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Home My WebLink About10-2239 UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - TD #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 v,Z6UIS 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 ATTORNEY FOR PLAINTIFF C7 0 Jl: 13 J y Cn ) { . ;71) co Deutsche Bank National Trust :COURT OF COMMON PLEAS Company, as Trustee for Morgan :CIVIL DIVISION Stanley ABS Capital I Inc. Trust 2007-NC2 Cumberland 4708 Mercantile Drive Ft. Worth, TX 76137 Plaintiff V. William S. Moser County 404 Lamp Post Lane : NO. !O - =39 Camp Hill, PA 17011 Defendant (s) COMPLAINT IN MORTGAGE FORECLOSURE Ct V < <Ter(A 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 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 6) Carlisle, PA 17013 *qaa-00 pis Ai-rl 800-990-9108 148501 ?. a?gsgo F 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 notificacion. 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 C. 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, who is the legal holder of the mortgage and is in the process of formalizing the Assignment of Mortgage to be sent for recording. 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: 404 Lamp Post Lane MUNICIPALITY/TOWNSHIP/BOROUGH: Hampden Township COUNTY: Cumberland DATE EXECUTED: 9/25/06 DATE RECORDED: 10/16/06 BOOK: 1969 PAGE: 2667 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 refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pay the installments of F 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 3/25/10: Principal of debt due $321,087.90 Unpaid Interest at 9.05%* from 2/1/09 to 3/25/10 (the per diem interest accruing on this debt is $79.61 and that sum should be added each day after 3/25/10) 33,276.98 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $252.59 and that sum should be added on the first of each month after 3/25/10) 7,898.93 Late Charges (monthly late charge of $131.97 should be added in accordance with the terms of the note each month after 3/25/10) 1,528.69 Attorneys Fees (anticipated and actual to 50 of principal) 16,054.40 TOTAL $380,451.90 *This interest rate is subject to adjustment as more fully described in the note and mortgage. 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 n 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 198.3 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 $380,451.90 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. UDRE CES, P.C. BY: Attorneys or Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE -NP,OUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE Maf-26-2010 09M Fras- 7-483 F.OD#AN F-294 TaXt MnMW 4gt at lassd, &,A eWwt- 3r. kwpc?r.• Townr4l;4. 0wbderXardelt ::pwtty. Pat"VI-vMai$., imu p&r_icuIo'w1+ aau:.t Va aid 0ag-r ii i'6::?Y. Xn wI# ? W. At 0 5. "Point feet tAaM-rtftxriyaide diOf LASP ra nSa m.anrw :!r.._ish =Ss1C r,orckmaSt tcrmft, Of rar:iagt, house Dr V4 fffo Leap Pon Lenc w+,r; ;U0 dw?41-K fins batw0cm Late 14. ly End. 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BEAi?141?dQ -:?1h1':?Y ACT 91 NOTICE DATE OF NOTICE: 12/22/2009 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. This is an official notice that the mortga e on your home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notification en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. Prepared by: GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 Fax (215) 627-7734 EXHIBIT A Date: 12/22/2009 Homeowners Name: WILLIAM S. MOSER Property Address: 404 Lamp Post Lane, Camp Hill, PA 17011 Loan Account No.: 2000250770 Original Lender: SAXON MORTGAGE SERVICES INC. Current Lender/Servicer: SAXON MORTGAGE SERVICES INC. HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (33) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set C forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be filed or postmarked within thirty (30) days of your fact-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE; IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT Bring it up to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 404 Lamp Post Lane, Camp Hill, PA 17011 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payment from 03/01/2009 thru 12/22/2009 (10 mos. at $2,891.99/month) $28,919.90 (b) Late charges from 03/01/2009 thrul2/22/2009 (10 mos. at $131.97/month) $1,319.70 (c) Other charges; Escrow, Inspec., NSF Checks (d) Other provisions of the mortgage obligation, if any (e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $30,239.60 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $30,239.60, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check, certified check or money order made payable and sent to: SAXON MORTGAGE SERVICES INC. 4708 Mercantile Drive North Fort Worth, TX 76137 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender brings legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY Period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. e RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by pgyina the total amount then past due, plus anv 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 anv 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 Sheriff s Sale of the mortgaged property could be held would be approximately four (4) to six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: SAXON MORTGAGE SERVICES INC. Address: 4708 Mercantile Drive North Fort Worth, TX 76137 Phone Number: 888-325-3502 Contact Person: Loss Mitigation Department EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. BEHALF. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR f? * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Contact: Loss Mitigation Department Phone Number: 888-325-3502 HEMAP Consumer Credit Counseling Agencies Report last updated: 11/27/2009 2:32:10 PM CCCS of Western PA 4402 Peach Street Erie,PA 16509 888.511.2227 ext 108 888.511.2227 ext 108 Center for Family Services, Inc. 213 Center Street Meadville, PA 16335 814.337.8450 Greater Erie Community Action Committee 18 West 9TH Street Erie, PA 16501 814.459.4581 Shenango Valley Urban League, Inc. 601 Indiana Avenue Farrell, PA 16121 724.981.5310 St. Martin Center 1701 Parade Street Erie, PA 16503 814.452.6113 CUMBERLAND County CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 888.511.2227 Community Action Commission of Captial Region 1514 Deny Street Harrisburg, PA 17104 717.232.9757 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PA Interfaith Community Programs Inc 40 E High Street Gettysburg, PA 17325 717.334.1518 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 DAUPHIN County CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 888.511.2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 DELAWARE County Advocates for Financial Independence 202 East Hinkley Avenue Ridley Park, PA 19078 215.389.2810 American Credit Counseling Institute 175 Strafford Avenue Suite 1 Wayne, PA 19087 610.971.2210 888.212.6741 American Credit Counseling Institute 526-528 Dekalb Street Norristown, PA 19401 610.971.2210 888.212.6741 American Financial Counseling Services Inc. 1080 N. Delaware Avenue Suite 200 Philadelphia, PA 19125 267.228.7903 800.490.3039 American Financial Counseling Services Inc. 405 West Germantown Pike Norristown, PA 19403 267.228.7903 800.490.3039 American Financial Counseling Services Inc. 175 Strafford Avenue Suite One Wayne, PA 19087 267.228.7903 800.490.3039 Page 8 of 21 C, 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. UDR CES, P.C. BY: Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE •,OUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE E IIDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. IIDREN, ESQIIIRE - ID #04302 STIIART WINNEG, ESQIIIRE - ID #45362 ~-' ~ ~~~~ T~ ~~ r LORRAINE DOYLE, ESQIIIRE - ID #34576 - ' ALAN M. MINATO, ESQIIIRE - ID #75860 CHANDRA M. ARKEMA, ESQIIIRE - ID #203437 G~~~ ,.'_:~__ ~~ ~'~`~ _'~ ~ ~• ADAM L. KAYES, ESQIIIRE - ID #86408 Jul, 3D ~~ 3 ~• ~3 MARGUERITE L. THOMAS, ESQIIIRE - ID #204460 [[''~ `• ' `.~•- V Li~i •i~~ ... _ ~~VI ~ WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SIIITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Company, as :COURT OF COMMON PLEAS Trustee for Morgan Stanley ABS Capital I Inc. :CIVIL DIVISION Trust 2007-NC2 :Cumberland County Plaintiff v. William S. Moser Defendant(s) NO. 10-2239 AFFIDAVIT OF SERVICE PIIRSIIANT TO Pa.R.C.P.RIILE 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: July 21, 2010 UDREN LA Y• Attorneys for Pl iff S UIRE STUART WINNEG, E I LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUI~2E 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 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 Deutsche Bank National Trust Company, as Trustee for Morgan Stanley ABS Capital I Inc. Trust 2007-NC2 Plaintiff v. William S. Moser Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON CIVIL DIVISION Cumberland County PLEAS NO. 10-2239 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): William S. Moser PROPERTY: 404 Lamp Post Lane, Camp Hill, PA 17011 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberiand County Sheriffs Sale on September 8, 2010, at 10:OOam, 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 sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 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. ExHiB~T a .~ v~ N 0 O W O O n C (D .~ T O W OD V y TI lD Q' c m +~ O 3 C Q' fD n O eo C. ~c i A 7 1 7~ 7 r -i to O ~ CT -~ A ~ W ~ N ~ ~ ~ O f~ OD v O fr ? W N -~ r 7 Z 3 D p~ n~ ~ Wnn.~ ~ o•c _ c ~(D ~ m m t71 ~ c O N ~ 3 ~ N m n ° ~ ~ N _ ~ . N _~ N o ~ ~ ~ o m y ~ ~ ° °' o pmp -~~ o~ ~o m°? ~ wcn ~ ~y Wm~ mm ~oo a o ~ n np~ ~= ° = Nn v =3 Z ° ~ NZO -~ cn ' ~ C~ -i m o~ ~, a x ~ ~ z mvm Z m ~ N _-~ ~ ~ m Z D C ~ n ~nr ~ ~~ -°~ ~O ~ C C ~m mv N ~ '<R iD H°. „ DN C~ N W wCm v~~ cnc~ ~ ~ xcng ~ r. N C o ~ r m N '0~ ~ ~y ~ O ~ TI- i D2 ~ ~ yZ ~ C~ ~' O ~ ~~ y v D m~ D c z m c Z vi O~ ~m nm ~ ~ oh ~ c ° 3 ao to ~ ~ ~~ ~ ~~ ~ m cC io ~ C7 D `''' O ~ m T ~ °w ~ m °' i Z r cn I'n . D m w mD ~ N ° _ s~~ z ~m D ~ o ~ m v-. D ~ ~ NZO = D ~ ~ ~ n n 1 w ~ m T z g N ~ w m ~ W ~ ~ ^ ^ ^^ °, O C7 C7 ~ ~ m ~ ~ ~ ~°• .f ~p f/1 ~ ~ n m ~ 'fl H a a m 1 y a ~ ~ ~ ^0~^ 0 1 016H265192 16 1 x ~ n ~ m fD ' L ~ ~ ~ T ~ ~ _ S 'O - d C ~7 y . ' OT 7~ `~ V Q .~ ~ • = f~~s' f7~I2 ~ ~ A ~ H ~ ~ ~ t 1Q j _ ~ Mai:2~ €ra:n J80J3 - - C D ~ N v ~ ~dQ;" o ~`~ ~ m c r ~ fJ a~ ~~~ f M~~ ~ N o v~c`~o a `~3 y 72 o ~ wgm y o m~- ~ d 3 C SN d a ^~.Z1C) '~o mn~ Uf _. ° ~ N~ !° c ~<~'n _. N ~ O m Na w ~ ~ S S N y ~ ~ ~ `~ O ~ ~ ~ ~ G' O ~~ vOO~ ~° m3moo~, ~.~n '4 N O O d ~~'p - N N m m o~ n m (A 7 C Q d 3 ~, p ~ n 0 C O m c ~ n n (p ~~ m ~ Q ~ ° ~ p~j n y c n~ p N ~.~ m o d' C ~ m d N c ~ ~ m 3 m _. >>n% ~;m.~~Q ~.v ~ a~D 'cnm3m ~ y nN y n~k d aim 3 ~m ~~ N 701 .» d ~ ~~.3 4~i 0~ ~ Q ~ ~ y... . J d OO`Z A d (~ ~ °~ = ~ M ~d O~ n ~.3m m~. ' - ' d N d vim" ~~yo~ m ~ S ~ T ~~ . v N W ~ ~ d ° ~ n . ~ y ~, ?O~c 0 =c`wa ~ j w t" ~+~+ ND 01 ~ N n~ Z ~~ ~ ~ ti a. m N d ~mW o ~a3 ~O\ y N y c y~g~~s 2 m d ~ m a aca ~ N ~ ~ ~ J O 3.~~° ° ~.~~~~ EX IBI A ~ N ° - w ~ ~ ~ ~ T °,°' m o N SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~,,tr ci ~u~hbrr~ Jody S Smith ~9 ~d Chief Deputy ~ r } ~~~ r~~ '~ ~ Richard W Stewart `~°~°~`^ Solicitor c~lc~ ~F T~= sN~R(~F Deutsche Bank National Trust Company vs. William S. Moser Case Number 2010-2239 SHERIFF'S RETURN OF SERVICE 06/26/2010 10:06 AM -Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on 6-26-2010 at 0957 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 William S. Moser, located at, 404 Lamp Posi Lane, Camp Hill, Cumberland County, Pennsylvania according to law. 06/26/2010 10:06 AM -Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on 6-26-2010 at 0957 hours, she 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: William S. Moser, by making known unto, John Debogory, adult in charge, at, 404 Lamp Post Lane, Camp Hill, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $898.92 July 02, 2010 I~l ~:.... SO ANSWERS, «, C~---~...,. RON R ANDERSON, SHERIFF Ex-~817' ~ (ci CouniySuite Sheriff, Teleosoft, Inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY t _ Ronny R Anderson a - Sheriff ~ Jody S Smith y; x Chief Deputy Richard W Stewart Solicitor Deutsche Bank National Trust Company Case Number vs. William S. Moser 2010-2239 SHERIFF'S RETURN OF SERVICE 06/26/2010 10:06 AM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on 6-26-2010 at 0957 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 William S.' Maser, located at, 404 Lamp Posi Lane, Camp Hill, Cumberland County, Pennsylvania according to law. 0612612010 10:06 AM Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law; states that on 6-26-2010 at 0957 hours, she 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: William S. Moser, by making known unto, John bebogory, adult in charge, at, 404 Lamp Post Lane, Camp Hill, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of''.the same. 09/07/2010 As directed by Alan M Minato, Attorney for the Plaintiff, Sheriffs Sale Continued to 10/6/2010 10/06/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on October 6, 2010 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Alan Minato, on behalf of Deutsche Bank National Trust Company as Trustee for Morgan Stanley ABS Capital 1, Inc., Trust 2007-NC2, Mortgage Pass-Through Certificates, Series 2007-NC2 of, 1661 Worthington Road, Ste 100, West Palm Beach, FL 33409, being the buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of $ SHERIFF COST: $983.22 SO ANSWERS, November 08, 2010 RONNY R ANDERSON, SHERIFF 1019 Ce, - s r ,U "DREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF _ MARK J. UDREN, ESQUIRE ID #04302 STUART WI'NNEG, ESQUIRE - ID #45362 LORRAINE DOYLE,sESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsl!-Pudren.com Deutsche Bank National Trust :COURT OF COMMON PLEAS Company, as Trustee: for Morgan, :CIVIL DIVISION Stanley ABS Capital. I Inc. ;Cumberland County Trust 2007-NC2 Plaintiff :MORTGAGE FORECLOSURE V. William S. Moser NO. 10-2239 Defendant(s) y, AFFIDAVIT--,„PURSUANT TO RULE 3129.1 Deutsche Bank National Trust Company, as Trustee for Morgan Stanley ABS Capital I Inc. Trust 2007-NC2, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 404 Lamp Post Lane, Camp Hill, PA 17011 1. Name and address of Owner(s) or reputed Owner(s): Name Address William S. Moser 404 Lamp Post Lane Camp Hill, PA 17011 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 None 4. Name and address of the last recorded holder of every mortgage of record: Name Address Deutsche Bank National Trust 4708 Mercantile Drive Company, as Trustee for Ft. Worth, TX 76137 Morgan Stanley ABS Capital I Inc. Trust 2007-NC2 Mortgage Electronic! PO Box 2026 Registration Systems, INC Flint, MI 48501-2026 b 5. Name and address of every other person who has any record lien on th(e 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 Department Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, PA 17013 13 North Hanover 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 404 Lamp Post Lane Camp Hill, PA 17011 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: May 22, 2010. UDRE P C. BY : ".,.. Attorneys -for- P?ntif f MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE 1-7 77DREN LAW OFFICES, P. C. ATTORNEY FOR PLAINTIFF 7114ARK J. UDREN, ESQUIRE - ID #04302 I STUAR.T WI.NkEG, ESQUIRE - ID #45362 .. 1!ORRA.INE D®YLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 140ODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust 'COURT OF COMMON PLEAS Company, as Trustee for Morgan :CIVIL DIVISION Stanley ABS Capital I Inc. :Cumberland County Trust 2007-NC2 Plaintiff ;MORTGAGE FORECLOSURE V. William S. Moser NO. 10-2239 Defendant (s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: William S. Moser 404 Lamp Post Lane Camp Hill, PA 1.7011 Your house (real estate) at 404 Lamp Post Lane, Camp Hill, PA 17011 is scheduled to be sold at the Sheriff's Sale on September 8, 2010, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgmentof $385,838.40, 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.) { 1. Tf 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 :gale. 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 ALL THAT CERTAIN LOT OF LAND SITUATE IN HAMPDEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED .AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE EASTERLY SIDE OF LAMP POST LANE, WHICH POINT IS 2913.17 FEET IN A NORTHERLY DIRECTION FROM THE NORTHEAST CORNER OF CARRIAGE HOUSE DRIVE AND LAMP POST LANE AT THE DIVIDING LINE BETWEEN LOTS NO. 29 AND 30, BLOCK D, OF THE HEREINAFTER MENTIONED PLAN; THENCE BY LAMP POST LANE, NORTH 19 DEGREES 13 MINUTES WEST, 100 FEIN TO A POINT AT THE DIVIDING LINE BETWEEN LOTS NO. 30 AND 31, BLOCK D, OF THE PLAN; THENCE BY SAID DIVIDING LINE, NORTH 70 DEGREES 47 MINUTES EAST, 149.21 FEET TO A POINT ON THE WESTERLY SIDE OF CONODOGUINET CREEK; THENCE BY SAME, SOUTH 23 DEGREES 13 MINUTES EAST, 100.24 FEET TO A :POINT AT THE DIVIDING LINE BETWEEN LOTS NO. 29 AND 30, BLOCK D OF THE PLAN; THENCE BY SAID DIVIDING LINE, SOUTH 70 DEGREES 47 MINUTES WEST 156.20 FEET TO A POINT ON THE EASTERLY SIDE OF LAMP POST LANE, THE PLACE OF BEGINNING. BEING ALL OF LOT NO.30, BLOCK D, PLAN 10, PINEBROOK, WHICH-PLAN IS RECORDED IN THE CUMBERLAND COUNTY RECORDER'S' OFFICE IN PLAN BOOK 19, PAGE 85.. HAVING THEREON ERECTED A DWELLING KNOWN AND NUMBERED AS 404 LAMP POST LANE CAMP HILL, PENNSYLVANIA. UNDER AND SUBJECT, NEVERTHELESS, TO CONDITIONS, RESTRICTIONS, EASEMENTS AND RIGHTS-OF-WAY OF RECORD. BEING KNOWN AS: 404 Lamp Post Lane Camp Hill, PA 17011 PROPERTY ID NO.: 10-20-1848-034 TITLE TO SAID PREMISES IS VESTED IN WILLIAM S. MOSER, SINGLE MAN BY DEED FROM WILLIAM S. MOSER AND BYRON ANDREW YOH, EXECUTORS OF THE ESTATE OF C. ANDREW YOH, JR. DATED 07/13/1999 RECORDED 07/14/1999 IN DEED BOOK 203 PAGE 885. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH'OF PENT' SYLVANIA) NO 10-2239 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisf / the debt, interest ,and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY, as Trustee for MORGAN STANLEY ABS CAPITAL I INC. TRUST 2007-NC2, Plaintiff (s) From WILLIAM S. MOSER (1) You are directed to le`ry 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 $385,838.40 L.L.$.50 Interest from 5/23/10 to 9/8/10 Ongoing per diem of $79.61 to actual date of sale including if sale is held at a later date -- $8,677.49 Atty's Comm % Due Prothy $2.00 Atty Paid $174.00 Other Costs Plaintiff Paid Date: 6/1/10 (Seal) J David D. Buell, Pr(lhonotary By: Deputy REQUESTING PARTY: Name: ALAN M. MINATO, ESQUIRE Address: UDREN LAW OFFICES, PC WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,1\fJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 75860 t On June 14; 2010 the;,Sheriff levied upon the defendant's interest in the real property, situated in Hampden Township, Cumberland County, PA, Known and numbered as, 404 Lamp P'o'st Lane, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein, Date: June 14, 201Q By: Real Estate Coordinator i 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 sane as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 16, July 23, and July 30, 2010 Affzant 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 utter of the aforesaid notice or advertisement, and that all allegations in the foregoing atements as to time, place and character of publication are true. i isa Marie Coyn Editor SWORN TO AND SUBSCRIBED before me this 30 _ day of July, 2010 C? - I Notary NOTARIAL'SE A_L""? DEBORAH A COLLINS RUSLE BOROUGH Notary Public . CUMBERLAND coo My Commission Expires Apr 28, 2014 Writ No 2010-2235 Civil Deutsche Bank National Trust Company vs. W0.liam S. Moser Atty.: Plan M. h'iinato ALL THAT CE;RT.grT,r 13t of land- situate in Halx?pden Tov,-nship, Cum- berland County, Pennsylvania, more pa.-ticr.iar1 ao-,?nded and described as follows, to wit: BEGINNING at z pcir.t on the- easterl-, side of Lamp Pcst Lane, which point is 2913.17 feet in a riostherly direcuen riom the north- east corner of Carriage. House Dr'cc and Lam ti Pus- L,a.e at the ividinz- line between Lots No. 29 end 30, Block D. of'! - hehn_re nafter ::ientioned n'1an: thence by Lamp Pont Lane, North 19 degree's 13 ini.nutes West, 100 feet to a point at the dividingline L%etween Lots No. 30 and 31; Blodk D, of the plan: thence 'by sai%' dividing line, North 70 degrees 47 minutes' East, 149.21 feet to a. poir,- on the westerly side of Cc.rodos-trh -t Creel ; thence b? same, So, t,h 23 den •ees 18 minutes East. 00.24 feet to a paint at the, dividing line, bct_ween Lots No. 29 and 30, Brock D of the plan.- thence by sad di-Od,ng i ne, Scuth 70 dearer-s , miner es W-_,t 156.20 feet to a po nt on fne easterly' side of lamp post lane, the piace o` BEGINNING. BEING all of Lot lac. 33. Plo k D. Plan lv, Pineb-ool Which plan is recorded in the Cum_berlard Co?anr.?r, Rcco;der's Office i P`_n Pc-k J_9, Page 85. A J1NG '17 S- EREi 1N ERECTED z dwelling knoxn and numbered as 404 Lamp Post Lane; Comp Fill, Pennsylvania. UNDER AND SUDJECT,nev??rt'De_ less, to conditions, restrictions. ca-F, - rne,nts and rights-of wa,y of re<cord_ BF_iNG KNOWN AS: 40 Lz?:.p Post Lane, Cam;; H' PA 17011. PROPERTY ;D NO.: 10-20-18443 034. T17L.E TO SAfD PREi,AIS S ?S VESTED IN Williar S. Moser, singie man bt= deed from Wih am S. Mosel, and Byron Andrew Yo , e rec?!tors ofi the estate of C. Andre,.< Yoh, Jr, dated 07/13/1999 recorded 07;'14/199 in Teed Book 203 rage 38 The Patriot-News Go. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE the patt votwXews Now you know CARLISLE . PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, 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: 07109/10 07/16/10 07/23/10 worn to any d bscribed before met is d August, 2010 A.D: Notary Public 1___CO "WEA 7-°H OF PE PE N r1a1 SYLVAtVM . errle L Klsnpr Notary Pubiic Lower Pa xton 'rWP., dauphin Coun ?Y C0Mrnissio?p Ir851?av. 26 l+1pt?pnn?+8vflla A. . 201.1 ssociation of Notaries ?EiJc.21-0U-Y<wy :vii , c,i-i . a,utsche Bank Nationat Triis* Company Vs "Jiliiail"i S. I1d03er At Ly- Aian M'`viinata All P 'CNI` LO'', (-)F I D Sl'h- l i' lI 4PDFN POVvN, iM,I COU?7iPFNN`Si4'-,VIA. '['LARL) 130l'` bEl) AND - ? ?OItv1' r?_, 'i'HI `IDE OF i_Alff POST LAiNil. f0j),T- is 'yl?.17 Frt i i?? 1l C%ll'R' 1aCT,10' d'RU) -,TjF I;IHE: 31 C'ORNE'R CARRIAGE vr` AR-,' LA'lli `)ST LANE IDU'C iJ BET)!'FEN LINA] ? _R MENTl N ?.?CE BY I-AN11' P I;I '- `,j )RTJ 1 - , ; `?LS'L IU(J ')ING LLNE iI t" Ii"BJC"n I3. DlYtDING L_'NF ^.'012, il 0 DE_;RLE - 11'Ni L4 LA T 1 !Q.21 FEET To A "'I T ON THE 'WEST!'RL SIDE 0' Ga,' 0GITINLT hiFti; Ti LNi'ii F- ?0 C7I1 P .G„ i 1D0.2Y BFTF, ?T) i?. BLOCK D O} 1Fil ' N: i'HENUE BY SAII DiVTD;N6 I OI I'Il 7Ii DE?,REliS T7 ?Ln E, k' i N I563(i FEET 10A POINT rN1N E: ?TEPLi'SIDE,O1 ULM!) POST 1 h. TI+£ '11CF OF BEGINNING. Ata J;' LOT .?i1. 30. PLOC'I" r. i) Nr N PiNFI3RC)OIi 1GFIICHPI IS R[ OR1)F' IN THI CUMLR, AND OU 1 iiDER S 0H ICE AN 30Ci 1 A\ i DWEJ i'E-iVP; ` NDt I Iij _t J .4L t Cltii I;-i x O ( ONDITIONS, RESTI iC?90rv5 1SEWINTS ',-ND R1, , C 0RL). LING (?;NO' ane ;'ROPER T Y ,!] %?GLL 1$AN PY .CD "R(),) 1? ILA l.i l S MOSER AND O''.eiDRS;d' YOH L._ rCumRS Of E,,ZATE 01; G AT D I U 7I3. '`JEL il?IlTrIJ99 kFCORDED nrr ? DEED Book y'3-PALL d;; COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Morgan Stanley ABS Capital I Inc, Trust 2007-NC2, Tr is the grantee the same having been sold to said grantee on the 6th day of October A.D., 2010, under and by virtue of a writ Execution issued on the 1 st,day of June, A.D., 2010, out of the Court of Common Pleas of said County as of Civil Term, 10 Number 2239, at the suit of Morgan Stanley ABS Capital 1 Inc, Trust 2007- NCS, Tr against William S Moser is duly recorded as Instrument Number 201032590. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this I _day of A.D. ) 10 zs, Rec r&dDeeds,0nbWWCMM pA- Re order of Deeds my wrnnis w Expimft Fat maway ai im 2N4