORE OR LESS, FRONTAGE ON THE ROAD AND
EXTENDING IN DEPTH AT AN EVEN WIDTH 115 FEET, MORE OR LESS, TO
OTHER LANDS NOW OR FORMERLY OF JOHN E. HEFFLEFINGER AND OMA A.
HEFFLEFINGER, HIS WIFE.
SAID LAND BEING IMPROVED WITH A FRAME DWELLING HOUSE.
ENDER CAN SUBJECT, NEVERTHELESS, TO EASEMENTS, RESTRICTIONS,
RESERVATIONS, CONDITIONS AND RIGHTS OF WAY OF RECORD.
BEING THE SAME PREMISES WHICH JANE A. ADAMS, BY DEED DATED
08/15/96 AND RECORDED 8/15/96 IN CUMBERLAND COUNTY RECORD BOOK
144, PAGE 296, GRANTED AND CONVEYED UNTO JEFFREY C. EDMONDS, IN
FEE.
BEING KNOWN AS: 468 Wolfs Bridge Road
Carlisle, PA 17013
PROPERTY ID NO. 21-14-0867-032
TITLE TO SAID PREMISES IS VESTED IN STEPHEN E. MYERS AND MICHELLE
M. MYERS BY DEED FROM JEFFERY C. EDMONDS AND JEFFREY J. JANCSE,
EQUITABLE OWNER DATED 6/9/04 RECORDED 6/16/04 IN DEED BOOK 263
PAGE 2860.
' WRIT OF EXECUTION and/or ATTACHMENT /
' t
COMMONWEALTH OF PENNSYLVANIA) NO10-285 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION -LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due WELLS FARGO BANK, N.A., AS TRUSTEE FOR
MASTR ASSET BACKED SECURITIES TRUST 2004-OPT2 Plaintiff (s)
From STEPHEN E. MYERS AND MICHELLE M. MYERS
(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 properly 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 $91,275.92
L.L. $.50
Interest FROM 2/18/10 TO DATE OF SALE 6/2/10 ONGOING PER DIEM OF $6.89 TO ACTUAL
DATE OF SALE INCLUDING IF SALE iS HELD AT A LATER DATE -- $723.45
Atty's Comm
Atty Paid $181.90
Plaintiff Paid
Due Prothy $2.00
Other Costs TO BE ADDED
Date: 02,'17/2010
`(~eal)
RL~UESTING PARTY:
:~~ame: L~3UI:S A. SIMONI, ESQUIRE
Address: WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
Attorney for: PLAINTIFF
David D. Buell, Prothonotary
By:
Deputy
Telephone: 856-669-5400
Supreme Court ID No. 200869
On March 22, 2010 the Sheriff levied upon the
defendant's interest in the real property situated in
Middlesex Township, Cumberland County, PA,
Known and numbered as, 468 Wolfs Bridge Road, Carlisle,
more fully described on Exhibit "A" filed with this writ and
by this reference incorporated herein.
Date: March 22, 2010
By: ._
~~~
~~~
Real Estate Coordinator
CjU ~~.,':j ~`4, lJ 1 vJ ; U!:i 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 16, Apri123, 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.
~~ititi ~""
isa Marie Coyn ,Editor
SWORN TO AND SUBSCRIBED before me this
30 day of April, 2010
.~
Notary
NOTARIAL SE
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH, CUMBERLAND COUNTY
My Commission Expires Apr 28, 2014
Writ No. 2010-285 Civil
Wells Fargo Bank, NA as Trustee
for ABFC 2006-OPT3 Trust, ABFC
Asset-Backed Certificates, Series
2006-OPT3
vs.
Stephen E. Myers
Michelle M. Myers
Atty: Mark J. Udren
ALL THOSE TWO tracts of ground
with improvements thereon erected
situate in the Township of Middlesex,
Cumberland County, Pennsylvania,
bounded and described as follows:
TRACT NO.1
BEGINNING on the north by a
public road leading from Carlisle
Springs to Middlesex on the east by a
tract now or formerly of Fred Gilliard
and Madelle Gilliard, his wife on the
south by a lot now or formerly of John
E. Hefflefinger and Oma A. Hefflefin-
ger, his wife; and on the west by a lot
now or formerly of P.Q. Sunday.
CONTAINING 90 feet, more or
less, frontage on the road and ex-
tending in depth 133 feet, wide a
width of 107 feet on the southern
boundary line.
TRACT NO. 2
BEGINNING on the north by a
public road leading from Carlisle
Springs to Middlesex; on the east,
south and west by lands now or
formerly of John E. Hefflefinger and
Oma A. Hefflefinger, his wife.
CONTAINING 56 feet, more or less,
frontage on the road and extending
in depth at an even width 115 feet,
more or less, to other lands now or
formerly of John E. Hefflefinger and
Oma A. Hefflefinger, his wife.
SAID LAND being improved with
a frame dwelling house.
UNDER OAN SUBJECT, never-
theless, to easements, restrictions,
reservations, conditions and rights
of way of record.
BEING the same premises which
Jane A. Adams, by deed dated
08/15/96 and recorded 8/15/96 in
Cumberland County Record Book
144, Page 296, granted and conveyed
unto Jeffrey C. Edmonds, in fee.
Being Known As: 468 Wolfs Bridge
Road, Carlisle, PA 17013.
Property ID #i 21-14-0867-032.
Title To said premises is vested
in Stephen E. Myers and Michelle
M. Myers by deed from Jeffrey C.
Edmonds and Jeffrey J. Jancse,
Equitable Owner, dated 6/9/04,
recorded 6/ 16/04 in deed book 263
page 2860.
--~ The Patriot-News Co.
2020 Technlology Pkwy
Suite 300
Mechanicsburg, PA 17050
Inquiries - 717-255-8213
c~epatriot Neu~s
Now you know
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Marianne Miller, being duly sworn according to law, deposes and says:
That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of
Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News
newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that
The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and
all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is
interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time,
place and character of publication are true; and
That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to 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
Sworn to an~bscribed before me this 18 da~of? ay, 2010 A.D.
.~', '~~
~~ <
Notary Public
COMMONWEALTH 0~ P+~NN3YLVANtE1
Noterl~l SeN
Sherrie L. K15rkr, Notary PuWlc
Lower Paxton Twp., Dauphin County
My Commh.~ion fxpir~ Nov. 26, 201!
04/23/10
04/30/10
Memlxxr, Pennsytvanla A~ociatlon of Notaries
~'~rR No. 2D10-286 Givil Term
Wells Fargo Bank, NA
as Trustee for AFC 2006-OPTS
Trust,
ABFC Asset-Backed Certificates,
Serbs
2006-0PT3
Ve.
S'wphsn E Myrls
NNohielle M: Mywa
Ally: Mark J Udren
ALL THOSE TWO TRACTS OF GROUND
WITH IMPROVEMENTS THEREON
ERECTED SITUATE IN THE TOWNSHIP OF
MIDDLESEX, CUMBERLAND COUNTY, ~,.
PENNSYLVANIA, BOUNDED AND'
DESCRIBED AS FOLLOWS:
TRACE N0.1 ~
BEGINNING ON THE NORTH BY A PUBLIC
ROAD LEADING FROM CARLISLE SPRINGS
TO MIDDLESEX ON THE EAST BY A TRACT
NOW OR FORMERLY OF FRED GIl.LIARD
AND MADELLE GILLIARD, HIS WIFE ON
THE SOUTH BY A LOT NOW OR FORMERLY
OF JOHN E. IIEFFI,EFINGER AND OMA A.
HEFFLEFINGER, HIS WIFE;.AND ON THE
WEST BY A LOT NOW OR FORMERLY OF
P.Q. SUNDAY.
CONTAINING 90 FEET, MORE OR
LESS, FRONTAGE ON THE ROAD AND
EXTENDING IN DEPTH 133 FEET, WIDE A
WIDTH OF 107 FEET ON THE SOUTHERN
BOUNDARY LINE.
TRACT N0.2
BEGINNING ON THE NORTH BY A PUBLIC
ROAD LEADING FROM CARLISLE SPRINGS
TO MIDDLESEX; ON THE EAST; SOUTH
AND W EST BY LANDS NOW OR FORMERLY
OF JOHN E. HEFFLEFINGER AND OMA A.
HEFFLEFINGER, HIS WIFE.
CONTAINING 56 FEET, MORE OR LESS,
FTt~NTAGEONTHEROADANDEXTENDING
IN DEPTH AT AN EVEN WIDTH 115 FEET,
MORE OR LESS, TO OTHER LANDS NOW
OR FORMERLY OF JOHN E. HEFFI,EFINGER
ANIS OMA A. HEFFLEFINGFIZ,, HIS WIFE.
SAID LAND BEING INiPROVED'WITH A
FRAME DWELLING HOUSE.
UNDER OAN SUBJECT, NEVERTHELESS,
T0. EASEMENTS, RESTRICTIONS,
R1~ERVATIONS, CONDITIONS AND RIGHTS
OF WAY OF RECORD.
BEING THE SAME PREMISES WHICH JANE
A. ADAMS, BY DEED DATED 08(15/96 AND
RECORDED 8/15/96 IN CUMBERLAND
COUNTY RECORD BOOK 144, PAGE
296, GRANTED AND CONVEYED UNTO
JEFFREY C. EDMONDS, IN FEE.
BEING Known As: 468 Wolfs Bridge Road,
Carlisle, PA 17013
Property ID # 21-14-0867-032
Title To said`premises is vested in Stephen E.
My~ and Michelle M. Myers by deed from
Jeffrey C. Edmonds and Jeffrey J. Jancse,
Equitable Owner, dated 6/9404. recorded N164D4
indeed book 263 page 2860.
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003
856-669-5400
Wells Fargo Bank, N.A., as :COURT OF COMMON PLEAS
Trustee for MASTR Asset Backed :CIVIL DIVISION o
Securities Trust 2004-OPT2 :Cumberland County - Z -
P.O. Box 961730 rnCO
r z,. Z=-F"
Irving, TX 75063 .ar
n C ----
r
0
Plaintiff :NO. 10-285 -< > c?
v ' -
.
Stephen E. Myers ? f? c-
Michelle M. Myers
468 Wolfs Bridge Road
Carlisle, PA 17013
Defendant(s)
PRAECIPE TO WITHDRAW JUDGMENT AND DISCONTINUE WITHOUT PREJUDICE
TO THE PROTHONOTARY:
Kindly mark the above captioned matter JUDGMENT WITHDRAWN
and ACTION DISCONTINUED WITHOUT PREJUDICE, upon payment of your
costs only.
DATED: July 27, 2011
Attorney for Plaintiff
09120657-1