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Home My WebLink About10-2859t SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 DANIELLE BOYLE-EBERSOLE, ESQUIRE, ATTORNEY I.D. NO. 81747 ,,9TCHAEL CLARK, ESQ., ATTORNEY I.D. NO. 202929 r-Jr '}'r?Y LESLIE RASE, ESQ., ATTORNEY I.D. NO. 58365 3600 HORIZON DRIVE, SUITE 150 ZO« AP" i 29 N1???: j0 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-036823 CUMBERLAND COUNTY U.S. Bank, N.A. as Trustee for the registered ; COURT OF COMMON PLEAS holders of Structured Asset Securities CIVIL DIVISION Corporation Mortgage Pass-Through Certificates, Series 2007-TCI PLAINTIFF VS Sharon K. Landis 1809 Letchworth Drive Camp Hill, PA 17011 DEFENDANT NO: h -a359 C L; i y &V.' l le'rwt COMPLAINT - CIVIL ACTION MORTGAGE FORECLOSURE NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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. G-3> 4qa. oo Po A"H wo 345916 p ,+ aq i3a7 Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES, USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN 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 DEFIENDE, LA CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO O NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ES PEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO O SUS PROPIEDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. 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 Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 DANIELLE BOYLE-EBERSOLE, ESQUIRE, ATTORNEY I.D. NO. 81747 MICHAEL CLARK, ESQ., ATTORNEY I.D. NO. 202929 LESLIE RASE, ESQ., ATTORNEY I.D. NO. 58365 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-036823 U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC1 PLAINTIFF VS. Sharon K. Landis 1809 Letchworth Drive Camp Hill, PA 17011 DEFENDANT COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC1, the address of which is, 1661 Worthington Road; Suite 100, P.O. Box 24737, West Palm Beach, Florida 33415, brings this action of mortgage foreclosure upon the following cause of action: 1. (a) Parties to Mortgage: Mortgagee: Ameriquest Mortgage Company Mortga or(s): Sharon K. Landis (b) Date of Mortgage: November 17, 1999 (c) Place and Date of Record of Mortgage: Recorder of Deeds Cumberland County Mortgage Book 1583, Page 729 Date: November 23, 1999 The Mortgage is a matter of public record and is incorporated herein as provided by Pa. R.C.P. No. 1019(g). A true and correct copy of the Mortgage is attached hereto and marked as Exhibit "A" and incorporated herein by reference. (d) Assignments: Assignor: Ameriquest Mortgage Company Assignee: U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007- TC1 Date of Assignment: January 19, 2010 Recording Date: January 28, 2010 Instrument No.: 201002450 2. Plaintiff is, therefore, either the original Mortgagee named in the Mortgage, the legal successor in interest to the original Mortgagee, or is the present holder of the mortgage by virtue of the above-described Assignment(s). 3. The real property which is subject to the Mortgage is generally known as 1809 Letchworth Drive, Camp Hill, Pa 17011 and is more specifically described as attached as part of Exhibit "A": 4. The name and mailing address of the Defendant is: Sharon K. Landis, 1809 Letchworth Drive, Camp Hill, PA 17011 5. The interest of each individual Defendant is as Mortgagor, Real Owner, or both. 6. The Mortgage is in default because the monthly installments of principal and interest and other charges stated below, all as authorized by the Mortgage, are due as of August 1, 2009 and have not been paid, and upon failure to make such payments when due, the whole of the principal, together with charges specifically itemized below are immediately due and payable. 7. The following amounts are due as of April 16, 2010: Principal Balance Due Interest Currently Due and Owing at 5.856% From July 1, 2009 to April 16, 2010 Late Charges Escrow Advances Appraisal Fees Property Inspection Title Search Cost Attorney Fees & Costs of Foreclosure TOTAL $35,063.82 $1,632.70 $166.53 $1,611.59 $111.00 $21.00 $250.00 $1,753.19 $40,609.83 8. Interest accrues at a per diem rate of $5.63 each day after April 16, 2010, that the debt remains unpaid, and Plaintiff may incur additional attorneys' fees, as well as other expenses, costs and charges collectible under the Note and Mortgage. 9. The attorneys' fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriffs sale. If the Mortgage is reinstated prior to the sale, reasonable attorneys' fees will be charged based on work actually performed. 10. Notice pursuant to the Homeowners' Emergency Mortgage Assistance Act of 1983, 35 P.S. § 1680.402c, et seg., was sent to each individual Mortgagor at their mailing address and/or the mortgaged property address by first-class mail and certified mail. Pursuant to the act of December 21, 1998 (P.L. 1248, No. 160) (Act 160), this Notice contains the information required by the act of March 14, 1978 (P.L. 11, No. 6), 41 P.S. Section 403 et seq., and separate Notice of Intention to Foreclose is not required. Copies of the Notice are attached hereto as Exhibit "B". WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in rem in favor of Plaintiff and against Defendant, in the amount set forth in paragraphs 7 and 8, together with interest, attorneys' fees and for other expenses, costs, and charges collectible under the Note and Mortgage and for the foreclosure and sale of the mortgaged premises. SHAPIRO & DeNARDO. 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Landis 1809 Letchworth Drive Camp Hill, PA 17011 7009 2820 0004 2451 3124 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortme 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 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, von 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 NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUSS AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO 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. shl 4 b) 14 It 6 1 ' HOMEOWNER'S NAME(S): Sharon K. Landis PROPERTY ADDRESS: 1809 Letchworth Drive, Camp Hill, PA 17011 LOAN ACCT. NO.: 30497911 ORIGINAL LENDER: Ameriquest Mortgage Company CURRENT LENDER/SERVICER: Ocwen Loan Servicing, LLC LAW FIRM FILE NO.: 09-036823 HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISION OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOU 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 THE NEXT THIRTY-THREE (33) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES- If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific infonnation 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 have 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 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 bankruptc , ou can still app) for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT Brin it u to date). NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located at: 1809 Letchworth Drive, 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: August 1, 2009 to January 1, 2010 @ $390.26 = $2,341.56 Other charges (explain/itemize): Late Charges: August 16, 2009 to December 16, 2009 @ _ $12.81 $64.05 Inspection Fees: _ $21.00 Appraisal Fees = $111.00 TOTAL AMOUNT PAST DUE: _ $2,537.61 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,537.61, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check certified check or money order made payable and sent to: Ocwen Loan Servicing, LLC Cashiering Department 12650 Ingenuity Drive Orlando, FL 32826 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the. reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period you will not be required to pay attorney's fees. OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale You may do so by paying the total amount then past due plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the 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 3 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: C/O 'The Law Firm of Shapiro & DeNardo, LLC Address: 3600 Horizon Drive, Suite 150, Kin of Prussia, PA 19406 Phone number: (610)278-6800 Fax number: (610)278-9980 Contact person: Christopher A. DeNardo, Esquire 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 X may or _ may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE PROCEEDING OR ANY OTHER MORTGAGE DOCUMENTS, OF A DEFAULT IN ANY FORECLOSURE LAWSUIT INSTITUTED UNDER THE • 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 (Fill in a list of all Counseling Agencies listed in Appendix C, FOR THE COUNTY in which the property is located, using additional pages if necessary). 1 i HEMAP Consumer Credit Counseling Agencies CUMBERLAND County Report last updated: 11/27/2009 2:21:07 PM CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 888.51 1.2227 Community Action Commission of Captial Region 1514 Derry 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 l , • VERIFICATION Michael Clark hereby states that he is the Attorney for the Plaintiff in this action, that he is authorized to make this Verification, and that the statements made in the forgoing Complaint in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalities of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. SHAPIRO & DENARDO, BY: Michael Clark, squire Dated: 0101'al 10 Attorney for Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff :o'~t}'Gi' oti Lanr~f#'f,~il~ ~~~ Jody S Smith Chief Deputy Edward L Schorpp Solicitor 20l~ MAY ! 2 AM ~ 47 ~~~~~ ~ t US Bank NA vs. Sharon K. Landis Case Number 2010-2859 SHERIFF'S RETURN OF SERVICE 05/07/2010 08:45 PM -Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on May 7, 2010 at 2040 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Sharon K. Landis, by making known unto herself personally, at 1809 Letchworth Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. ~~ TIM B C ,DEPUTY 05/10/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Occupant of 1809 Letchworth Drive, Camp Hill, PA 17011, but was unable to locate them in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Occupant. The only resident of 1809 Letchworth Drive, Camp Hill, PA 17011 is Sharon K. Landis. SHERIFF COST: $62.50 May 10, 2010 SO ANSWERS, ~~'~'."" RON R ANDERSON, SHERIFF CCtnrySU;te Shr:rif. Te~esoft, InC. SHAPIRO & DeNARDO, LLC BY: LESLIE J. RASE, ESQUIRE ATTORNEY I.D. NO: PA Bar # 58365 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO.09-036823 U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC 1 PLAINTIFF VS. Sharon K. Landis DEFENDANT ~y t._f.~ ~lfr ~~;`t ~: COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 10-2859 MOTION OF PLAINTIFF, U.S. BANK, N.A. AS TRUSTEE FOR THE REGISTERED HOLDERS OF STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-TC1 FOR SUMMARY JUDGMENT Plaintiff, U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TCl (hereinafter referred to as "Plaintiff'), by and through its attorneys, Shapiro & DeNardo, LLC, pursuant to Pa. R.C.P. No. 1035.1 et seg., hereby moves this Court for Summary Judgment in its favor and against Defendant Sharon K. Landis (hereinafter referred to as "Defendant"). In support of this Motion, Plaintiff avers the following: 1. On or about November 17, 1999, Defendant borrowed the principal sum of $35,500.00 from Ameriquest Mortgage Company, and as evidence thereof executed and delivered to Ameriquest Mortgage Company a promissory note in the amount of $35,500.00 on the same date (the "Promissory Note"). A true and correct copy of the Promissory Note is attached hereto, incorporated herein by reference and marked as Plaintiffs Exhibit "A". 2. In order to secure her obligations under the Promissory Note, Defendant also executed a mortgage on the same date (the "Mortgage") in the amount of $35,500.00, describing and encumbering certain real property located at 1809 Letchworth Drive, Camp Hill, PA 17011 (the "Mortgaged Premises"). The Mortgage was duly recorded in the Office of the Recorder of Deeds of Cumberland County on November 23, 1999 at Book 1583, Page 729, et seq. A true and correct copy of the Mortgage is attached hereto, incorporated herein by reference and marked as Plaintiffs Exhibit "B". 3. Ameriquest Mortgage Company subsequently assigned the Mortgage to U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC1, by written assignment, dated January 19, 2010, which assignment was duly recorded in the Office of the Recorder of Deeds in Cumberland County on January 28, 2010 at Instrument No. 201002450, (the "Assignment"). A true and correct copy of the Assignment is attached hereto, incorporated herein by reference and marked as Plaintiffs Exhibit "C". 4. Defendant subsequently defaulted under the Note and Mortgage (collectively referred to as the "Loan Documents") by failing to make the required monthly payment of principal, interest and other collectible charges under the Loan Documents, which payment was due on August 1, 2009, and all payments since then. 5. On or about April 29, 2010, Plaintiff instituted an action in mortgage foreclosure against Defendant pursuant to Pa. R.C.P. No. 1141 et seq. (the "Foreclosure Action"). Plaintiff commenced the Foreclosure Action with respect to the Mortgaged Premises, as a result of Defendant's failure to make the payments of principal and interest, together with other charges as authorized by the Loan Documents when due. A true and correct copy of the Complaint is attached hereto, incorporated herein by reference and marked as Plaintiff s Exhibit "D". 6. On or about May 19, 2010, Defendant filed an Answer and New Matter with Affirmative Defenses (the "Answer") to Plaintiffs Complaint. A true and correct copy of the Answer is attached hereto, incorporated herein by reference and marked as Plaintiffs Exhibit ..E.. 7. In the Answer, Defendant admits the following: (a) The legal description of the Mortgaged Premises; (b) Defendant is the real owners and mortgagors; (c) Defendant's mailing address; and (d) Defendant received notice of intention to foreclose. 8. Defendant's purported denials in the Answer fail to plead with the requisite factual specificity required by Pa. R.C.P. Nos. 1019(a), (b), (f), and (h) and 1029(a) and (b). 9. Defendant's Answer fails specifically to raise a genuine or triable issue as to any material fact which would preclude entry of the Summary Judgment in Plaintiff s favor. 10. Pursuant to the terms of the Loan Documents, upon Defendant's failure to make the payments, as set forth hereinabove, all of the sums due in accordance with the Loan Documents are, upon demand, immediately due and collectible. 11. On or about June 4, 2010, Plaintiff replied to Defendant's New Matter and Affirmative Defense. A true and correct copy of Plaintiffs Reply to Defendant's New Matter and Affirmative Defense is attached hereto, incorporated herein and marked as Plaintiff s Exhibit ..F.. 12. Attached hereto, incorporated herein by reference and marked as Plaintiff s Exhibit "G" is Plaintiffs Affidavit of Johnna Miller, authorized signer employed by Plaintiff in support of this Motion for Summary Judgment, and attached thereto is the current and updated loan history, which together establish that the Mortgage continues to be in default, and that as of June 8, 2010, the following amounts are due and owing to Plaintiff under the Mortgage: Principal of Mortgage Debt Due and Unpaid $35,063.82 Interest $1,910.06 Late Charges $89.67 Escrow Advances $2,162.40 Appraisal Fees $222.00 Property Inspection $42.00 Foreclosure Fees & Costs $1,753.91 Certified Mail Cost $22.16 Title Report Fee $300.00 TOTAL $41,566.02 13. The pleadings, exhibits thereto, together with Plaintiff s Affidavit of Amount Due and Loan History, clearly demonstrate that there is no genuine issue as to any material fact, and that Plaintiff is entitled to summary judgment as a matter of law. Further, disposition of the motion will not delay trial in this matter. WHEREFORE, Plaintiff, U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC 1 respectfully prays that this Honorable Court enter judgment of Mortgage Foreclosure in rem in its favor and against Defendant, Sharon K. Landis, in the amount of $41,566.02, authorizing sale of the mortgaged property, together with additional expenses and interest through the date of judgment and thereafter as provided by the Mortgage and applicable law, plus reasonable attorneys' fees actually incurred, and costs. A proposed order to such effect is filed herewith. Respectfully submitted, Dated: ~ t ! u 09-036823 SHAPIRO & DeNARDO, LLC BY: Leslie J. Rase, Esquire Attorney for Plaintiff/Movant Attorney I.D. No. 58365 U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TCl vs. Sharon K. Landis VERIFICATION Leslie J. Rase, Esquire, hereby states that she is the Attorney for the Plaintiff in this action, that she is authorized to make this Verification, and that the statements made in the foregoing Motion for Summary Judgment are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. SHAPIRO & DeNARDO, LLC DATE:1/t~to 6 BY: Les i .Rase, Esquire Attorney for Plaintiff S&D: 09-036823 ~ No. 142973945697 ADJUSTABLE RATE NOTE (LIBOR Index -Rate Caps} THlS NOTE CONTAINS PROVISIONS ALLOWING FOR CHANGES IN MY INTEREST RATE AND MY MONTHLY PAYMENT. THIS NOTE LIMITS THE AMOUNT MY INTEREST RATE CAN CHANGE AT ANY ONE TIME AND THE MAXIMUM RATE 1 MUST PAY. November 17, 1999 ORANGE CA [Date] (City] [State] 11!09 LETCHWORTH DR CAMP HILL, PA 17011 (Properly Address] t. BORROWER'S PROMISE TO PAY In return for a loan that I have recetved, I promise to pay U.S. S ~,~•~ (this amount is called'princlpal'), plus interest, to the order of the Lender. The Lender is AMERIQUEST MORTGAGE COMPANY I understand mat the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who la entitled to receive payments under this Note is called the'Note Holder.' 2. INTEREST Interest will be charged unpaid pdncipal unm the full amount of principal has heart paid. I will pay interest at a yearly rate of 10.750 This interest rate I wAl pay may change in accordance with Section 4 of this Note. The Interest rate required by this Section 2 and Section 4 of this Nota is the rate I witl pay both before and after any default desafbed In Section 7(B) of this Note. 3. PAYMENTS (A) Tirrte and Place of Paynwnts I will pay principal and interest by making payments every month. I will make my monthly payments on the first day of each month beginning on Jaauary 1 , 2000 I will make these payments every month until t have paid al of the principal and interest and any other charges described bebw that I may owe under this Note. My monthly payments will be applied W Interest before principal. If, on December 1 , 2019 / I still owe amounts under this Nole, 1 will pay those amounts in fua on that date, which is called the `Maturity Dale' I will make my payments at: 505 SOUTH MAIIV STREET, SCE. 6000 . ORANGE, CA 92868 or at a different place if required by the Note Holder. (B) Amount of My Inklal Monthly Payments Each of trry Initial monthy payments wit! be fn the amount of U.S. $ 360,41 This amount may change. (C) Monthly Payment Changes Changes in my monthly payment will reflect changes In the unpaid principal of my loan and in the interest rate that I must pay. The Note Holder will determine my new interest rate and the changed amount of my mouthy payment in accordance with Section 4 of this Note. 4. INTEREST RATE AND MONTHLY PAYMENT CHANGES (A) Change Dates The Interest rate i will pay may change on the first day of December 1 , 2002 ,and on that day every sixth month thereafter. Each date on which my Interest rate could change is called a'Change Date' (B) Tha Index Beginning with the first Change Date, my interest rate will tx: based on an Index. The "Index' Is the average of Interbank offered rates for six-monM U.S. dollar-denominated deposits in the London market ('LIBOR'), as published in Tire Wel! Street Journal. The most recent Index figure available as of the data 45 days before the Change Date is called the 'Curtent index " If at any point in time the Index Is no huger available, the Note Holder will choose a new index that is based upon comparable Information. The Note Holder will give me notice of this choice. (C) Catculatlon of Changoa Before each Change Date, the Note Holder wit calculate my new sl rate by addfrig Four and FJ`hty Two Hundreddu percentage point(s) ( 4.820 qe) to the rrenl Index. The Note Holder will then round the result of this additbn to the nearest one-eight of one percent (0.125°/,). ubjed to the limits slated in Section 4(D) below, this rounded amount will be my new interest rate until the next Change D te. The Note Holder will then detemrine the amount of the monthly payment that would be sufficient to repay the unpaid principal that I am expected to owe at the Change Date In full on the Matudty Dale at my new interest rate in substantially equal payments- The result of this calculation will be the new amount of my monthly payment. Inltiel~'1 lof3 70a1AD1(M t/9n Evh;b,~ ~~A' . • a No. 14297394-Sri97 (D) Limits on Interest Rata Changes The Interest rate I am required m pay at the first Change Date will not be greater than 13.750 a/. or lase than 10.750 %. Thereafter, my interest rate will never be increased or decreased on any single Change Date by more than One Percentage point(s) ( 1,000 'y.) from the rate of interest I have been paying for the preceding six months. My interest rate will never be greater than 16.750 % or less than 10,750 %. (E) Effectlw Dste of Changes My new Interest rate will become effective on each Change Date. I will pay the amount of my new monthly payment beginning on the first monthly payment date after the Change Date until the amount of my monthly payment changes again. (~ Notlu of Changes The Note Holder wiA deliver or mail to me a notice of any changes in my interest rate and the amount of my monthy payment before the efledive date of any change. The notice will indude Information required by law to be given me and also the tltle and telephone number of a person who will answer any questan I may have regarding the notce. 5. BORROWER'S RIGHT TO PREPAY I may repay this Note at any time as provided for in this paragraph. If, within true (5) years from the date of the execution of the Mortgage or Deed which secures this Note, I make a voluntary or involuntary prepayment during any consecutive twelve (1~ month period of any amount in excess of twenty percent (20%) of the original principal amount of this Nole, I agree to pay a prepayment charge equal to six (6) months advance interest on all amounts paid in excess of my sdteduled tnorrihy payments that have come due as of the date of prepayment. 8. LOAN CHARGES If a law, which applies to this ban and which sets maximum ban charges, is finally interpreted so that the interest or other loan charges collected or to be collected In connection with this loan exceed the permided limits, then: (i) any such ban charge shall be reduced by the amount necessary to reduce the charge to the permitted fimit; and (a) any sums already collected from me which exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing the principal I owe under this Note or try making a direct payment to me. If a refund reduces the principal, the reduction will be treated as a partial prepayment. 7. BORROWER'S FAILURE TO PAY AS REOUlRED (A) Late Charges for Overdue Payments If the Note Holder has not received the full amount of any monthly payment by the end of fifteen calendar days after the date It is due, I will pay a late charge to the Note Holder. The amount of the charge will be 6.000 % of my overdue payment of principal end interest I will pay this late charge promptly but only once on each late payment. (B) Default If I do not pay the full amount of each monthly payment on the data it is due, I will be in default. (C) Notice of Default If I am in default, the Note Holder may send me a written notlce telling me that if I do not pay the overdue amount by a certain date, the Note Holder may require me to pay Immediatety the full amount of principal which has not been paid and alt the Interest that I owe on that amount. The dais must be at least 30 days after the date on which the notice la delivered or mailed to me. (D) No Waiver by Note Hotder Even 'rf, at a time when I am in default, the Note Holder does not require me to pay immediately in full as described above, the Note Holder wilt still have the rght to do so if 1 am in default at a later time. (E) Payment of Note Holder's Coats and Expenses If the Note Holder has required me to pay immediately in full as described above, the Note Holder will have the right to be paid bads by ma for all of Hs costs and expenses in enfordng this Note fo the extent not prohibited by applcable law. Those expenses indude, for example, reasonable attorneys' tees. 8. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to me under this Note will be given by delivering It or by mailing it by first Gass mail to me at the Property Address above or at a different address H 1 give the Nole Holder a notice of my different address. Any notice that must be given to the Note Holder under this Note will be given by mailing k by first class mail to the Note Holder at the address stated in Section 3(A) above or at a different address K 1 am given notice of that different address. 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs Nis Note, each person is fully and personally obligated fo keep all of the promises made In this Note, including the promise to pay the full amount owed. Any person who Is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, induding the obligations of a guarantor, surely or endorser of this Note, is also obligated to keep all of the promises made in this Note. The Note Holder may enforce its rights under this Note against each person individually or against al! of us together. This means that any one of us may be required to pay all of the amounts owed under this Note. ~/ 10. WAIVERS. I and any other person who has obligations under this Note waive the ' hts of presentment and notice of dishonor. "PresentmenP means the right to require the Note Holder to demand payment of a unls due. 'Notice of Dishonor means the right t0 require the Note Holder to glue notice to other persons that amounts due have not been paid. ~,(~ trassl..~k~-u4 maaAw tns..rivrr Zof 3 • -Borrower 11- UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations in some jurisdictions. In addltbn, to the protections given fo the Note Holder under this Note, A Mortgage, Deed of Trust or Security Deed (the 'Security InstrumenC), dated the same as this Note, protects the Nole Holder from possible losses which might result H I do not keep the promises that I make in this Note. That the Security Instrument describes how and under what conditions I may be required to make immediate payment In full of alt amounts I owe under this Note. Some of those oondil'ans are described as folbws: Transfer of the Property or a Beneficial Interest in Borrower. If all or any part of the Properly or any Interest in it is add or Vansterced (or if a beneficial interest in Borrower is sold or transferred and Borrower Is not a natural person) without the Lenders prior written consent, Lender may, at its option, require immediate payment in fuM of aN sums secured by this Security Instrument. However, this optbn shall not lie exercised by Lender 'rf exercise is prohibited by federal law as of the date of this Security Instrument. Lender also shall not exercise this opton if: (a) Borrower causes to be sutxnitted W lender infortnatlon required by Lender to evaluate the Intended transferee as if a new loan were being made to the trensferee; and (b) Lender reasonable determines that Lender's security will not be impaired by the loan assumption and that the risk of a breach of any covenant or agreement in this Security Instrument is acceptable to Lender. To the extent permitted by applicable law, lender may charge a reasonable fee as a condition of Lender's consent to the loan assumption. Lender may also require the transferee to sign an assumption agreement that is acceptable to lender and that obligates the transferee to keep all the promises and agreements made in the Note and in this Security lnsWmenL Borcower will continue to be obligated under the Note and this Security Instrument unless Lender releases Borrower in writing. If Lender exercises the option to require immediate payment in full, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is delivered or mailed within which the Bortowet must pay all sums secured by this Security Instrument. if eorcower fails to pay these sums prior to the expiration of this period, Lender may invoke eny remedies permitted by this Security Instrument without further notice or demand on Borrower. 12. GOVERNING LAW PROVISION This Note and the related Security Interest are governed by the ARematlve Mortgage Trensactlon Parity Act of 1982, 12 USC §3802 et. seq., and, to the extent not inconsistent therewith, Federal and Slate law applicable to the jurisdk:tbn of the Property. Oral agreements, promises or commitments to lend money, extend credit, or forbear from enforcing repayment of a debt, including promises to extend, modify, renew or waive such debt, are not enforceable. This written agroement contains all the farms the Borcower(s) and the Lender have agreed to. Any subsequent agreement between us regarding this Note or the instrument which secures this Nota, must be In a signed writing to be legally enforceable. WITNESS THE HANG(S) AND SEAL(S) OF THE UNDERSIGNED. ~, ~lll G/j[ .~G/J~~~~~i~~>/ (Seal) SHARON K CANOES -Borrower . No. 14297394-5697 (Seal) -Borrower -Borower r 3 of 3 mo-~na t~..a~ssr 17 , 1999 . 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Ibda tx TaRa sad keamroee. ~ to apptiabla la. a b a rrdMtlr vpaitsr M Loader, Bsnaeeer aWl pay to Leaidei on me day ~Yp as'edteedtr tie Tiore, aRW rao Wot. 8 ryfs br Adl. o tsm:C'~litadr'1 dad to 7'~T. keua wdaramann rrAicl mR~+iaatn -+s ~~ Soaulq lsawment a slim atr ,1'nsxar<y; N) 7pA7leteeiold 1 a a~ :er,a m tia ~oRrrd'. if ~': {c- r'a+a! ia»rd or pttfya y itaataace td11~7 haoe psefitwts. it efr: tN ye»iy hsbwtu pacisftr, it oaf: aai t0 rt! roe. paYaile M b: LRftder. is a .rim rite w ~ t ~ la Gas of tf>t pgrrr of aortvsa is.4aana line wera rm called 'Basaaar Yeats:' Leader ary. rx ray :rate. cdke[ rd bold }'twdt b Rn ~t gait ro atataed tYa tttafetam a trader rar a dsdatily related rttottatac ban tglgr togaire ter iblroasr't taetoee eootrr coder fire foaad dlSeed Eire Sredeaar Ptaaed+ta Asa of 1974 as aateedod ffarn Ofna to ~S. 12 U.S.C. Sactlop 26p! n ~, t'BESTA'1. ~ aaerier law Nat b Ofe irfdt sett a knee atmrm. U ao, Leads easy, st oaf tdvq edfrs aM itoN Paadt iu >ts ahtawta sot b aaoatal tie laser amowtt. LgaNe n<r aa3aute the fotmtt of P+oAr dw oe am easir o(twrer Asst sad nsro~Wa ertitettp awE tspmditalet d mfpre m~uorf' ifeatt or tditetwiee ip aoeaaSaaa evit6 applktbte lar, 71ea PbMt Ma{1 is tats is'm troiilrtba ..lost deposits arts iastaed fry a fie~eni gamey, dptplYq, or adltT I eddet. if t~eadsr it rash a dopiattloc) ar in tttY Federal NotAt lase 8rt~ tba0 tpgy ;dfa [hale b peat toe F.aerow Ism. 1.ao0er ass}` cat dotes liarroraa for sad K1V1ryL ~ iSfYds atta[ytlaa ~ eeaprr aecamf, a tplfyisa the Eacro+. boric, odor-I.atdat pgRHate~sr 4M~~fta M 4e hW ad b+pdu tasdr b uslpe weA a cSvsa- ffawava, f.eader mte! fa9eim 1lnrorrer q pq a aao~tddte rinse dsr ee ~ real eettY rate rcpottita aeerlce and Ay Leader ie ooaaocrioa > rile detee, awkp appYrabie law Pe"~ Utarwe as atr~ea Y anaat a appiinbfe lanr :sryuiset iatateN to bt psis, (.cadet tY~' pot is te~Wred b pq 6bA~l rx areiaeat as tie fhads. Bomerw! and Leodcr mq alter Ip rurlfioa, ioretst dot ieatiatt ttr116s Nsid m ffie t.aidar #rd fFv+e ro Borrower, w[tiaat cetet>ta, aR .read +movt{os of tie Faade. drotksa etaalaf sad adis w tits ~rr4e iRd We pagtoau mr rrdriA aacl deidl b tie l5rade m made. Thafiwda are piedaed r teddltlasal 1 maw aafas tdosred Mf t1;e saaary hsOrsmeat. tt ut PRadt held br f.tsd~e trmeed me.wtsa paemNltfd es it idd y ap~IrnYaN ~1rav, loader teidl tfeosart b Btamrees th. aaonr r~ m acoerdanee .dN dr ~w otappiloeifa hoer. K ma of Ns Ford. Ydt Alta Ltatdtr ar,in~r lima b mr ttaldo,rat to prR the 8uaoar beau rMw drs, tatdK am9 suaalty Borrtawerdp *'~R. +ltm L aaeieea 8prrloner >e4dt Ph' b tmaw Wo atwt~pt pxcm+~ to tree ap Ate drlfdotrer. Battuw+r rtitH m}lta ep tltr dctrietts it m more tAss twet.e aAnmb fta: at laudcr't Batt dhuerka. i Ups paytrer'lo (4dl,of art carat staved Uar ftdr Seanit). tatrnwmr, Lauder rljaY petaKeptlr ra6td m Aasrswsr guy fiatda Odd lr facdea. [f. cedar paeapRpb 2f, tsRatr dpitiaapdnr txaeal tha Prapaty, Corder, ptNw to tlw aagltit)tAod ar ask of de reodwq. siad! rppiY rinY Ftutd: Vera by tatda at utctitat ad atgnb(tie ar ata~d a caalk apdme Nt rams aaeateA by NieSeetu~ity Yrmetma. 3. AppBeaOao of Uolasr rgpGcabk latr ptwldn otiet+eite. aq paymeetr tmeivad by G~Oer artder paraaraphr i std 2 be.pptiees; class, to mp prtpeymmt edtataea,dr; order the tiaeG aacoed. n~~ wareosata prryabk cords paefateplt 2; ridld. b lorereu due:; fasrN, to pt4aeipd tltf~ Y! IeM. b atgr Ism eisrYe dse tteder O~e'f~°" ~. i~far'aefi Ideal, Botraras scut{ 1+a7` rq tea. attmmema. t9autta. Ma and lropaai0o~ attribmsi-e w the f'rapary vriiRdt airy eeain prirxity over rile Sa'+a7rJ Ierft~a. sad ladeYwa ptt}7ftdtir or reels, a aRy. Eorrorrer,ialf pay tl+tse uMipt6mer to tae etaacrx provided b ! L or f[ fnf paid is rise teattu. tb anal! pal Nam op tint d6erty to fife paaoa otted peypkat. ibrrower aMdl pltaa*fly 6rredai b I.rttier nfl patiae ofaieeieah 1o be pad wider rids prate. Et 8earcw~er aftMt+ ibrae payp~ts ddrtafy. Bouower tdetst praaepdy dadaLe b l,trfder nxzipa seidfsfdrs dtpsyareau. Beftvxet>ialt pmmprty dinduvpe arty tiep aedtidr t~pfiorfty over rile SepRtAy leae}rtarmt asters Eottor~a: tN aY~ is vrritia6 M Ate paytpem of tits oidierrioe aeeatrd Up tie ilea to a serener aoceptrife b (b) rnaYaY it ~ WOt tbt Nra iY, or defards riadwt eofaemtest of tlm lint ir, loyal proaxdigs eniide lreaO~~~a APiaiae .parrs to prersstt tie atfaraantetfr d the tietq or tc} states from Nebttida of ate Oef au saredpnt fo Lander ta6oedier3aR the fiat to this sorority ~l~asrrtevpvw.r. tt Lenatr dttmtdnes ar attar paR of tie P,opury Is aelJau to .ilea wear +rsr olds prbrity .ear ills $OC4<drr 1RglYA1Gr. LaAdCr aeay aTVC lbaOMK R se0ea Wm1ti~Mia Ne lira. ~ rtrirty Ne lfeo or fil0 Opt M rtroro of tla aeaooa ace tsar chart witlit t0 aayt of ate afvteg of Rardoe. -aN?Al a~~nnr wuap.. +~- hw l.rs Lignr No. tlZ9Tt9a,x647 rw.~atud lJSO aa,lli5~3n~ X30 3, 14tauird ar lYslpstT leurewees. Botsrve!st shstl ~ We ieepmYSa Prcgaty lomted g+i.u krt ~ E6r, 3ssards Saciaded vhlSe rir trsas "errmi eoods er ttAatHo~, forwNei Laude[ Sasursaee. This henratce tmsU b ttiu'[teder requires, 7Ae at:ier pra-i0iq/d~r p,gKSeoe ddtea ee atikh shit na hs ~e+tao•bty withhtki. IF idat~r l~s to orwela ewa ahtafn oares~e a ptosect Lradex'r rlp4s to &b PespafY b reaosdwaoe A9utmtauoe policies and rfaleirrr stew haserrtephisar L+[tilflet rdrr thse Kara cio cyAt w hsMt Wr prtleles aid neswait. ]tl.imidet pquher. 9ossu' r.ia ptamims rm raeewsi aeries. Grre an.t d lots. >' •rD d'~ pc leadermrr mdcc peoatnt toe urstarfe purprfy er Bwnwt~. Unlaas Lrnder atd Bottover omerxLc,Vea >e . iruaeoe proQea r ~+txd. tt derssaesiloa «1. em.e,airatlT tJrni6Maed toad repaa it ea om.oaWay lketiilo « Larder's aaselt~ weak ce hxseaed. the rtured hY thb Saeiriry insltatesst, +rCteeur 4t' ttac rim dpq ~ ar~r esioa Pruperq, ar does not sarv ritbia 3Q devs s netiee 6osa t:eoder that Ste iehi l.atrfar my couea the hreaeoe proceeds. Lradar rry wt tie ptoareariQ sec+ued M ~ ~eeds7 Lstir+oeat. ^hdhs a autiplp drr..1L 304s! perlol tlaletr 1sa0ar ad 9ottorws oeirssrAe sppas it tnr&iep, t!sS s~tlglb paittpsee tie d+e ade et rle mrYr prttapk rKRd to lq P l a twder pstajtsph Zi Ow tempestr b rngeiad b tartkr, Honort~e's sirht to ar, thattro w ttr ikapestY P~ q dta eiMl R ist Levier seder auger itppgala~dy prior to drarigalrW.,. t Oaa.pecT, ta...+.ris+. adalteeaaee rei [ntoafa st Ou Lsaerieids. tTatearrr /lee ~plr etuilirr. arl.wedte Piopertr a- Hnroua e+t4i~ipa d rAk SmKilr laaeemneer, aid WYI exrtfYte noonspy tie P,eylpty ~ rer site rbe dole a[ oa4rproq: ttrsos~cad,r clewbe +Ooer !e wridss, rA c- rrdne otimndap drq~MS~tew eaiM rrhit~ env bereed N«eor.er'e ooettol dts PtepesrT. avow dra Property to deeRiaeasC. w ooeomie worn M drt t§pjsesi adios of Pmt. wiedror atoll or etltnbei. k hem dat ie laider's decd Propaty a odraYisetertr9~r 1m(sdt tie ties anmat ty due secedq bWw dee taeeh s defat4 red tl~sNrdl6, a! ptorldad hr /uar[sp~ 1!, hY catniK Ar`~ ttite, ie l.eader'r flood bh6 dssetlNardae, peacitdes tixfeleao of tie Bona itrpdrmest at tit tlas erwad bf ~ f"iSS~esslC w Ltttttee'a swats eb[{O7r{e, duttrq the lac ePP Pmesn. !~+ w~aiYtf refa~ ~ intoaeee m ptw{de l.adn veldt aq. enpat4d i~,tlewle aeanrnW vah rag Iwa h eo, eepteteaearloas i tl,tmwee's aoc al e6s?lapeety>r a psLtd krnsppW. Botapirtr shtll moiply;rgiall tie peitvidgeMoFtlie Wet..i[Di haedrrid rd rYs ttis Ntltahtesrr e~p+etlus Laidtrapw M drtmeeyar foot 1.14etss~e ottasd~ eta h tlell~rrgi. lC9onnea /rb m pe+ chic tY leerameet, er time b e lead P ~ n+Y f t peaoaodlit{ it hatkrupLL7r. ptdrte. far coeroearsrlleo ae forfrLun or w rr[aro pp far .vhsreev 4 ewp0urf >' Protect flat sable of re Praeger ma tinder iualode perylnd gay goers waved Al' a Itea rdtiri >~ ptiarit> are thla Sr erireem~lilr arnare7r' revs ssd oorahsp oe the tatap,rtr a ~ ~ Alcor 7, reOder doer oor isrebdo ra. Aty imo~t dL6t~oied er Lradsr trader dtb ps:apaph ~ raw baoom sacuriryi tm1. ibbM 8atmrr.c ad Loads gate b othau tame of eye are of r dte Hole rrla ,oa rtise be P•rabie. aidu i4 w dt: Rift Yr~rtrar.lf LeaW nagrlnedmrrrirpe'mausrae a<awpdi Borrosra rtrd Pei u#t Pr±eutnwtt mooted adoppae imiweeioa eur~ertMe ttapieal b>• Lsadeat Metes or recce ro he ie erect ahotie a saeuretiaetr egtssdair ro qte ranttrue lseeauoe peeMomy, ti cat m Susvrrat ire aareppa iastrrasm prerlostr hs eery fioae tatlte eabrmihd#y ageirakat fawtree ooraaec L got aveilebM. Battaare7 ataatretlli of tAe x~b e+rawrtcs i lrigf piid iY 8otratre tie im ti7ea l.eodtr tr3U aaorpe, weed raaM thin pa~moets a be tcretwl to mshrsia the y]Y{ ~~~JI~tt6E a iu mrr eeiutits M eacatla etrr~ed oo tlet i cevrrsje` aad eta othtt htiartY, laah~as srieWeta +A ehr raernups rast &er the periods n by Hottvwxr t Oo Ltsaee'a apposal ie darerihaQ bore, l.asdirt mtpf, tt iemdet`s to putenaA 7. f isreir4e ~ atredrd ties. Lender r tit! pnespdy /lee o 7sraer all eecdptiot rPs eotloe a dee Mwraeae crests aad Leerle. ,6rt he appiisd tr mseatlo. a tgpstr ~ re „eariry a eor laretd. Ii the teetaaderea ae>ttoc ptoree0t sYstt be appifad a ~ res tdd a 6ssrq~rsr. it Beuower ahartdou the r1eeCatelrr hr.ot>kred b,sgea a rLira rice ae tataee fia:Ploratt or to pq swert ~Ie iep{s>~ ~ reitiw L ehirt. of P a t> eisY esit area tx 2 cr ricers 4a atesatr of the rnrsseM >t i-!he PtrpettX ar o~brt msrtW reee~s thrY s1sD its it delolt K rrt msatgste. creep iawretwe b oe • crerrw ecquitrr 4ea tNk w We hop'titY. me ~- lrtet6ew»srerer teds~srsestrtt eastMieed'u lfoq Leodrr's d~Ys iu the ProptiRt pnch a a tsars or rgglsfieei): rise l,a3er ry m stsd r ripta irtis Peapst~: tmdss"s a4iaoederl' arigr (ewlrmst. ePP~K ix saiati. t+vl*s ~ leader arf' Lks eaeite uaArr dde le~~WFr addigoari dyer. d 8oem.ot arcvaid e7 ad. erd. mde raurr rue berrirnrer tiara tie r erUee fsmsleader a Btmatsr tegseMie~ for of thelosa aetmed by tits seaairy er Wisrt.eoe is veer t!. !ac arq tsrsor, the Houower tali p41 the pnsslttm. ete4dtae to F vibe. x :case aEeparLpt ngalvakat us me Brier inetst ~°d by leader. Ir iwtl eel m Lender ~ trerAr a rrrsegeul w eMtr tlee iweteetaetat{s ltpsed ar satesd to is Ikq of Meseseca. tars taare LoaatVe. it~44Sd9'l tupo Pot tttay m ~ k tagaited, ~ tLe opbtr of 1eMer, It i trot Leatlix rtqu+ml pee+idad bT ~ tewv ~ppt~d M Isnoe Ate p teTsk*d b nrbttln irrxe~e inrarsirnr~:eftao, t tpwrrspoeaadr in acraaaeoe ails gay ~rJtten igaaaen 9et.reea !. tor~edka Deader to ha tit arty sookr nosonsbie p Aatmtalr aatieq at (tie ripe aCa prior b sa itrprgioa epadfyly pn Wa amaze gad tar the pwiod a~aMa and k ohWarA. Bt+tau+ter tWl pay taaeNe, wW.1Le Goe aaanyi~a ter or AppliaLle taw, fettioda of tLe Ptapesty, !<oier diatt ltve lit C.eadmariea 'i6e pcaoeeds ot.ey .r«a a dim 9r dltUot~ea. drgti er eoaucgendia[, in cneaeala+ w~ my opedmmaaam a o~6cr tatiaA of goy Pert d:ffie Pioprny. a for is Ikq of awa4amaNota one (rere0r/ Moped"wd :Merl ttepe~l a fsaaia. IOIMe Caralt A'f n total t~--OL tttt~ ~P~'• ~ V~ tAel)AC-~pPlkl{ 1D IIMnY ~tldlfOd br dl~t StldR>t~ ~[YO~Ot. rdtet6ar ar gal t1reA ~ with atq etatas pdd b 8extvuer: !i the nitM d a ~ t+~ OZ 8~e Pionarlr h wNddt tM.fiir aaadaa vatoa of rLa lheipettir 4sawAalely teefcre tLe talits~ k ~ as a pa.er tl~r rtn apoenc ar~e,mr secmai to dus sieetxitr Idotrmeear LaWar tlta ealaK, tudaa Dwrower.A Xbder ~odp~Ne spar M waltlsh, fYe sit r~aoe~at 6y tMit searx~ Ltavaaent ahact is txtatoea b) the nartta of age A ~arrs foitowiq itaetiat: W lMs taxi agora of tMe rat aaatrod hddte ata wrier, dSv13d 6r A) eia yak ware of tLe Pto4rtty imge~Aidy Lsfne b Vitae. AeT halanee abo9 Le paid a 60sltlrllal~ Lt ale ereR Of A tWtial taiiot ~ ~ PtoP'wV' b w6kL ~ ftdt m.cka..ire of mn pta4atT ImmedLray twfetc Jae trtl~t Se kAA tMr tMa asncrdt a1 dte aama aaaatsd Maardfnetz ba(etc the taAiur, aeiea 8aaorv and Leafrr otMatwit¢ y/!e Mra «tndwa rpPlicatiic'fpgr aAntwire ptttvidea, dp tttoeeada dull ie tilBt'd b the ttptt anattod by 1)tit sacmitl ~16ee ar pot dteaoar trA fim der. If dtc t'rgfnt7 V afiaodooed 67 Hotaetaer, ar if, aAnsadtiet Dy Under a atatgte CaiadCltnlar OfiWA m eotWe>R aswed ar.aNk a claim bT d+myiu. 13onpwrr 6d1a b tetpaad to tender witbbt ~f dam ikr the diAe Air rootke it i~aa. l+ada k tfdlerined to coiiau and apply else ptveeadt. r hs opmra, eA6er a Ar igrc of the Pmpaptr a ttt 4tA sxtn aeerreti iry ~ . v a m tlrn titre: tMiess LatNcs and Borrower atl+avfao a6nrt 4t ~• aa~ rppiiraiat of Btoor1ed' a procip+i aMLL Aot oskod at ptagreHt sLe doeetate d the tnnnrhq paypeme teferrrd re i PAM t tad2 «etya~e rbe amotnit er.adt psi: u, seewtaar loot Rdaaadh 1'w'b..troe p! trdtrtiat . WMaae: Hsr.eiaei of ate thoe far prymcat at ainAS~oidoti dA1a0f(ieAlJaA a[ tllt than feratttd L9' ~ SeeAe[t1 i0otttrttael partaiM My Latlefae a~y atroeearear is Lteteat at Bonanwr a1gB not ePetar is ralee.e ®e uatibih of tha ~ lterre~rar aie BwYrrwrar'a awareps Iq ieterea. LaMer MqU sol 6e a eai.eaACe peomedlep seairat aa' aoocHSas !R uNaee oa +afrw ae rtctaat tine for oroataxaac wpdiiY aanttlfatioa at ata gran aer~pd Ly this Seweiry teonaateAt M raapr< of aaY dsdttatd rosdoort~Mttl Benowar a 8attoree's arooetaara is iaearatt. Auf faheatanex try t;mdar if aerdciq s~ ar testedf' {hdl oot tie t wah'at t~ a yadtirk Ae eaweio6af taffy ~ ar tmaedy [ 12.5ba'atror+ and AsdAaa 9.nadc laiet asd $e+ad I.inMBefi t:a~A' The tewdnaat rod ApeaAr79ts of ado Seeat~tyleAerrea~ dtdl brad and taW'it >!r watgera-ard rttQpr of Inndea aM~Mttower. sabJaat a the paar4iti~ of pataprep- 17. Bortotn2'a oa~n++rs ,ad yraeaatU rh.ti be Jett rAtt oeveesd. lataawetG Mp ~ tWa 4atrtity Iwnnsant ist doer nac erteeane tha Nou: (q ~ eo-tdhatat the. sooteitl6rararaeel m ttwtt+aF. prx ad ~a•af 8orroauet'a ierarat m dr Pmyeetq wida~ the aenas of tt>fa saraalgr iet?rnlMtmC iMd is tot penopaBp ekilpeM a pay the gran awted bf msa Sevcige famsanoot; twd'«? aa+~'~ l.cada aa4 tq atMx 1~arrewer !ray ayee a e7ttmd. tuodFfp, fahesr or mdte anf aarsvscodsdae~+ a+Bh aed+t'd m Jan team of tl,ia Sacarity tenUrlaipet a the . wghpat Jut eotrotaer's catnsa,. l,3. Lon L'!av U the logo ttetaued t7 t4b Seowity iasuuaAent b m • whftA stsu ®arttwrus taw tom. and this taw as findty kaeapeeted ao thatlLe ttttetat ar grey Im tdarrr ~ b bo oottaQed in ooweCflom rrMh 104 bar twoeod tie pexmingl iMdt; thm: fa7 gay aaclr iaa emrna ahif be ta0roeri My ate rtrtooax aaomry m tadiree the t3atTc a diE petniaad liaale: gad (b) ~a9 sttASt aiecady oelteeroA hero BMSYwei wMkh peta>ittetl Uaaitr wiR be rNmoeat to Boamwnr. i.eoder gtsp dente ra nsdie tttb termd ~I tadoebt de i>t owed +pder We time or Ly arlirg'a dkea Paytamt m HorrMr¢e. u a nefand seduces priarigal, tha rodnaioa arW Le tteatiee `ns a p~ tit + >+7 PaWyt~t Mate ~ toe Noe, f id. I+ttdiaas. M'saicA w 8onuatec pto.iaet au ~ ttt4 scatty Tnatnaera atwB be earn hr ~+i~!s u a M *~~s k by fitat cLa mti0 ttNw appiicahk Iaw t me of utarher tsattifn6.'!rie etuke rdtill tie d'noolad a t~*1`taPe+t7' Adtitept or gay ether addeeas Bortmver deniyux+ LY eatia m isadv. Anlr +wtfae to `ahaB tie giren My Net elm cwt a Lenda'A raldrwa atafRd Leseia or aAY oJtu addrep Lmdes• drsEdeOtd bf twtice LntG1~. Aay autiee Piv7Wed for ie tbls Seatr&y ftwtttetat t~q be dwtted to have Mein Jda~ m Borrower or Lender whm p p Ptevieleet is 1Mis para~tapM. IS. Coraaipi! l:rwt Scvaadtilk~. 'fltit saatity irwtmamt aiwi be l~+tt~~ L!' federtl taw gal the law of ate jetrisdiceba iA ar>3cA the PraPariy is fasted: La tLa ercos rLat a+9 provirtott or dove aE this 9oapaty lttattaotrttt ar J,e Mate aaMicts wift applieaCle faw.. saeh wtJliec aludl rol atGrx atfwr ptwfsioas of atb Sewtit~ LtArvmwt a the Nde vldw tar tie gWea.. effou .rYhout ttw aoa0ta(ng peovkian. Ta ttAs ad. we pia,etsuma to ra3s Seeurityi tonnaeent and tke't+ote are doe:Ltrd a be maable. i& 8enosra`s Coplr. ]3artovetshill Les Bit age waformrd mpyot the bate tuvl of Jw Security irr~rt. ~j -NtgNtt nra<aci ss~rAw.vnl na.sra Later iio'1a291394dA9?~M MO . , e?o>115831w~ 732 lraa thn.~ eaya trace iMe dtfte the ratke i< ielnaaad x: ttaalid w~idtb liremw treat VaYIB atarr raeatrd ~ dds Seer te.wmea[. N SewYa~ h8r a ppy~rr there rearsprtar b the ~~ ~» lR~. l,eeder>01ge hehelor sry tesardYa pamWsd by th0 5awdt} tttatruetem sefltioat frnher rotiez or detaerd oa ~efmMff. 1R. Beerawla fo RdrYale_ IF [tortawxr taeers strip eaad~iees. Saemaa ,halt Leese the *Wt m hne a&+rtsmwl of thL Sedulcy hnapmmt diwwttfswd x cap tSeae ptSa ap ihekartlh;r /C (a13 ~ (or mah ~ paled as aPR~ us' ~' 4~h' pr tNarutetoeeat) helots arts m >be Ptopeny t~ W elf P~ o[ etas ooenFeed >a thin Seeetiq loatrderat: a (b} vary of a J~em ~~ tbir ~Y gtrmrePt~ eopditioea aee tart Sptto+rea (a) prya i.eldee s0 trts wiidt rhea wvdtl ~. dtts nda tfir Sswrkq Imttamat and Nave r K m aaadt9atloa W gs>wtmd: (-) wtu ray drGttlt et airy other aeraluu er amam~ k1 prpr all ~'+ h edaeY~'1W SromlylLaltamttat. iatudLK. htr m 1ppYM ia` seeaoatAtk ttmtpeTt' kea: red (d? tdxx area ankw n Ea rder tttap rera•a}I7 M aartm ntte t6r tier of tlis 9eaatMlr IlttNtaMd' Laa4er'a L the Peepeaq aed tdenpaa'r oMiwioh a tlts,writ »aank by eWe 3aaxiq~ int:aeast a4a9 otrYoa areM~M. Upaa bs tleroa~w~er. t61e tnlettaas~tt arts Ihs ailipttopa !'eared hgsehy ~Mef1 ttmaitrfhBf effegiw r i! no aoodeztdoa hd tlowrsty, this rf+t a ntdatuer tdrtl me~ it the ere d a/oeiaatfatt ttttdge ptttnprpit I7. 7f: sew K Wrea1 Cf,arMa at 1.r. Airslerr. Tits Naa « a yauai h the Nets trliahv trhY tW Stkotkf isetrtremtl serf Ir raid osr a atrer tftasa rritbost prfrr at>tlaa b Sonora. A MaM rrl itwdt h a e1~ b the wttf~ferrr to the"'Lon Servioer7 t4r tollratr I~ drr trader qtr ttoee and Ihi Sa~LL~ leatndKrt 'iLaro etas stet/ he wr a area rt fhe iarl Serriav ttoedrted a r aah of mr Nairn S bens n 4 af~e i.ar ~eetlgr Hoaowa r~ bts aiYntt wrillm endetet t6a cbaese b armilor ~tllh ptee~eaph ti dtwe and >~ hA. 71r artieo tv91 err Ns name d atldteas of Ars:wr Lor 4errkv red dte addspts Mt ~ritir3 prfinear saaaW ma4e: 71ea tsatla still aMo aorttia alp rota isiotmrlasreglllsst 6y apptitabtc hw. 24 NrsMr~ ~e4tprer, 8aao~er aLaq ret case or peneit ehe PnvFace use. aNport, none„ er re4sse s! aq Hsrrdarr At6ertren oa ar L the iloipatr. Sastssres ahMl lot da, rrr draw arpattr cite r d0. agytMttB ~t the .POOprlty drat Y m tidrei0r o< rY EaritarmCl~i iaw. ~ peteetdas t1w raeleaaer aha9 let a~ Y ~- palaMrOr. tote, at arnttye oa thr PsoornY of mG gtrmWr dNamadeer ~mesea it aee,~oetaly raeoydsed at>te fhraipd,ee re camel midmWt acs sd r ~mahearrwrd us Moper<y. Borrow sdd ptattepdy (ire Leach trrhae0ltOdoe d aAp iasad ~I. tft,tlltrd, bweit a YORt ttttim ar tsesta~y +p~arf a Ddws issrt~ the Pro~,tr reA ilaraduwr su6wtnc4 ae 45rv1 w ett n9tiih tiatrow~r W aroW Wri{eeiss. V Bons+rer karpt, er a mtFlYda~M~~jr pvemmaarl ar tsa~WaMrY wBorKJ. that mf remoras or other t~or of cif ila>:rdena sltbataero a the r tteeeraef, 8orwsrer aYaO peoept•,p ttaor all alcawr rveedid adios i. reootdslae trilh Perhomeaed Ilse, Ar e.ee iA ddr pvraraph 20. 'titiaerdoue 9ehrtratzr" rm thoM detdla! ~s rorie arhwoloes rr6mrort~bbr~ Pavixo~orsuJ Ir.. r.a tae fdia~-6s ryb~taooec tip. 1rpYeras. rdwr err taotie ~ehaieeea l~utlep~ tesk peskieider .a+ inbkidst, vdrWe ad.+eru, Irrl~irFa srhetta n lru~~ raetlspire rrari Meuea Ir t3is eaaetaah 20. •~+Lunaotoal tav* mesa tedaal isw~s a~9 tws of dte Where Ms t4afaef- 4 bated t3ae ti'alaae r arise or earLereeaed e.seento._ iT. 'I~sorta of ibe opac~ oca 6etdldd lttterma is ISOetstrer.lt ~ n trp prt of me t'mpaty rr sq itttaeat is h Id or trat>fa~ (ar it~a 6ara5chC lat~,c is Baemwee 4,oW ar 1 ~ +a4 Darraver it aw : pauwt pe+am} wt~Ewue a'tt t~ waiper oaa.mat, Leador trey. >r Its- aptian, tagpive bomn~paynanx la ttti< a< aB trma lenued hY' tbb iaru~attew. {loerera, miropFiarahatt on Leeaetahal6Y Lmaer if is pio4~Nai try tedcnl lw a ot~e 4ue ttptior. Le~dershdt~ive ~oRto(v« nMio6 et,ocelra+tlar. T6a moat mall prori~ s pea{od at cot K cop erv~ R area applioefir Lw perrtt{Vt aM4 re~oied is new eb. ettitilidtf lwidtir.andrrtaet~ d thr e !4!eMsee~, reader ahrY Ihril tatrdentre'rreredhtR !Aa s tYedt(aui[ Y eeet earrd M 4 lids iDanrk7 irtrmt~l wit Ludo' hr r1tWd M tneisetbar, 6tK ao1 ElaJeri b, t70Cff)ed ek4ml0~a0~d li m BCStowsL Stltaa;ASC dfW htatcammt, but twb Ff lbe cat tear red c Paf tlf msawoll t+oaa. imaer mf moat Les is EWd to a tltM patty for advioa tsadeaed the 10 Ihr et.kpt pCtm+ped h9t appliaWs Iatr, waWse Ie1 ttatl, sod bceshp wetlrer the heeetsdpy ptstealtx rim ipae+trmmea, hap tad race. rod Lottttrotd eae~oQdao. ad. Boaow'a timem rdoraee troriAed b eatdaiaam~hh to the 1'itspary, Wie':StcetkY Ima 1~•dINPM..w.ia.m tlseeaa...vme nwsss acociy83tu~ to ttmq K We fre k pettatpW tinder r mf atrx err detrtaa h proocsd'eyit laws ptorit8ej far etaf of ett~setaial. t-etl eaetad m oae httor ptbr to the ot. m b bat to Baerowter to aegelxe tide 1t1~9ii~669Yrrr~~ frogs ]07e LYO za. W sat late Altar iad~at. nwew.a vra. aut ire aMae~e..k p.~.ik fir, y a t. aa.mm ~maetpp foredewuo a6otN ~ ~ caws 1 ' aaeaea on mo rsene Pay+~ flam eLua a urns w~fix we Nixe. 1!. Afa.. a leis 8aertieT yrlnssW Il ar or mole ddr>d «e aoneMNd i ~seeaosgt, Aa aavnua:nt a~aaernrs of eacb wcA d4r id1 be iKpp ~~ Mµ.io.a~l. attlis ~aau4y brnrroeac at Cdr ridat(s).~aie apc ®A~abte ea~c xwa {apj ~° ~ Pl~i vet Uaslopeeec Rtea ve s~ ~* waer BY 9[GNQf(3 BBLON, Bonowa aoaps wad w ~e ums tied Dora °~ apy sfdR{s) aaweed 6! 8aao+~ asd ietv+dee whk $. Wifoe~ ? tyAU l.G87 cs -~...a c~.an~,rRwaeva. ~ ~~ -• , do tha srtlkin-nseae~d ~Ptue b k10 iD1YN x ~UNTaY RD., S'1'E.1fld ORANiiE. Cat 4746! ~"~"'~ WNaeaaaoytraWlWa i"~- gayof ~ . yam.. COAllti0NW8ALT$ OF PSNNSYLYAI7LA„ C1A~! ontria, ~ tom''' aayaf A.hxr.+t~sw I9~ c+*+aadty a~e,ma x. Petsoa aflrose naa~t I S tan+ro subrai6ad a ~e wh6io isWOaOra! and ac-~ rLe same Rtt tra peupaaes haels ennbineA. iM Wk77i13SS wFtr3ate0P, I baiamuo set ~ 9aad wad otficiat My C.7MaV~AlfGewi~C RliEie . W Earar~a.aNwt T+Yd ~~11PAhwm-0i .ruelw tun .ns.a LoYlil 60{nf$~fACf ;~~ ~aa~d eda seomniy lnuaa-aat. i-~ r arses sr ~ ~aaeoea la trh Staeity avt and r csdu {stirs ~~ -s«~...~ ~r~h dat des ecnwee aed~w oe A~Nte!-fee~pjer 6aare roa.~tta '~F ;~,~, ~~~ r ry ~ ~ 3:.. aaEoraddi~~~~_ :p~~ died t6rc ~a' ~ = . d j"'nn v,. .[k97S9itiif4f Farts ~o3a a/ao 7a: /lwee[qurst Caap tlill tl StlSYtlt haa: Da1lYr I:aaieet uY"°°"~°' CQMNlITMENT FOR TiTl.~ SCMEOULE .>< GONTINUEt) Legal D•eClSptioa it/!8/~! lI No. A7L4319ets1 1I+[. l7UT C[RS3.I[7 lot of! Qi.ow.4l gmwtd xitb tlsR buildi¢gR atd ,1.npp7lOVwwiaetLl CtMtspR •rrat•a, wiewco Sn tho TexhRlsip o[. Lever Julia, Cantr,o! naiMrlRpa asd_04t• e! VumRylaala., being ks`oraa~..Let 110. 2w, iloRlc •C, ea~lwn tb_ S o! D•valoiw.nt,..aud• bY' D.?. n.llwaw fiSghlaadtiocatos a, i9SO, aid rooorAwd Sa Plea loof~~NF• Rylrentd Jlut~a7or, L~oxa•, fa., ltd May asa 200. sash 1o31y QaaRarib~d aat~o23exov A1'OllalIItO at a pelat as T3R ewltbw..t.Kly eida o! Lwt ~ stla Csixo, Salty [S01 lent xid•, ac'C[1w dliatwaaw K tfw. WaNtKed i!]cty-tw~Ra aid rey'nip~ yfeAtMQUN 1]il.7f) !•wt arrouroQ.p~cgr~aswwr4ly wad Motxwsaly •laas ~ ~oakkwa-t1Y #m~0 #aYCb~ely oldo of [.wcoJarosth 77ri.w tsaR4 cA. wt.~m-rfoRt L/r=Adrwo .b! R eadksl sW11G e~oss0r ooop•etitlQ Llta senehorly bA+ eL tncohwetJi ihivoMlth dhw wt+rly bldb of lfia~ta•otb street,. •Ssey tool ta•t x14.1 7fF7~[1# in a abrtb•rtRZly dls9cclott slaaq. cW Muthaa•t•sly aidw os t.•C~1ierth ay.• m tA• asa s! a eli~ol.en s Xiereurviag tw flea 1.lc lr.ina a c.eliw oP `Are hwdr•q Hlt.aa [91a1 !eat, Itb• are di•t•ee•• et litty (sal Leaf to a palaz; TZa01Q •st•adiap M a# o.sswr as• •r.S• riRas 7,•rw >Daodrwd aid JF.1.lty tTlgbc bmgdsadtbo t7ow:3~1 tRwt •cp a DoiacJ I'hwwuw'a~ctwabiag• aoarhNrdlT a~aR sandrd. •is Rae forty-thiv-~mdraipba (lec.411 !o•t ~. fR poJ,wt~ smrkswack•n31ng ri 77 aagne•• os•oi_a` tWe fro lwads.d..tYirty-tiw te4niaetZi-foar Mmatrachs. iai7s:ss1 -tRbt to the Aoutbaut•rlp aide oC Lttafrmteh Dritio, the lirsG aratianad ti~~ and P1aw o! 71gaZg177lp. ^RIIq Lot Ste, A6, Block `C•', Pla4 1b, 5 ot%1yhtYW'atai••. gJl7rLq Tl~CM isl<CTN a oaw •ndpaw-Aol! •wry siasl• 41rf11[rq 11n01gt •• ia09 lAtdellOrbL Dr1Vw, dl~ 11111, PII. Stan d PeaoryM~ ` $B CounNwf Caw~LMMfd~ a as-otNa#r«ntalnoasaodoada c ~niira+r t V 7111: car#L~at Ss taw7ld Re7MR tIN taua'tW P~-ifa~s !d TeMdiaf~s A rk ~ ra atLd.M [lr•t LwRrioaa 7!Stl• InRaratt0• Lba*•Qy 7W ADNSTABLE RATE 1 a.u+o+e~ri.a~G,~,~, rluc AAjI75TA8L8 BA?E ttror~t ~. ~ m~ me at, ar ~~ ~ ~ trra ;d. aad ~.a ~ tieetmt i wme . •~ .D°°°(!fr`'9e`"`~''le'°"nkae'1ofaYessw,tl,,.~tYe, ~jr•~te ale,~oee ~ma.,~., m A fie'i.aada'j,Ntee.naee.er,rra,...:.,..._~, uy ternwro~~ CA>drNlFd.~PA 17Ait [HareyAaaeiep: tN77A~T ltA~ '~ PA ,~ ~ TA~18 AND 11~ MA>~[!A1 RA7t ~~ >tAA11s CAN CNAN ~+~xusr rA+ ADm1'T7QNAL G81~EAIAd+tX'& La aadlioo to Bte oovtuavtr a~ un Borrower, ,od tinder Rers.eoe.,,s,rl Vmr K foperrt ~- BST RS'f8 AND MOIYt'8GY PAYri1$Mp '1>,e Nole ptovTaa !a an timid imaat rre d is.7l0 ;. uurreK cue aed c6e tnoaepir W7m~ts. ae follows; 91e N t ' RAIL AND M~1'ttt.Y tAYMgNP CAAWGiB G-1 Oyes. Dttaa '~ Fotereac ate I will PaY ~f dwnl~e aft ma rintJt7 d M ewe auu4 maoet etmaalhr. Pad dnee a..Ata1 ~;s~nnc rare ao.rd wr Te. rant ~taaio~ ,vtr>, me Ivor t~aepc )~. ~ lpy~ rn ,~ tie area a eo Ldt: o! iwabsNc o8letea cams ror .Gc-+.o.a u.s Aortr~,d.,w~p,~ ~ a. t "ai 77u wur[.Areer.truwat. ira teest mneee tedec arrittlla w a Datc b+Wlad fife •Ctttretielea,• I! Bea Oedrt is to loagt a*aHable.'4itr Pore ItoGler +slll tha~we a ssnr raskx t ialorne~an. "(]w Nato iblda wi[I Etrr rrc aotlee of fhb rioioe. fC1 CaktBatiac od CLw~et '~ ~d+aitrlr fie` ate Mare Ho{der wiQ ealrolax sy ow:w ieksef[ fate Yy ILe f?ancnl lnfieri. Tka Nate ttordrt aefH tlYr rdxatt the entftasditrosb I P paaa (a.i25x1- a t4c CttNta coat 4 Sxyrwa 1(Dj aaoww. dtfee new lyderezt rase nWil the eact Ci~sase patc 7be Natc FiWdtrr vi71 tbm daetmiae the aupnr d Bte ~ u+tpaid priueiyar clot t atq expxtea m oae a the ~ M ~ '~Y °4"d Pa7~t, Thr ryph o! d~ csiwla8o4 wPl tie Wt a l~~S83nraE .7~ uuusresrstutsatora.tuoru+nett ,,,,., ~. teen ~ it>77.i!{,~ ja e>vtr 1NGEB $? ~[ x ra~na met ~ Az ANY Wars e~ ~ ;e t6t: 7 pnR'tdes lbr ~e8d ~ y1e aoaa aw au ma< wlea'er~uaoe• 'flee 'iaarc• b Bss coarse art aiutas ('LtBQir7, p e Are: 45 daya bslua aaeh }t tysad ~ '~~ FotR aatl 8tdty +-~ xj to e'~'~ O0o'.doee enrdM ea10eM mitt tie aey card h,q ant~tt p nNf bate at o~ eew iar "' texaoat d my asatAiY tnl I3,oMa ea iatererr hate C~ta 71fe ~te+ert rau t xn requited m W7 ~ the tort ~ oue.rn aot }te g~aeestbsn 23.7SQ !G or tes Chas I0.7sa t. '1lereaFler, mr haacn f+teirriU aeKr he htaeuad or AterWted a- aer ~~ ~ Dre br mere dm ors ~ p P~KsI ~ t.eoa x) from drC rr+e d htuasc i haban P~-~ C~ dte ptaordhq aix mwdtr. laurea rata rill) oera be sra-er daa i~.'~SQ '.i a ~a igwf !Q TlA %. (p Pa-ieek~PrspWatC7ueeda My ttarhttaaa trte viU heroatir eEfsalw m girth Chrode Daa. i i~- pY fheaa~Amt et mr aea mcethtr wo+~ Md~s on doe sra rneioirty paymdK date atlet dte CO+ope;Dw uatit tha sntoomt of mr Y RYt~ at+~ p4 Nsiiee d 4Latger 'ILir Noes Holder ail! dear a troll ro ma • aotim at aaT ~~ al tor~at t5ae iwd Ms oagant d moahir pgmteot 6etars tha elfediMe dax d sar ~6R 't7te tpriu Ieedode Lttottortigat M a« ro he Rl.n m rrd atea drc Ntie aad tekphoae aWtha at a peaaaa I add ,m.er r'sr gaenion t » a. ~or~~t~asrcl~sroRas'tcw.u~'~Crn+ ueidomt Carsea.c dT ordrc sernrnr u aaaMea to and K 'ltinaAr d me Ieepuer x . Beeena.F layattw m Mepnar. tf +it air ~r wec d aee ' ar ss hxetat is it Load or rmafdted (or iFr 6mefkbl httaesc m Hortowsr tl aold a GaruaiYSed sod 9eerom srQ it na . aanrat Pe.a.J.;~ar i,eoder'a p~.nr'n coe+e.c. LcaAer my, r ~• mgsna avmeae is Minot au rne. seaaieA sr t-;esmekr henasiest. fia~aR IW ' Wq.or -e e7rmcatd 6r [,eedei it e:aes is pto4ilbed ar Raawf hnr r oEmeaaead+Ai. saak(sr teraav ref e1Y.n oa sreaeisa tiir opdau ik ta) eettow~u ada w he aefiatJUOA a ivdx ir~tatrttara i? r~ to ewQtrae dar ttrRerided tr~.aerea ac K a.n. {o..,wae &Le md. ra ai. a.ustaa~ ,.a (pl , ' re~rre+r aaa~d+e. art l.eadera aeaak rrtN .oe ee ~'b7! dK less k* *r dut ita title rt hneitlb of aarerrertiet or teach Chia Srrmety irinttmmt ss eo isadet. ~ TO dts eirirpd ! ~1 aPPi~~ hw, Lealdt +Wr ~ 1.:. Eae r a eoadtNan ~ [.eodds amaerl ro dae bas earraeptfoa. tadrr nrr a4s tagdrs dr awl°bge~s° ~°°P~a ~sarC tit h >. w iaader d tlW oliidaen dr oneNreMet ~o finep sl the see a~ra~mraw. wade hs dre-tiers aad is ~Oir $g7a/it7 htsremant. Bn[rwMt[ trig eOedOOe b Us RidC pse Note uud fhk SOCWip' Eeaut~smt Wiwi Spode[ rderea AallOe'4ia.+~fet. tf Isdrr exaefre the a regv&S ImoodiaY p~ S~t.etnler tdtdi jlM 9orm~r aoti~a o[ aaodane»a. 7be: sake b+~1 psaride a petbd d earksa dta 30 dept dte dais tha satfoe V delherod ac ntdMd wMiia Mle1e0 Hotrarre; wort tMr aR rrW samred Lr rites LaarnMert. n BetroaRr 8iti b par these WIOi P~ a dice mtpiradw d EtAhhi @artnd. laldea• ayq' ~~~ taoa0iat Petaimere h?' ~a r loktrbtnWtwi~aes tncthermtkeardecaadoneartowa; BY SlotiilK3 SFS (3W. BoRawer eoapts +md af~ m >De tcas aorrWtls cmuFard inshh Apia R\ageR~ider. ""' SB+lR01'fKI.AND64 •eanwnr i -noao.v ..~ - AaiOUIilDttflt7t RQ1RR-1,190Q IIfAmi. - M1at pX9atiWNO~ tW .9orwe~.4r t~~Q""? ~xa~v-sae loer~5~-~ =~ . a~ ~ ~ Prepared By: Ocwen Loan Servicing, LLC Retum To: Shapiro & DeNardo, LLC 3600 Hozizon Drive, Suite 150 King of Prussia, PA 19406 610-278-6800 ext. 225 THE ABOVE SPACE FOR RECORDING USE ONLY NI~MIIIWIIII 673049791119 Attorney Code: 0037fi ASSIGNMENT OF MORTGAGE PENNSYLVANIA This ASSIGNMENT OF MORTGAGE is made and entered into as of this 29TH day of JUNE, 2007, from AMERIQUEST MORTGAGE COMPANY, whose address is Go Ocwen Loan Servicing, LLC. 1661 Worthington Road, Suife 100, West Palm Beach, FL 33409 (°Assignor°} to U.S. BANK, N.A. AS TRUSTEE FOR THE REGISTERED HOLDERS OF STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2007-TC1 whose address is c% Ocwen Loan Servicing, LLC. 1661 Worthington Road, Suie 100, West Paim Beach, FL 33409 ("Assignee"}, for and in consideration of the sum of Ten Dollars {$10.00) and other good and valuable consideration, the receipt of which is acknowledged. AMERIQUEST MORTGAGE COMPANY does hereby assign all of its right, title and interest, as holder of, in, and to the following described mortgage, the property described and the indebtedness secured by the mortgage to the above referenced Assignee. Mortgagor: SHARON K. LANDIS Mortgagee: AMERIQUEST MORTGAGE COMPANY Dated: NOVEMBER 17, 1999 Amount: $35,500.00 Recorded: NOVEMBER 23,1999 County: CUMBERLAND Book: 1583 Page: 729 Property Address: 1809 LETCHWORTH DRIVE, CAMP WILL, PA Tax ID #: 13-23-0547-230 LEGAL DESCRIPTION MORE FULLY DESCRIBED 1N EXHlBfT "A", ATTACHED HEAETO AND . INCORPORATED INTO THIS ASSIGNMENT. Together with the note or obligation described in the Mortgage endorsed to the Assignee, ("Note") and all moneys due and to become due on the Note and Mortgage, with interest. Assignee its successor, legal representation and assigns shall hold all rights under the Note and Mortgage forever, subject however, to the right and equity of redemption, if any, of the maker(s) of the mortgage, their heirs and assigns forever. Assignor, by its appropriate corporate officers, has executed and sealed with its corporate seal this Assignment of Mortgage on this 19TH day of JANUARY, 2010. ATTEST: Name: Juan A. Pardo Title: Manager of Account Management STATE OF FLORIDA ) )SS COUNTY OF PALM BEACH ) AMERIQUEST MORTGAGE COMPANY By Its Attorney-In-Fact and Servicer in Fact OCWEN FEDERAL BANK FSB BY Its Successor In Interest OCWEN LOAN SERVICIPlG~C. Name: Scott Anderson Title: Executive Vice President of Residential Loan Servicing POA recorded on: NOVEMBER 01, 2000 Book: 658 Page: 1122 BE IT REMEMBERED, that on this 19TH day of JANUARY, 2010, before me, the subscriber, a Notary Public personally appeared Scott Anderson, Executive Vice President of Residential Loan Servicing and Juan A. Pardo, Manager of Account Management at Ocwen Loan Servicing, LLC, OCWEN LOAN SERVICING, LLC SUCCESSOR IN INTEREST TO OCWEN FEDERAL BANK, FSB ATTORNEY-IN-FACT AND SERVICER IN FACT FOR AMERIOUEST MORTGAGE COMPANY who 1 am satisfied are the persons who signed the within instrument and they acknowledged that they signed, sealed with the corporate seal and delivered the same as such officers aforesaid, and that the within instrument is the voluntary act and deed of such corporation made by virtue of a Resolution of its Board of Directors. NOTARY pLBLIC-STATE OF FLORIDA ,,.,~.••. Carla xinoco Ga~m3~sioa #' DD912557 ~„~ ~~ er~i~+.~~ B~tmYn~a co ~>Na. HPNn~'~liA I hereby d~rtify~l~e address of the Assignee is: sue. otary Public NAME: c/o Ocwen Loan Servicing, LLC 1661 Worthington Road, Suite 100 West Palm Beach, FL 33409 Phone Number: 561-682-8835 When recorded return to: $~'taplTrO & ~@NatdO, LLC yy 3600 Horizon Drive, Suite 'f 50 King of Prussia, PA 19406 Prepared by: Laura Buxton Ocwen Loan Servicing, LLC 1661 Worthington Road, Sui#e 100 West Palm Beach, FL 33409 Phone Number: 561-682-8835 ALLONGE BORROWERS: SHARON K. LANDIS PRESENTOWNER AND HOLDER: AMERIQUEST MORTGAGE COMPANY NOTE EXECUTION DATE : NOVEMBER 17, f 999 NOTE AMOUNT: $35,500.00 This allonge shall be annexed to the original Note (or to a copy of the Note with a Lost Note Affidavit if the original cannot be located), referenced above for purposes of transferring same from the present Owner and Holder of the Note, AMERIQUEST MORTGAGE COMPANY ("Transferor°) as of the date set forth below. As a result of said transfer, AMERIQUEST MORTGAGE COMPANY has no #urther interest in the Note. Date: JANUARY 19, 2010 Pay to the order of U.S. BANK, N.A. AS TRUSTEE FOR THE REGISTERED HOLDERS OF STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-TCi, without recourse, representation or warranty express or implied this 19TH day of JANUARY, 2014. AMERIQUEST MORTGAGE COMPANY By its Attorney-In-Fact and Servicer in Fact OCWEN FEDERA ANK FSB __... BY Its Successor f nterest OCWEN LOAN SER ING, LLC. By: Name: Juan A. Pardo Title: Manager of Account Management The effective date of the allonge is JUNE 29, 2007. 673049791119 673049791119 EXFIIBIT "A" ALL THAT CERTAIN lot os piece of ground with the building^ and improvements thereon erected, situate in the Township of Lower Allen, County of Cumberland and State of Pennsylvania, being known as Lot No. 26, Biaok "C", an Plan No. 5 of Highland $statea Development, made by D.D. Raffeneperger, Registered Surveyor, Lemoyne, Da., dated laay 4, 1950, and recorded in Plan Book 4, Page 100, more fully described as follows: BSaINNII~IQ at a point on the Southeasterly side of Letchworth Drive, fifty (501 feet wide, at the distance o! two hundred ^ixty-seven and thirty-Wino hundredths (367.39) feet measured Northeastward2y and 6astwardly along the Southeasterly and Southerly Bids of Letchworth Drivs from the eastern-most terminus of a radial round corner connecting the Southerly side of Lstchworth Drive with the easterly aide of Nineteenth Street, sixty (60) feet wide; THBIQCE in a Northeasterly direction along the 8outhaasterly lido of Letchworth Drive on the arc of a circle on a 11ns curving to the left having a radius of Two hundred Fifteen (225) feet, the arc dirtsncee of fifty 150) lest to a point; THENCE extending N 89 Degrees 39' 49.5• Eaet Two Hundzed and Fifty Sight hundredths (200.59) feet to a point; Thence extending Sauthwardly one hundred six and forty-three hundredths (106.43) feet to a point; THENCE extending N 77 degrees 09'41.2 iQsst two hundred thirty-five and ninety-four hundredths (235.94) lest to the Southeasterly Bide of Letchworth Drive, the firer mentioned point and Place of BE6INNINQ. BBING Lot No. 26, Sloek •C", Plan No. 5 of Highland Eetatee. AAVII+Ta THSRECdQ ERECTED a one and one-half story Dingle dwelling known ao 1809 Letchworth Drive, Camp Hill, Pa. ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 201002450 Recorded On 1/28/2010 At 10:27:23 AM * Instrument Type -ASSIGNMENT OF MORTGAGE Invoice Number - 00012 User ID - RZ * Mortgagor - LANDIS, SHARON K * Mortgagee - U S BANK N A * Customer - SHAPIRO & DENARDO LLC * FEES STATE WRIT TAX $0.50 STATE JCS/ACCESS TO $23.50 JUSTICE RECORDING FEES - $11.50 RECORDER OF DEEDS PARCEL CERTIFICATION $10.00 FEES COUNTX ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 TOTAL PAID $50.50 I Certify this to be recorded in Cumberland County PA a ort °UM~~ ~ ° RECORDER O D DS Y~30 * Total Pages - S Certification Page DO NOT DETACH This page is now part of this legal document. * -Information denoted by an asterisk may change during the verification process and may not be reflected on this page. IIIIIIIIIII I~IIIII'III SHAP~O ~ DeNARDO, LL., BY: CHRISTOPHER A. DeNARDO, ESQUIlZE, ATTORNEY LD. NO. 78447 DANIELLE BOYLE-EBERSOLE ESQUIRE ATTORNEY LD. NO. 81747 MICHAEL CLARK, ESQ., ATTORNEY LD. NO. 202929 LESLIE RASE, ESQ., ATTORNEY LD. NO. 58365 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FII..E NO. 09-036823 U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TCl PLAINTIFF VS Sharon K. Landis 1809 Letchworth Drive Camp Hill, PA 17011 DEFENDANT COMPLAINT -CIVIL ACTION MORTGAGE FORECLOSURE NOTICE Cy ~ ,V, -~j ^.7 ~ -- Tau -~ <~ r=- ' ti.f -/ ~ L~_ ' _ i -- ` -: ~ c' c~ -., . u-. ,~, --< 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 W 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 MAYBE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY ~vh~6:~~~p~ Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES, USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN 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 DEFIENDE, LA CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO O NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ES PEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO O SUS PROPIEDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. 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 PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY LD. NO. 78447 DANIELLE BOYLE-EBERSOLE, ESQUIRE, ATTORNEY LD. NO. 81747 MICHAEL CLARK, ESQ., ATTORNEY LD. NO. 202929 LESLIE RASE, ESQ., ATTORNEY I.D. NO. 58365 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-036823 U.S. Bank, N.A. as Trustee for the registered ~ COURT OF COMMON PLEAS holders of Structured Asset Securities CNIL DIVISION Corporation Mortgage Pass-Through ~ CUMBERLAND COUNTY Certificates, Series 2007-TC1 ; PLAINTIFF ~ NO: VS. Sharon K. Landis 1809 Letchworth Drive Camp Hill, PA 17011 DEFENDANT COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC1, the address of which is, 1661 Worthington Road; Suite ] 00, P.O. Box 24737, West Palm Beach, Florida 33415, brings this action of mortgage foreclosure upon the following cause of action: 1. (a), Parties to Mort~a~e: Mortgagee: Ameriquest Mortgage Company Mortgagor(s): Sharon K. Landis (b) Date of Mort~a~e: November 17, 1999 (c) Place and Date of Record of Mort~a~e: Recorder of Deeds Cumberland County Mortgage Book 1583, Page 729 Date: November 23, 1999 The Mortgage is a matter of public record and is incorporated herein as provided by Pa. R.C.P. No. 1019(g). A true and correct copy of the Mortgage is attached hereto and marked as Exhibit "A" and incorporated herein by reference. (d) Assignments: Assignor: Ameriquest Mortgage Company Assignee: U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007- TC1 Date of Assignment: January 19, 2010 Recording Date: January 28, 2010 Instrument No.: 201002450 2. Plaintiff is, therefore, either the original Mortgagee named in the Mortgage, the legal successor in interest to the original Mortgagee, or is the present holder of the mortgage by virtue of the above-described Assignment(s). 3. The real property which is subject to the Mortgage is generally known as 1809 Letchworth Drive, Camp Hill, Pa 17011 and is more specifically described as attached as part of Exhibit "A": 4. The name and mailing address of the Defendant is: Sharon K. Landis, 1809 Letchworth Drive, Camp Hill, PA 17011 5. The interest of each individual Defendant is as Mortgagor, Real Owner, or both. 6. The Mortgage is in default because the monthly installments of principal and interest and other charges stated below, all as authorized by the Mortgage, are due as of August 1, 2009 and have not been paid, and upon failure to make such payments when due, the whole of the principal, together with charges specifically itemized below are immediately due and payable. 7. The following amounts are due as of April 16, 2010: Principal Balance Due Interest Currently Due and Owing at 5.856% From July 1, 2009 to April 16, 2010 Late Charges Escrow Advances Appraisal Fees Property Inspection Title Search Cost Attorney Fees & Costs of Foreclosure TOTAL $35,063.82 $1,632.70 $166.53 $1,611.59 $111.00 $21.00 $250.00 $1,753.19 $40,609.83 8. Interest accrues at a per diem rate of $5.63 each day after April 16, 2010, that the debt remains unpaid, and Plaintiff may incur additional attorneys' fees, as well as other expenses, costs and charges collectible under the Note and Mortgage. 9. The attorneys' fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriffs sale. If the Mortgage is reinstated prior to the sale, reasonable attorneys' fees will be charged based on work actually performed. 10. Notice pursuant to the Homeowners' Emergency Mortgage Assistance Act of 1983, 35 P.S. § 1680.402c, et seq., was sent to each individual Mortgagor at their mailing address and/or the mortgaged property address by first-class mail and certified mail. Pursuant to the act of December 21, 1998 (P.L. 1248, No. 160) (Act 160), this Notice contains the information required by the act of March 14, 1978 (P.L. 11, No. 6), 41 P.S. Section 403 et seq., and separate Notice of Intention to Foreclose is not required. Copies of the Notice are attached hereto as Exhibit "B". WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in rem in favor of Plaintiff~and against Defendant, in the amount set forth in paragraphs 7 and 8, together with interest, attorneys' fees and for other expenses, costs, and charges collectible under the Note and Mortgage and for the foreclosure and sale of the mortgaged premises. Date: ~- BY: S & D File No. 09-036823 SHAPIRO & DeNARDO, LLC 1'ml ~aµ.1.n+.r~ta1~ wom a m.u ~n: AM13RfQ[JESTMACiECOMPANY MORTGAGE P.o. eox t ISl}i 3tANTA Al'!A. CA 9Q7! 1 TH[S 14nR7'Gw[IH CSaxtlry. fastnwrat7 4 iHat as SHAILON K I.Al~1piS ('t3ermw'`)- nca Sexrriry saa[tuoaeot a ~ w ANERlQUSST MOR7GAGS t70MPANY R`~nFRT E. ~.IEGLE•R RECORJF;^, CF ~EEOS ctcBtRt1." ~ Cp1J117Y-Pa '99 NFU 23 P(9 Z 1 T Novartd' 17 , 1999 .Tk aso[tsfyor is wh'xh a oT~~ixed imA QiduL d+der be tt~vl u[ des 9poe of Ddmce add¢a is I f0010WN ~ COUN]RY RI)., SI'L'. 70D ORANfat?. G.42d6S ('1.w~ TLiny Ptvo'ILomsed Ifire Huedlod +04 aoll.~. 7bit de:OC 4 svideooed by Bona~ia's Hors dti"te4 foe nmc date M~.~, ~Ji!~7'm°ei0~`1'bllhe Anf dcha„jt+ior psidr>rtln4 dnt ad R+fi~"oa 7SM Sbcvdry Isdluueok socv[a,M l.aedar: (d die u'Qq~ of~e felt a.id ex~osbmi' and of LLq NoaC (b) the P~~ oC ~ cWc1 .1:e Rater CYe srrndty at41Y Socw81: tem.-ted (d o3e PetPamma °[ Smuiij. teW Vmcm ad d.e. Naffs. Por tl~N pacpcra &xiowc doa hae0ry aK deaeri6~d pnV~f loe~ted in C11M$FRL..'+I~fl 1~C'iA1. pffip11Pt~Qlt.ATTACH>wQ f11;It8'I'0 AItD>MADH A PAR? t aed 1Noae Born~wer a~va lmaf:r ibc P ~+ of ~Iku(U.3. S 35.300:00 ), b7 Srnaumen ('Tlala~, w~hit3 PA1~ for 1 ~Dt9 bf6e Noa. ~'k11 Vameas aaN atl gals. 'J< to~eret, afv.~osd qds[ gi,~apt 7 m wtrt rn.~aRU and seder etia ~,-paot aad aoevty /a I.e0d6r ftr tbliaerhrt ', Pn~glvioda: wAfciz lua the addlmof IE49 I11~CHWOA'~'It. DR CAMP 1i11L nemiytrwla Hutt t'LV~i CY^~"ry: row~av~uwt-sWM r~r+~ u a~'tiallar+~t r-1,.1 xu snn . ~il1~A) MMM I~ ~~ ry, l ~ • ~OSi1t1w..11a1 M +[Q? •'y'YOnMY~OAa aD1t11-1111 _ M~iHI{ Is» arl. 1 ~~~~~~ ~xh-'b~'~ ''~'' k Tnc!?'t[{EIt W(Tli a14 the 'vry><O.aarnt, aor tx 6ueaficr esafed an tie Prnp•nf. rtd z;11 earxaates, a+d CaaWV Iqw a hesrattm a Pan of. tie pteipefty. All rt~l.caaeets. xd -.ddklee..Ltia Yrao be avbrd. y taL 5~ity laftnwaatL M at dR fix'galn' fa. iehe+ed m b fhb Se~oncr f.rtr.smi . the 'FRop~cey_` HtMROWH& CQVp.NANfSthaf lforra+rer n ta.rfdlp cJaed at tlae cute ~' o0as~eycJ fa+diat tkc cijtrt totnoagaK. gran and onaveY .the 7'mpeclY. ~ ~ ~ Pt9P~y a uawcuobeaod, aw~st foc oe¢~6rsroca of rari+d. Sonower wrtraats and w!i11 ddcad {KOea117 rata tide to tiK hv¢crt7r fyhta all r4aruf na deensdr. snhjlcx to rer mamlratm c(rawfd_ TiiLS SOCURft'Y INS[RUMFN[' awrUoes mifome w.®m for tsatioorr we aad ttoe-aa(farmt~earcfc riti iimiied varinooof by Jatirfidioa b mwcitute a tv8foren tlocniR7 ImttemrAt tnrer4ar rW ptepcrij; UfdIPORM CJOVPItANTS. Butvvu xG I.a-1et coveamt trod fpa r fotlorin:,`: t. @+t7~'ot PrtndQrt aad 7nttraA; Peapgnwt +ewi Lag Clut~., aidl psaospLLr par vAa dre Aao priocipai d and tafe:eai oa ttie bebt erfdwtr d by tLe N«c >ofirtr M4Yr~++ fMdcharya doc tads the None. 2. 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Upon xYn.aat io fu11 o! ~ aeu Pawed M tLdt Seaeci<7 taaarmes, i.aadrr till pannptry reline ro Hoaeoser any Fmm told by [.mac, (f. tiaeer parapapa 21, l.eodor aln4.at.>;tdtt x ae8 t!m-Pmpaty, lrnder, ptbr to tAe negaiatlboo. or aak of tie Propcny, shall apply n19. Wtnls held ly Leat1R Y.dtGAeoeotaogtehaina rK sale As. n cteilitapiiaa We mareaecatea by lik Seesrity faarvrrknt. J. Appikatloe of Pannmtt. Uakn fppl"enNe laer ptovidea othen!iaC all payreent j naodved br I.eade mores P~tf i and 2 fdaFl be appilof: (7at, m v+r P ~ due tfader me Naar" set»>td. tb fmotMf payfME tmda puefflgtaptt 2, tblyd. b intaea dae•„Caath, to ptirctpad daoC and ifat. b aaq 1Ae dee tmda ale I~oee_ 0. C6Q4er; Clues. Balurty dWl pfr.~p tun, attasmmlr, duusa.:8oes aodir atrribouMa a tae Property whKh mar Buda ptiocity tner mke Sada7tJ [mtnancie, od teate6old payareutsoipoioe [ettlr. if r7• Borrower siudl pry these oitiar;oes la rho apnacrptn.taed b pdtgpegth :. ar Y ota wad iet6at mina, Bo fhali pry rh~.on time dhectlx to ree pawn green pgmeat: Barower t~ prmiply nttsiart m [.eneer 4t aefiora of rho b~ pald autrrr sls ptatWpti, It 8ortower atftes tine dirta),r, Bono:eer mfd. prompttY 4aaik b t.alder eectgAa erS~.trciaq tie 8ortvwa >ballpttanptly diaduge atgi liew riich haspeitutt)' ovK tlds 9mp'itY wtean Batnorer. (a) +~ ie atsfiR!{ b the psyriem of the oWiNeion sawed by We can is a ~' accaptthie to.f.tsEq: (b? maluu fageod hiAt tin lien by, a defmdf r~fiaK cafwo~ ofthe tern in,-kYalploteodL~! vhith b tbetal~kfr opiaimtlpeate to prevaat 4r eo[«crnrnt d the lim: a (e) taum. from the holds of ILa lim. a Y l1RYtrrS° .Iy :to Lnidrr wborsieeliarlie Uen to mu stausgr toruumeaf. rf tetder aNasaacr ent our wn of tht p+opeiq 9 treljeet b t tks afi+m taay uulq ptfOtlty o ddr Sacerity taaeueaeet. Ceadcf m.y ti" r. Botrowec . ootioe lautgyrir4l thcliea. 9onaw.er f~H. atrafy me ilea or lake gad to tnota o! the anloaa act foM .box wilifq t0 nays. of «r [i~8 of u0tioc. -•IH7'wln..ont.ma•s...na .:a.r+s tgarNo.';if19739(-5697 rw.wa07! 9J10 ea,~1583nu :lJO 3. Huard or Ptepety Iraanru. ltamaes th+il tarp tec ir.prorem ('tgwty Sra~cd asatnu loos hY Cue. 9aracd[ iocf~ded eritein dK tum'estea< ttoaOt or noodiin~; bwmhiclf trnder requim ~^^^•'ibL Mapances>,an b that larder rd@+ita• The iamaooe ticsiar PEwidiaL tk. ddlbe ch trhicfi ahel8not ea ema+oanc~f timtie~kl. Tf. Boraeee 4ile to sawn cave opdae, ohtffi oovua je to prot«c wars'. ttiVtu fa tie propatf it atmtEaaoe wa uucrnoe,poLda aad emewa4 aia8 ie: iooepuik a I.mdee be ~ ebril have me dsAl b bola tee, P~ toed 4eaaRalt. U isndet . 8otm~ p.id ptamta~s and ttxaRd rrtixs. h tie evfrtnt row ~ocroatr ae,n slut pr Leader muy. e>tte p.ocf of lon it set-tarirptmpdY e7 Boaaw,Y. UtdExa ender aM BOttovrr odEa~rlae'asra N rrtSmt. t~taooo ptexea Ptvpvtp damased, i(tha teseotat6oe a apdc k ecopomiad7 Gaeibk and Lead wpai[is not kratbca ar Isader's 7 world 6e ' . _ -ed, tee aacseead by ~ ~ih' • taioiier or aot rhea duo .ria ae) esod peupetc7. or dax na ~eai-erwtilhir JO dgsa aetice i<atr lbder tbtt dse ier tmda rat' eocieet the Lnaace ptcc+eeds..t'p~dee w,Y tun 3a P to .ecrosd M tYta Seosdry' ]mtaoaat: nidltr ar not teesf Orr earl ~bf l~o~ !lame !radar aEd Bonot>1a atiet+'4e +it°° fa ~4 «t7 ~l4~'tb potgaaee ths' Ow date of the maathti Arlae+w! Man'e4 it o;-panpapia t r uadtt. p'cw~faph 2t .tie. PiaQenyla aogritod hf !lades. Bonatra'a ~ b-sat darwp n: df Pbopexey atlas b see;aoe~fltlooa6rN Ow ~ I.arde[.b Bee timeai ietimdiaW y pTirsr to tlot+cpElwtlga. L OaaTaael. Pr'e~«'ratla«. 1.MLfswaa sad c'ratgoda. e! W Iwardtelda. Bortovtt aMg Ooatpf, ertablinl< led ter the RaPr:+tT as tccirotye exocrtloe of O,w See,.iq. lane,erom. ra .e.p corLut ea omiPY the PrepElty yw Bea the am o(otxrpac.7. adw Leaaec atbuwit erstar a trsidy, tvl or wiaaoim~tlnj cicamgrrr~ eai« .~iki aaa bayra0 a«eeuafe oawal the PtaPritT• agwr 1tia Rwperty m Oaceiorare. «matmk traee ab dte tmpos Mar ar pmcepdha~, wieegia elti! a etctai>iti M ~ But L c.ewaer'a booe ~apull of otltu~r6c toaai.it~ impdt the lira aural by Oda Soo«iq htatt® eas ta+ch a t>~ earl. tetoeESt~ >a petnldod 'ta /e+eWWrW Id, M' cwthEe 6e « t6iat, h l~n6er'a seod. filch daemtieaoor. ptedrda fotteLmo of de Sam. impaittaet! of tie Bea anud by'thL Sawtiry 3nttemed a trtedefs ncui Bocmtam, tie laaa ePPfYxi.°° Faeroe. Rry asraWlr fNar ar iumsa b pm.Ide Iaedvrlm aay o~eertat ie(a®aefoy.L cuaeaaYaa ~ ub.... ~ t0. ey~ueeeYfrer +'i Borrorcr'a a°~'-Y at tee ftoperty >r -1+rlad kawfiotd, tkaaowrr d+dtmvrfltY +ith all the t~>~ of doe lase. U b kaae4otd ae1 die 6rtMle eitY m mrrOc eaJar Leach ~ b tie ~+ is ?. Aolaatcaaof Lsdet'sR{shbt V tM 7r'o~q. ItBortvra tub b Pe Wis Soeausey hapremm or rapt is a keel P~'~t ~ ~f dD7 ~ ptaaedlps Ls 6atthttpte7r, pntMte; fr+r'esademoatioa or tats or to adac pay (or trhatertr fe ' io ptoYect.1M valre oS tee ~peRl' aad teach iadada }veins-roY eama aecxead il' a:llea taYkh bs. p~4 era Ah S rcnooaeke 7e' feamd t m the haply' 1o E~ rgrvs. Alt-eu 7. t.coOrt Boa ea have av do ao. Aay anaaen Qbhtrod br tsadcr uada[ thta P~Ph Y del bemm Saerky hsmvmrat. Unlep Hatawwc and Lrada µKC m tNha ttrme ac par Oae of dlatntaemea at the Nara taee and idulc6e pgs6lpwith ~~: eF payeunt. tL Mange lrrtrree. t(t.radcr >'oquitad mattp~C iaR7ae0e n ttOOd tnao-tarcat. mnower aeaq pry tie pteatitrre teuiEe4 a mdataie tee piwa m iaruaren cova,e~e xogelted br eradeX l.p.ee ar cocoa ro be is aRe obcaia wrrsrde anfYtaotia[!Y egri~abtelo the:mtYtpge fiownnoe pterirmlf, l m« m Ratower o[ the aaatpee ioartaaot Ptaiard7 ftt af6wct from 4.eet tab~aoitalE, Sq¢i+dna moa~e. faamneci_mvese(;e Y as awnabla, Banrae eoe+ta~dAli of tbe. fatf m0~°10t Pa~"m bebi O+d iq_8attanc ee is efieu. tsad« Mti aortae, raa am ~ t6ge vynvnu a e ba Eaa+e -aNB.At ,...awl o.,c, ems. u.. .... s «. +~1,*rf~cc u ma exi«ins or beteaflc esvJed oa ~ OOVera~e' aad nY tithe[ hmrda.. intlibinL ~uianfeed is the arc earl Tor the pesioda ra by Bottv+ree as t.rndeF'r spptoval e dacribcd abOCe, trader ttntf, K Leada'a b paragrupe 7. iacbtee . ataedatQ sneppse Barre. Coda .>~ txamrdr ttcee q rmdc eft nceipu of abdlee tpplced. m esteati0a t reads o! for 'a asoriry ie pot kaseeed. If drc teaoarrioaot rsnroc pto«edt ~ be rPl'~'a w the pai0 m Batowwr. It BOaawcr ab.,dou the aooe tousles hr olLered t0rettkatlahy tleo fir a tense dr.:PeaKcty or`!a py'aarr: dtl egla tie rotba i rlvnt: .tit promtt{t so ptirelpat airy ex atmd a 2 qr. tfire~e tie aeotet:eidtrMaatrta. H ioaecanea; ppBcleer .od Ptoe°pda aanMiaR flan ~f tiewrs eeetsed.ef M4 Ste>~ity Laa'reet fi. SRpeish Tare A~atelae; i ptLcipd reat6arx rririle rttgr dsr agar Eha Botmwez'a pttrr.4prl tealdeew fw u kaac me :6 asreeel rWl tie! 6t ~! w6iiidd. 6artovKr watl ttgl deaioy, drre~a a dti 1 eodd otad!'it forleihns ad tie w a t.eudn'r teaaFtt~ hrerrat. Bona~er roof xo[ pmoeerir~ta'>Se.Aheiaed wits a r'a udeaast Teter; Ptopaty a tithe aella~ bttetee; Honeeer 16att also Ee V IdetM t< ~`-~.--' -"~ or wrarnu to 1:eedar [tie. idled eenee.! M' ~ Flree. hdedYy. Weaet IYolieA ltalda+ee. [ftby Sepgf~ CsYt~b w e 'or« aO4+lro the tide m+tbe >:mpatty. ae tca Laoaa's dpts ec tttrrtnpas~ U~ r e We m tw;etirires~ tLea t.eedar mq do sa4 e tipbw the [~aepteYf. imda'teetiane m7 ItMrrmet, ,~'K 4' aar:t.. p4Lt e t.eader mry tike arlioe ta0et ebL edditioarc debt o! BtlErord aecmad h7 tiL eat, teae aactmeE aeaD bat iraew from tie a patiee fntm Loader b Borrawrr tegantips ha ad tttathts tie bu'rteaned if thL Setaai7 W ieMa>ieoe ie effort. it. for ref teeaea. the . ilor[oweY atrau pay ~ P~ ~ to etGeU;. v a ooe utiWMdrt17 agalvakgt to tea pert aEOttYasa _al4raadbr Leadrr IT ahrtt pg b [order ~ tattodi r rrc egaY to ties the ir.eraoae tamrys trprat a aasat to is tka oI sportg~c ~+~~/,~~,.~'3/cQa~n n:tarra ta~Na -tu739i349Y rsi*r bx atao payerau mty ao loaga be taquired, at the optba:of Laden. iC u'~rh+se IeltYSac6 aowrage.ritt the wooat and for rtiePeriod mu teotrrs tequira) Pemided dy sn iesirrteY fry l.eadea agset L:rnm s~ifa6k sad M otxaited. 9otaoter ~Mtl aaty ffie t t¢utad amtmtain uloeeR:{C Famatmee6tclfeta,. ato Povr}e a hcl tpnx, m+ti1 [be rege}rtauat fotttlatt~o ituuraaoe cads In aeca>bocYw"sh aay.svtitten agetmeffi'~etwteea 6araauer and rasps or sppltcahie Ltr, 9. ragkcUoa. Leads or Ets agim auy w6c teat»rpsbiet~u:n upon and . of tLe Ptopattr: t.knaer.6.iC f Boritnrrt ttetiee rt the ruse ortir prior tti m hrQed:oa.:pcd4kf~ rcaaoe.hte cwe~ppri{pq- 10. C.aadematla.. 7iae ptoorede of,ary a.ard or dim thr AMeftes. dies « cglgequeWiU, In.mmeedort wuh >by aood~oatim o' o+Eiet ulciasof noypaPt of tht any, t4:[or wreegMOt.ul'ea, of ~ are4ereby at.ij~rd-'and shrl.De toad a (.eoder_ ~ .. .hl me axat( of • tom. ukrnE of the FYOperrT. the peoaadr W W'.he.ppttoi q th~ ttuafV ieeued bit d~,Seartiry rq.v~oeey wileahat or tnt thm due, +wim say ~~aaPaU a eaarowra 4 tLe etntst uf-aPrWil ukias of rite F'tiepery ut wkfrt;l8efi1~ anher raton or tSacl7aopdiy in.~aldy ixfate.Ae talia~ is fir. to a R~ dltn the amount or the auelsaet7a+bi by. thrt 9smhy toettraaea ia~dual7 befooe itie tatda~, uoku Borrower aed Deader oW~rf.e .fie. in wrlde~„ ihs saes ~eoarad b7 ts,'s Sccatiey rarvemau ~ fx it50amt1. q Ale atoenat d ~ ptaseeeda natitlpitd by tde toilo+ia~ 6acticat_ (a) do leer ua+onat of the sttmt ntimeed laraodhtelY'hetat tln OYcip,. rri~riftd'q tai the fak.{eurkty uyue o1 the PlcxpatJ @mr6islory bofnae therakia!- Aay br~oee ahW tie pad b 8atrtarr, Mtlta etterR of A pvaid t^iimto( die ~P'a4 6 which. ttltt tsar tnrttst rrae d 76e Property tmmodiutlT bebre Ate tdLt Y ius dtudu ueoaera( t-e asaei s«acd MtmedirdT before ILe takte~, adesr edaoav sad t~der a6aviregtee ul wr~r1 a ualcas .ptaicafire htwothacwkae ptaride~, the ptvaee. aArii 6e apy15M d tfr iamts aeavredby mu 9eegri<r /aaraceeia waen.cr or to ti+eaw-.ee thps Jar. rf the Pmpct) L duodoaal M tbraower, a if, a9v noeioe by r.eada to Bottgwec ffiat:tlte ooadedaem~ nfkra a tutlx ~ award oc ,cafe ,.ct,im ~r draaArt, 8oitatet 611. b respoed eo. i.oadet a~Fn ]h dajM~alkt me~datt t}+a ooiiee it t.waec b tamed m txirect imd .pp}y tde prooonir a ka opttar rimer to tripe « seruir d me empaty err pi tbei Iowa srxed by this SeaxAJ' torttimr>rr. vheehcr err sot the due, I Utdaa Leader and. &xtowrr athcrwrse ttt~ ie writing, set! +Ppikacbn of A1O0f°d` to ptitetp.t stun ra caeead of Paapme the dacdatr! of d.e maomtr p.wmh tefcmd ere ra 1 1 tad 2 or rde smo.ttt e[ sac3t prp~ocpLt. LL Bartewar rfat 1Rs3erafi~ --orWwaaes El t.aadx rrtat a Wafrar. Hasmaioa{ d ids tone for paymem err tlldQt~tlOn dttaontllaatlta of mt Ytmt an7todlry Idit Seedy (tiwmsutt aart.d Ry ltm~ to r~y uwweaix b lafetcu al8artawiet ifia9 tnea ePe+aro to release me W6Hki a the orYlrl Bnrtouer err Bono+er'~ +awawai ~ ~..I.eada tAail not he regtiimd; a wmaauttc Paoetadiof: agate aw aac+ce~w la meaest oc ~e/ur. e. awaa 1t~ for p1yw~ a othcrxiae mod<iy aelarlli><fUoa id tlrc tsm» sued by thu Seati9ty i 6y aeaga of +M' tlamaid twdr f{'! t~ ot{~ltRl 9ortoaer a Pairwrefa eumerrara m fnmsat. hay forberaaa by Laadv i s qry tidit ec isxQr ~ tax be . wlira od err pta~ie Ue eaea9fealta7 thb-ot• raaelr. i2. St>o~s and A.dpu Batmdt .faint sad Sa.aar [Jaht~yt C~ 'The covesstn aced of dart stassity lanrummt duo aim. and batafit-thc alKetara and ardor oC ldda ,ui {i3oan.er, aanyed. m the pcovbie.. ut p.c>gaph f7. bortowaYa oolxemuus tad y+eaamn tdall be joint ~ te.rraL w lionowa nho «s.iws rids 4awtkr hwstiaea bat aces trot sienna the rise: tU is mrr~rt mi. sev.ky f.~atsa,a duly to teacsse. Ili aM aoacy t6r t3otto.ret's itaareat ra the Ptopcey undertlte rrtmr d tth Setaelte'-laea~eeax ihl.b ~. Pecror8r to P4'the amt aecmad-.by ush semdty lrmnuumt sad telag^~tMt.ader and .af etYV Bam~vvet ptT s9tt aeltteod. modify; Gsidaa ac arFi attY timovwto4a3om wuh tcd.rd a the team of dais SemritT Itaeraatmt or tM Nate ++a5oat th-t BoaaoaKr'a mrrmt_ 13, l.oaa t-motes- if the loan smued Uy twr Severity lartrtatieet u wbja:t to . ~.ww'hich wie matibmum !am dry. aM tM taw is Cixully Luertunal >b that the IMaea a ceder Mw tyurtw oolfodod od a be aodafed is oowttQtm MN1f toe bm eaeooed the tx<adtteJ limits, step: ter); tmy nick lam tmatge agtdl be reCuoa! >ri' the astgttM neoasaty tb tedaoe fitrNJtq~ rn ids paaaaed liadt; and (bt any :vein ray mllatod from Borrowv wftldi tternrtted Omia wUt be teforteed to Bartowe. Censer auy ckoort fu mice tfsb rtfaod try ~r+Y me priscipal o~ed finder the Note a by saa4itga a grist asfYnrud ro Botmwea- tf a taTted reduces prladpr, the redurtioa Hitt 4 tKaeed us a. P~ PnR~1'~ trSdtOat my a>~T~t dune nnder the Noce. tA. rktias. lluy aorta, w Barowcr ptoridrdfor ie tdh Saarky rra[nannt shdi pe Aivrn dy delivet&K i1 or by r~Uny h by first dm ttadl ~ applicdSe Inn tsquuea me of aaothcr nuthod. The tlotkr >~ be AitMid to the Ptoptzty AdMrnt tx say order adrktx[ 8ottowts desigttaw by ntaite m tinder. Asy totim to [aaderj WnU ire gf+ra 6J IItte dys tmrl to trnde{a addrrit sta6Cd irieia or ny rider addrep linden dr~ipsxr by notice a .Any saline piwided fOr ro silts Sernrrty laaattmnt aha4 be 8eettred to have bem tt>^~ to Eoiaoiver or Irnder Then gire# n pUavrded in this pe.gtpYh. 1S Gorarotetj Ca+r. Sr.vabiltty. This Saeatity faamaaek dun be Imatted q W4erd taw and the h+w of tM jur;sd'er~ioa fa which cede PTnperty u Iurstar. Lt me coca tMa ry ptovisloa or drove of mss S><arity pent ortbe Noe wxdi&ts web aDWits04e law, ~ conlV:a aloft ta+t affect othv p+arltiont of rbb Seatrit~ imefttrecal a tlce Nate .nc~h nn be gives d(+oct rithort the eaunictiag pto~la+ost. To t}uscad the ptorisiom a( tAh:Sewri4ltgatfaamcattd lire Nomaje dshttd to be txva'dsk 16. $errawe's Copy. Bartowtrfiatt be g~± me mnkrcw~d copy or the Noce and pf Hatt 5txurity irattaooeat~. ®~6rW~w1 n.<exrx o.ra,o... s+q ~~rr [are Na.ItT973P1.669?`wJ~~ iMD ~• naa~1583rict ..732 ':. !T. 7txmfrr of the 7'raprrty or a 8esrlidal >rttetw ie 1 u roW a tr}etsfusod: (aa• [t : Eent9cfst imenne iu Bocower 4 x header's pdur vtipw eaasaut: i.eedct ataY, ar Its optiw, m Y li~e+umeaL Howeror, a10 tytioa ati~11 aol tie taucbed ttra ebie ~%9 Lxrumeott ~ tioo4«te asc6~ed. UPsa! te+attafsor~ bi obliss[laassaesaed iex0y aid reels 1Whr:eflaliw u itm a~odeabalad eot apply m tLc use of itaedaatids ands patli~npll f7 19. S.ta of WeF t]r~it d l..a. S~+ileae. 71e Nova « a pat(d V tasa®eemt mar La add sae armrc ttaaes widput pd« sloekn to 9ot+o.v. A as me •ta.a Se<vicoc7 tsar aodma rr+ooeNr P•rnY.+ er r•eer t6P lfae and «a+otc dual~noCtLe rasa servion aetd,tcd b. sates[ me-IVac tl tLae K pyvn writlea naioa of the vela acwtJaaoe sim pati~ih l4 abotie sed s address. of tLe nae t.nsa 4a.icei red tLt adiieia m .bicL paymeaa rbduld I iabosaeulm roq,duai by sppiltablc hw. m. tl.andos. ~Ma~er. 6e..ewv .ti+e .al use or pv~sk ~c pas K::maoti. sbe.t.~e. na « is ae r,opaty. Baseesa shill Dot do, oor .+ pnopaty that L id iiatMioo of:acy Parace.0ud L.. Tbc paarfYS owr t10111j[ m [be -p•~-.~~,.-.~-~ of atoett of Flsraliluea~511lsuaeea d/ 4C mideaatl trac so0 sa tedstd~a at tltc lsapeQy. tSOr:ow tbdl pcoaytt7 !dam lrnder rtluir~t aria of ny msrad=stlo4 >(arermKanf a ta=ultl«7~ a~ac7 « M~ pp~~sfy ~ p~7 rM of w#ieIl lbesower has atwal kaasded~a N Baruwet kayos. « u aadf{ad bi auy remove! a< mrr ersfledtatim of say tla:arda,r 9tbsuaee sf>~ 6e Jte atlm~oqury ~adf.l sztios V ataoedaom .e.4 C'nrimuucntat I.-... ~ wed is tAL prn~n~Y 20. 'Haatdoos 9uhat~ow' rc chose ta$istsn Paadsooosraeal i,....a au [a1bWi.s .~+rramec ZrsG.e; hsareae, offiea petttidesana 6erbitid[t,.vol.ale ate*s. smrritls mWiidet s.6eass oeiui lfOff-(aMFVR.I-ODHBlIANIS. Beereitiia sad Lxder fiatOr+msv I L AaaerMloel >Rema~a Iwadtr sbp ~ woliea to Boeti+en of an7 esraonti ar ~ d die y taalron>ept (Lat noc ~>e lrw peeri(a slMrwtW, I.aad4•Id aoWyBonv.eCa(. sealolewl m eaev the senuk: k1 wlr4 sLa iehiM! sass be wtreik sail rasok Ia aaklrrefaa of Ow aeons aserad 6y tllfe ~V' P+dpMr. Crsda a1rH lYetl6Pr balLes 8ee*ower d tM: tt~tt m trial fasedemn [rneswllaK !L~ eass~detsraa a[ a deduk ar serf atfer dete the defatrY !r sat aril M l.radr, W b oplMs. m4 ~4°L' [Lis 6ane{t~ lrrrsmd wif-ast fiattber deaaed sail eery t«edau L.rader s6a~. G artfthd b as~d a$ a:p®re betas! h psui lnde~. but set limltad tw, ~efensys' Rar sail aMi d tSW tMdmcs 2L llefeaae. f1Poa paytots[ d all namsx+oaadby ~ 7' oomgad sbsli lealiaaR and 6egasas smfd. After sub oautmce. I+md to 8otoe+e>: 8atameet bail pip sey oeootdsttga tape. l~dc neq lam[, but Daly U tCe fee is prS a , 16ad periy (« uevioei taa appacsMelaw.: 7a. Wal~ae. Baeto+tct. W Ibe et1tlM pamiited Gy apptlubk Iew, t to eoiacoe tLisSaatity itxertameM. sod Lceetir_am.cr tYe_beeefu dtmY 7:4. Rriaetatatatot Hsiid. lioaouei'a t§ue b rdprue yweidod m oaasaatoaosst ot:Liddtq a a ~Aaill's sak ao16a sdc pmweat to mss Sa 25. Peir3ws rdaaey ~rie•~ !f aeY at the debt sewted M tLSa Sa b the Pmpefty, i`f'SaariEy imaarobl slut! be • pnafime a+aWy tmtsyQe ~.fHfPAI s~ia p] Ma1M w. vq rae ~~ ~~1St83tlCE aed 7i Lt e41 a~asaual~ petfaallio~R P~'x la taN of atl xaoa s~ by t8ls hette n pmhbllat by Qedetal tatr as of tLe sm rx5oa. The noclx sLldl pwfde a fKtiad e! 4ot 1 BotiONCf Ittart Qg aQ:'wn'tientnidby:dd~ ~( tLu raiod, lmdv iifkJ 4Vd10El71y tc~llai4 m. last 8aerva+a ~atl luve'IbetFjYt'.eo Lm eatlfer of: (s) 3 dgq's (ar srdi ashri pccipd as imsx at say poor of sale aotmiaed to tl~s IC T`Loae t»obitioee rR a~at Baitooer (s) psye b tlotc a it m rioddatloa Lai off: (~) lalatnad. 3a ssfotsiK dlit Ssw(1ty 6ut>rtararrai, m. ae L+rada_Taeq,sesaaMbU r!eaethea b aaraae !e tfc gets (teNtLR sell tlda Saatrlty ^1 eerdt is, a ~ tam ~y Ptiaw rsulgr htsrivmsu, T38rea6o aa~y'kaae ~e of me ia~ &rr1cQ, eoeso,Pr<.Bt be Jelstw. TLe .Date tPiu seals the eame.oe a. 71se. esaat will al.o snatain .~ stLQ a da0 as b sYa ps[asaaq rraq « r' ~ ~ b 00 ap*eopetsea m aotdul 1ta71t~ a O@fei a(d0a WJ inodoaa. Skslaaaia « 6txieaawmfY LNt a< tejat+rr7 wboelty, a,t feeoeeeey, Botrorrss tliaYptaa4ty Woe tiitid as auaSc «Laatdass aabetYOer:ly. 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' a. osrt~ teorBRTtr o¢a scxu. >xt~g»'r na tzoeaow~t th9Dorat Corsa.tc 17 of We seairuy ]rvsrmaux V rwoaded n mad r tajoan: 'IT.e.Rr d the t'at+peatp sr a Btadldat leans to EeRe+tr<. tf ,u or nay pre of tae etvpaq or .ej latemu is it L aoid or trnN4arcd (a if . beneficial tmaesr m Borrow ti satd « vatn&trea and Borrower o aoe a n~m~nl paaoy ri0oa imda'a prior vriaca caaaeat I.mder nmay, r is opeioo, rtxpvo ivataediate taa7a+er m tWl al aB m. aeaeed by +~ Sedaky 4.trnre.e. ito.z.'r. Leda, ap0oe da .a be ausl.ce 6Y l,enaa H e:acLc b p.o6ibincd M Pode~ad !a. r of dedaprdrAU Seaclry t-..e_.~^i~.. tinder aho'slutl noe etaoclee min opitee it. (at ~~+ a-t<'' m 6c tarbedpod b ftadot iatoaoaatoe b1 ttadst b etduaas the EeasOed htrttree a ff a nev ~ taae beiep sedan ~ ttsnl[cror: and (b) [,t00ac. nip tkaami+ea that itutkt'a .oanity .iu rwr eb ~ by tee b.e awaagltioa stau.e ttxi iialc of aitite.ceor rrap oewuoc tr t~tee>maa b th3c'.~'cs tiuhu~t !e aoo~caAbs b 4eader: To tee waacad tir ePPrtrabk law, trader trop ~ac0e a c~hk to r e ooeditim m I.mdda omarar to die loan aaaarrpdaia. I.andr+ roar aba tagdr5. abe raaarfene to dpr : ten h w I.roder aea acne ahffOrn Me. taaeeteaae n baaP all ee~e ~peyoiY~ar asd >. cods m tee Nele and-- bs rlsb $oaaiq boavammt. Bernier .!9 mtWoac a bo, "^~" trey tee tiatr• am mhh Seaaky rreMa t~odet rslerea Rwtaarer L ~t• ~ ~I 1t l.aedlrr ouecier the opdott b terpdoe lnmtediale papmnK fa ai.ea0a t3all Offs l-ataest eai0e d aabelrttniow. 7tie twtlee tbW paawlde a ptrrlud d twa ten tlua 30 rya tha dam We aotko la tldiasrod « tadLaO rltRta n7tlch Baaao»et rraut pap a9'uam arraaeS ~ thiF SeaKY7 taaaaameaa. H Boerova 6ita b ph lheae iPeOa p[ida b ie espbs3tn a( ltda-ptxidd, L.mdet rntr tnroMe~ atxedtea pt:ratmed bl' Aua ~r9 t4d(ImYt4l irld{dld. GttihK tao[ioe ordeotod ~ JioQGMCf. BY SlottlHO HFlAW, taatm..cr .axpts ,wd agtea m rbe retss mrraarru twMdoed in thl. Adjuarbla e,m a;eQ. ~__ rr'L'' w.n tit3ARON g I.ATIDL4 'eenw'° -ea~aQ ts..n awro.e .. wwasrslatswaamae-l~oeam~c ti,~ moswv+n rte .o.: acn.s~ warn ,8orra.r Date: ~ I`1~~=~~~ _~ r Sharon K. Landis 1809 Letchworth Drive Camp Hill, PA 17011 7009 2820 0004 2451.312,4 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mort~a~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 pales. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help 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 NOTIF[CAC[ON EN ADJUNTO ES DE SUMA IMPORTANC[A, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. S[ NO CONIPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION [NMEDITAMENTE LLANIANDO ESTA AGF,NCIA (PENNSYLVANIA IIOUS[NG FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELF,GIBLE PARA UN PRESTAMO POR EL PROCRA~-1A LLAI~~I~1D0 "F-i0~'(EOWNER'S EMERGENCY h~IORTGACE :~SS[STANCE PROGR:~~~I" F~L C[i:~(_, PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECI[O A RF,D[NIIR SU H[POTECA. ~xh~ b>~}- ~, ~ ~. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER LAW FIRM FILE NO.: Sharon K. Landis 1809 Letchworth Drive, Cramp Hill, PA 1701 1 30497911 Ameriquest Mortgage Compan}~ Ocwen Loan Servicing, LLC 09-036823 HOMEOWNER'S EMERGENCY MORTGAGE ASS[ST:~1vCE PROGRA1~~t 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 PROVISION OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOU DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A Rh;ASONABLE PROSPECT OF BEING ABLE "['O PAY 1~UUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQU[REIVIENTS 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 THE NEXT THIRTY-THREE (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_aQencies 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 Cor 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 have 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 WITIIIN 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 BEFORF_ A SHERIFF'S SALE, THE FORECLOSURE WILL BF. STOPPED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. The}~ ~~-ill be disbursed by the Agency under the eligibility criteria established by the Act The Pennsyl<<mia I-fous~ng Finance Agenc~~ has sixty ((i0) da}'s to make a decision after i[ r~cci~~5 y~oUi application. llurinY 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 INFOI~IATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLEC"t THE DEBT. (If you have filed bankruptcy, ou can stilt apply for Emergency Mo~age Assistance.) HOW TO CURE YOUR ORTGAGE llEFAULT (Bring it up to -date). hIATUIRE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located at 1809 Letchworth Drive, Camp Hill, PA 17011 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMEN'T'S for the following months and the following amounts are now past due: August 1, 2009 to January 1, 2010 @ $390.26 Other charges (explain/itemize): $2,3~ ~ .56 Late Charges: August l6, 2009 to December 16, 2009 (cU - $12.81 [nspection Fees: _ ~~'`I~~~S Appraisal Fees ~21.UU ~ l I L00 TOTAL AMOUNT PAST DUE: _ $2,537.61 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not ap licable): HOW TO CURE THE DEFAULT -You may cure the default «~ithin THIRTY (30) DAB"S of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO `fHE LENDER, WHICH IS $2,537.61, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either b cash cashier's check certified check or money order made a able and sent to: Ocwen Loan Servicing, LLC Cashiering Department 12650 hlgenuity Drive Orlando, FL 32826 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if n~~t applicable.) IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its ri hts to accelerate the mort a e 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 It'IORTGAGE [S FOREC[ OSFD UPON -- The mortgaged property wall 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 ou cure the default within the THIRTY (30) DAY period you will not be required to pay attorney's fees. OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- [C you have not cured the default within the THIRTY (30) DAY period and foreclosure proccedings ha~~e begun, you still ha~~e the r~ht to cure the default and~-event the sale at an time u to one hour before the_ Sheriffs Sale. You may do so by i~a >>~ ng the total amount then past due~plus an~dte or othe_r_ char es the_ n due, reasonable atto«ey's_fees and costs connected with the foreclosure sale and an -~- - - -- ether costs connected with the - ------- ~erif('s Salc as specified in writinti_t~ ~ the_lei~der and by_~erformin~ any other recLuirements under the mort~a~e. 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 3 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale ti~~ill be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: C/O The Law Firm of Shapiro & DeNardo, LLC Address: 3600 Horizon Drive, Suite 150, Kind of Prussia, PA 19406 Phone number: (610)278-6800 Fax number: (610)278-9980 Contact person: Christopher A. DeNardo, Esquire 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 X may or -may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that. the other requirements of the mortgage are satisfied. YOU ALSO HAVE THE RIGI-IT: • TO SELL THE PROPERTY TO OB"CAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INST[TUrION 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 OCCi.JRRED, 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 (Fill in a list of all Counseling Agencies listed in Appendix C, FOR THE COUNTI' in which the property is located, using additional pages if necessary). HEMAP Consumer Credit Counseling Agencies CUMBERLAND County Repori last updated: 11/27/2009 2:21:07 PM vim. ~+.~ ~~ ~~C'~CI 11 rH 2000 Linglestown Road Harrisburg, PA 17102 888.51 1.2227 888.51 1.2227 Community Action Commission of Captial Region 1514 Derry 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 Streel Harrisburg, PA 17110 ,17.780.3940 800.342.2397 VERIFICATION Michael Clark hereby states that he is the Attorney for the Plaintiff in this action, that he is authorized to make this Verification, and that the statements made in the forgoing Complaint in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalities of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. S~/H~AP~IRO & DENARDO, L - - - --1~^ Michael Clark, squire ~~~~ ~ ~ Attorney for Plaintiff Dated: USA BANK,N.A., as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass- Though Certificates, Series 2007-TC 1 Plaintiff vs. SHARON K.LANDIS Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA No. 10-2859, Civil Term MORTGAGE FORECLOSURE To: Michael Clark, Esquire (Attorney of Record for USA Bank) You are hereby notified to file a written response to the enclosed Answer to Plaintiff's Complaint with New Matter and Affirmative Defense within twenty (20) days from service hereof or a judgment may be entered against you . By: ~ - • . Geoffrey M. Biringer, Esq. MidPenn Legal Services 401 E.Louther Street Carlisle, PA 17013 (717)243-9400 Supreme Court ID#18040 E~ti~,b~,+.,E,. USA BANK,N.A., as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass- Though Certificates, Series 2007-TC 1 Plaintiff vs. SHARON K.LANDIS Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA No. 10-2859, Civil Term MORTGAGE FORECLOSURE ANSWER AND NEW MATTER 1. Denied. Defendant is without information or belief sufficient to respond to the allegation and proof thereof is demanded at trial. 2. Denied. Defendant is without information or belief sufficient to respond to the allegation and proof thereof is demanded at trial. 3. Admitted. 4. Admitted. 5. Admitted 6. Denied. As set out more fully in New Matter and Affirmative Defense below, Defendant's loan is eligible for modification under the Home Affordable Modification Program, pursuant to which Plaintiff is obligated to explore Defendant's eligibility for this and any other program she may be eligible for, before proceeding further with foreclosure. 7. Denied. As set out more fully in New Matter and Affirmative Defense below, Defendant's loan is eligible for modification under the Home Affordable Modification Program, pursuant to which Plaintiff is obligated to explore Defendant's eligibility for this and any other program she may be eligible for, before proceeding further with foreclosure. 8. Denied. Defendant is without information or belief sufficient to respond to the allegations and proof thereof is demanded at trial. 9. Denied. Defendant is without information or belief sufficient to respond to the allegations and proof thereof is demanded at trial. 10. Admitted. WHEREFORE, Defendant prays that Plaintiff's complaint be dismissed and judgment entered for Defendant. NEW MATTER 11. Paragraphs 1-10 are incorporated herein by reference hereto. 12. Defendant's loan with Plaintiff is eligible for modification pursuant to the Home Affordable Modification Program. 13. Pursuant to said Program, any foreclosure action is to be temporarily suspended pending application of the borrower for the Program or alternative foreclosure prevention options. Program Guidelines, p. 3, "In Foreclosure Process: Temporary Suspension of Foreclosure Proceedings." Supplemental Directive 09-1, p.14, "Temporary Suspension of Foreclosure Proceedings." 14. Defendant has applied for the Program and has received an application packet, but has not received any information as to her eligibility. AFFIRMATIVE DEFENSE HOME AFFORDABILITY MODIFICATION PROGRAM CHAMP) 15. Paragraphs 1-14 are incorporated herein by reference hereto. 16. Until Plaintiff has determined Defendant's eligibility for RAMP, or other foreclosure prevention programs, Plaintiff cannot proceed with the above-captioned action. WHEREFORE, Defendant prays that Plaintiff's complaint be dismissed and judgment entered for the Defendant. Dated: May C ~ , 2010 MIDPENN LEGAL SERVICES By. ., .. ~~~~ Geoffrey M.Binnger 401 E. Lowther Street Carlisle, PA 17013 (717)243-9400 Supreme Court ID#18040 VERIFICATION I, Sharon K. Landis, make this verification that the facts set forth in the foregoing Answer and New Matter are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. ~~~1~~ Date: Sharon K.Landis CERTIFICATE OF SERVICE I, Geoffrey M. Biringer, being a member in good standing of the Bar of Pennsylvania, hereby certify that I served a true and correct copy of the foregoing Answer and New Matter on this( th day of May 2010, by placing same in the United States mail, first class, postage prepaid, addressed as follows: Michael Clark, Esquire 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 .. ~ By: Geoffrey M. Biringer Attorney for the Defendants 401 E. Louther Street Carlisle, PA 17013 (717)243-9400 Supreme Court ID#18040 SHAPIRO & DeNARDO, LLC BY: LESLIE J. RASE, ESQUIRE ATTORNEY LD. NO: PA Bar # 58365 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-036823 U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC 1 PLAINTIFF VS. Sharon K. Landis DEFENDANT(S) -\~ \\ ' ~ ~~~Y ,` ;~ _. 2010 ,lf.~~ -~ ~ (0~ i ! ~,~, t r C ~J I ~r~ iFl..,.~.~~:~tr'~a COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 10-2859 PLAINTIFF'S REPLY TO DEFENDANT SHARON K. LANDIS'S NEW MATTER AND AFFIRMATIVE DEFENSE Plaintiff, U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC1, by and through its attorneys, Shapiro & DeNardo, LLC, and hereby replies to Defendant, Sharon K. Landis's New Matter and Affirmative Defense in accordance with the numbered paragraphs as follows: 11. No response required. 12. Denied as a conclusion of law to which no response is required. 13. Denied as a conclusion of law to which no response is required. 14. Respondent is without information sufficient to form a belief as to the averments contained in this paragraph. AFFIRMATIVE DEFENSE HOME AFFORDABILITY MODIFICATION PROGRAM CHAMP 15. No response required. 16. Denied as a conclusion of law to which no response is required. WHEREFORE, the Plaintiff respectfully requests that the New Matter and Affirmative Defense be dismissed. SHAPIRO & DENARDO, LLC BY: slie J. Rase, Esquire Attorney for Plaintiff SHAPIRO & DeNARDO, LLC BY: LESLIE J. RASE, ESQUIRE ATTORNEY I.D. NO: PA Bar # 58365 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-036823 U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC 1 PLAINTIFF VS. Sharon K. Landis DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 10-2859 VERIFICATION Leslie J. Rase, Esquire, hereby states that she is the Attorney for the Plaintiff in this action, that she is authorized to make this Verification as the Plaintiff is outside the jurisdiction of the Court and Plaintiffs verification could not be obtained with the time necessary to file this pleading, and that the statements made in the foregoing PLAINTIFF'S REPLY TO DEFENDANT'S NEW MATTER AND AFFIRMATIVE DEFENSE are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities. Dated: _ ~~ ~'(~ SHAPIRO & DENARDO, LLC BY: Leslie J. Rase, Esquire Attomey for Plaintiff SHAPIRO & DeNARDO, LLC BY: LESLIE J. RASE, ESQUIRE ATTORNEY I.D. NO: PA Bar # 58365 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-036823 U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC 1 PLAINTIFF VS. Sharon K. Landis DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY ; NO: 10-2859 ; CERTIFICATE OF SERVICE I, Leslie J. Rase, Esquire, counsel for Plaintiff, hereby certify that on (P S a true and correct copy of the attached Plaintiffs Reply to Defendant, Sharon K. Landis's New Matter and Affirmative Defense was served by mailing same by regular mail, postage pre-paid, to: Geoffrey M. Biringer, Esquire MidPenn Legal Services 401 East Lowther Street, Suite 103 Carlisle, PA 17013 SHAPIRO & DENARDO, LLC BY• Leslie J. Rase, Esquire Attorney for Plaintiff 09-036823 SHAPIRO & DeNARDO, LLC BY: LESLIE J. RASE, ESQUIRE ATTORNEY I.D. NO: PA Bar # 58365 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-036823 U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC1 PLAINTIFF VS. Sharon K. Landis DEFENDANT COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 10-2859 AFFIDAVIT OF JOHNNA MILLER STATE OF FLORIDA: COUNTY OF PALM BEACH: Johnna Miller, being duly sworn according to law, deposes and says that: 1. Affiant is employed by Ocwen Loan Servicing, LLC, attorney-in-fact for Plaintiff as Authorized Signer and has personal knowledge of the facts set forth in this Affidavit. 2. In Affiant's capacity as Authorized Signer, Affiant has the responsibility for maintaining the files of Plaintiff with respect to Plaintiff s borrowers, including the above-named Defendant. Erl,,l>f ~" 3. In the normal course of Plaintiffs business, Plaintiff maintains in its files the original or true copies of Defendant's Mortgage, Note, Assignments and correspondence to and from Defendant. 4. In the ordinary course of its business, and in servicing mortgage loans, Plaintiff maintains a record of the history of its mortgage loans on computers into which employees of Plaintiff make entries of payments, disbursements and other appropriate transactions. Interest is calculated by computer software, which software is applied to all or substantially all of Plaintiffs borrowers, including Defendant. 5. On November 17, 1999, Defendant entered into a Mortgage Note in the principal amount of $35,500.00 in favor of Ameriquest Mortgage Company. 6. Also on November 17, 1999, Defendant entered into a Mortgage in favor of Ameriquest Mortgage Company securing the indebtedness of the Note. 7. The real property subject to the Mortgage is located at 1809 Letchworth Drive, Camp Hill, PA 17011. 8. Subsequent to the execution of the subject Note and Mortgage, Ameriquest Mortgage Company assigned all of its interest in the foregoing property and documents, which interest now legally belongs to Plaintiff. The Assignment was duly recorded as noted in Plaintiffs Complaint in Mortgage Foreclosure and is a matter of public record. 9. Affiant is authorized to obtain a printed version of the data electronically maintained by Plaintiff for the subject mortgage loan account. Attached hereto and incorporated by reference is the payment history of the subject account. The Affiant has reviewed the history and, to the best of the Affiant's knowledge and belief, it is accurate and correct. 10. Defendant failed to make payment due on August 1, 2009 pursuant to the Note and Mortgage and thereafter has failed to make all payments on this obligation. 11. As of June 8, 2010, the amount due to Plaintiff pursuant to the aforementioned document is $41,566.02, which includes the following amounts: Principal of Mortgage Debt Due and Unpaid $35,063.82 Interest $1,910.06 Late Charges $89.67 Escrow Advances $2,162.40 Appraisal Fees $222.00 Property Inspection $42.00 Foreclosure Fees & Costs $1,753.91 Certified Mail Cost $22.16 Title Report Fee $300.00 TOTAL $41,566.02 12. The per diem interest rate is $5.62 for each day after June 8, 2010 that the debt remains unpaid until judgment. 13. The mortgage sought to be foreclosed herein is due for the August 1, 2009 payment and all subsequent payments. The dollar amount of the regular monthly payment is $390.26. At no time has Defendant tendered a sum sufficient to contractually cure the delinquency herein. 14. 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C C ~+. " C . ~ ° '.C C n C C C C C. °Li C `. 8 ~ 3 c S. . ~ = ~ . ~ c ~' .. ~ o C ~ m m a a - S>' ~ ~ ~ S ~ ~ - ~ i ~ ~ S ...~ 8 8 .8: ~ ° 'c o 8 8 S S s 3 ,i o :i . p C c C ~ .~. ~ ~ ~ ~ ~ C C 3 m a ~ ~ ~ ~ ~ e _ IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC1, NO: 10-2859 Plaintiff, v. Sharon K. Landis, Defendant(s). BRIEF IN SUPPORT OF MOTION OF PLAINTIFF, U.S. BANK, N.A. AS TRUSTEE FOR THE REGISTERED HOLDERS OF STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-TC1, FOR SUMMARY JUDGMENT SHAPIRO & DENARDO, LLC BY: Leslie J. Rase, Esquire ATTORNEY I.D. NO: PA Bar # 58365 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 09-036823 INTRODUCTION Plaintiff, U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC1 ("Plaintiff'), commenced this action seeking a judgment in Mortgage Foreclosure against Defendant, Sharon K. Landis (hereinafter referred to as "Defendant"), in an amount equal to the principal, interest, late charges, escrow advances, costs and attorneys' fees due pursuant to a mortgage given to secure the indebtedness of Defendant. The material facts in this mortgage foreclosure matter are: (1) the existence of an obligation of the Defendant to the Plaintiff; (2) the Defendant's failure to pay her monthly installments of principal and interest according to the terms of the Mortgage; and (3) the total amounts due to Plaintiff for Defendant's failure to pay her monthly mortgage payments. There is no dispute concerning the existence of the obligation and that the debt has not been paid in accordance with the terms of the Mortgage in well over ten (10) months; and the total amounts due to Plaintiff. There is no justification for the Defendant's default under the Note and Mortgage and there are simply no defenses to this action. Accordingly, there are no genuine issues as to any material facts and the Plaintiff is entitled to judgment as a matter of law. PROCEDURAL HISTORY Plaintiff filed a Complaint in Mortgage Foreclosure (the "Complaint") with the Cumberland County Prothonotary's Office on Apri129, 2010. On May 19, 2010, Defendant filed an Answer with New Matter and Affirmative Defenses to the Complaint to which Plaintiff filed its timely reply. The pleadings have been closed, and disposition of the motion will not delay trial. STATEMENT OF THE CASE On November 17, 1999, Defendant executed a promissory note in the principal sum of $35,500.00 (the "Note"). On the same day, Defendant entered into a mortgage in favor of Ameriquest Mortgage Company, which secured the indebtedness of the Note (the "Mortgage"). The real property, which is subject to the Mortgage, is located at 1809 Letchworth Drive, Camp Hill, Pa 17011 (the "Mortgaged Premises"). Defendant failed to make the payment due on August 1, 2009, required pursuant to the Note and Mortgage, and thereafter has failed to make any payment on this obligation despite due demand. As of this date, Defendant has failed and/or refused to make her monthly mortgage payment in well over ten (10) months. Plaintiff s damages can be easily calculated pursuant to the terms of the Note and Mortgage and total $41,566.02 as of June 8, 2010. ARGUMENT I. THE EVIDENTIARY RECORD ESTABLISES THAT THERE IS NO GENUINE ISSUE AS TO ANY MATERIAL FACT A. Standard For Granting Summary Judgment Summary judgment is governed by Rule 1035.2, which provides, in pertinent part: After the relevant pleadings are closed, but within such time as not to unreasonably delay trial, any party may move for summary judgment in whole or in part as a matter of law (1) whenever there is no genuine issue of any material fact as to a necessary element of the cause of action or defense which could be established by additional discovery or expert report. (2) if, after completion of discovery relevant to the motion, including the production of expert reports, an adverse party who will bear the burden of proof at trial has failed to produce evidence 2 of facts essential to the cause of action or defense which in a jury trial would require the issue to be submitted to a jury. Pa. R.C.P. No. 1035.2. The Pennsylvania Supreme Court provided guidance as to this standard in Ertel v. Patriot News Co., 544 Pa. 93, 674 A.2d 1038 (1996). The court accepted the standard of review in motions for summary judgment as established by the United States Supreme Court in Celotex Corp. v. Catrett, 477 U.S. 317 (1986), and Anderson v. Liberty Lobby, 477 U.S. 242 (1986). In these decisions, the Supreme Court stated anon-moving party on a motion for summary judgment must produce sufficient evidence on an issue essential to its case and on which he bears the burden of proof such that a jury could return a verdict in his favor. The Pennsylvania Supreme Court in Ertel specifically stated this standard is consistent with Rule 1035. Ertel at 101, 674 A.2d at 1042. This standard places a burden on the non-moving party to come forward with evidence to defeat the motion. According to the rules of procedure, summary judgment is properly granted where the pleadings, depositions, answers to interrogatories, admissions on file, together with affidavits show "there is no genuine issue of any material fact as to a necessary element of the cause of action." Pa. R.C.P. No. 1035.2; see also, Marks v. Tasman and Benson, 527 Pa. 132, 589 A.2d 205 (1991); Citicorp Mortg_a~e Inc v Morrisville Hampton Villa eg_realty Limited Partnership, 443 Pa. Super. 595, 662 A.2d 1120 (1995). The function of the summary judgment is to prevent vexation and delay, improve the machinery of justice, promote the expeditious disposition of cases and avoid unnecessary trials if no genuine issue of material fact is raised. Williams v. Pilgrim Life Insurance Co., 306 Pa. Super. 135, 461 A.2d 833 (1983). Another purpose is to avoid a useless trial. Dillon v. Nat'l R.R. Com., 345 Pa. Super. 126, 136, 497 A.2d 1336, 1341 (1985). Summary judgment is also 3 designed to pierce the pleadings and assess the proof to determine whether there is a genuine need for a trial. Phaff v. Gerner, 451 Pa. 146, 303 A.2d 826 (1973). Plaintiff has the burden of demonstrating there is no genuine issue of material fact. Hower v. Whitmark Assoc., 371 Pa. Super.443, 381 A.2d 524 (1988); Carollo v. 48 Insulation, Inc., 252 Pa. Super. 422, 381 A.2d 990 (1977). Once such a showing is made, summary judgment is appropriate if an adverse party is unable to come forward with probative evidence demonstrating it is not liable to Plaintiff. Phaff v. Gerner, 451 Pa. 146, 303 A.2d 826 (1973). See also, Pape v. Smith, 227 Pa. 80, 323 A.2d 856 (1974); Amabile v. Auto Kleen Car Wash, 249 Pa. 240, 376 A.2d 247 (1977). In this matter, Plaintiff respectfully submits that the evidentiary record, as defined by Pa. R.C.P. No. 1035.1 (pleadings and exhibits, depositions if any, answers to interrogatories, admissions and affidavits), establishes conclusively that the material facts are undisputed and, therefore, there is no issue for disposition by the finder of fact. The official commentary to Rule 1035.2 provides, in relevant part: Rule 1035.2 sets forth the general principle that a motion for summary judgment is based on an evidentiary record, which entitles the moving party to a judgment as a matter of law. The evidentiary record may be one of two types. Under subparagraph (1), the records show that the material facts are undisputed and, therefore, there is no issue to be submitted to a jury. An example of a motion under subparagraph (1) is a motion supported by a record containing an admission. By virtue of the admission no issue of fact could be established by further discover~or expert report. Pa. R.C.P. No. 1035.2 (emphasis added). 4 B. The Admissions and Defective Denials in the Answer Remove Any Issues of Fact In this matter, the material facts of Plaintiffs cause of action are undisputed and, therefore, there is no genuine issue for disposition by the finder of fact. The material facts are undisputed either because Defendant has admitted same or has failed to raise any issue of material fact so as to preclude the entry of summary judgment. 1. Defendant's Obligation to Plaintiff On November 17, 1999, Defendant executed a Promissory Note in the principal sum of $35,500.00. Contemporaneously therewith, Defendant executed a Mortgage in favor of Ameriquest Mortgage Company, which secured the indebtedness of the Note with the Mortgaged Premises. According to page 1 of the Mortgage, the Defendant unequivocally mortgaged, granted, and conveyed the Mortgaged Premises to Ameriquest Mortgage Company. See Ex. "B." Subsequent thereto, Ameriquest Mortgage Company properly assigned the Mortgage and Note to Plaintiff. See Ex. "C." Paragraph 1(d) of Plaintiff's Complaint sets forth the parties to the mortgage, date and recording information of the mortgage and that the aforementioned Assignment was properly executed and recorded. See Ex. "D" at ¶1 (a)-(3). Paragraph 2 of the Complaint states that Plaintiff is either the original mortgagee named in the mortgage, the legal successor in interest or is the present holder of the mortgage by virtue of the above assignment. See Ex. "D" at ¶2. In her response, Defendant generally denies all of the allegations of those paragraphs and she demands proof of same at trial. See Ex. "E," at ¶¶1-2. In disregard of Defendant's general and unsupported allegations, it is clear from the plain language of the Mortgage and Assignment that Ameriquest Mortgage Company had such legal 5 authority to assign the Mortgage to Plaintiff. The clear and unambiguous language of the Mortgage states that the Defendant mortgaged, granted, and conveyed to Ameriquest Mortgage Company the Mortgaged Premises. Plaintiff sufficiently set forth (1) the existence and date of the mortgage; (2) the fact Ameriquest Mortgage Company was the mortgage holder; and (3) that Plaintiff is now the legal owner of the mortgage, thereby indicating it had assumed all the rights and remedies related to the mortgage. See U.S. Bank v. Mallory, 2009 Pa. Super 182 (2008). Therefore, since the Assignment of Mortgage is executed in favor of Plaintiff (Ex. "C"), Defendant is obligated to make her monthly payments to Plaintiff. 2. Defendant's Default Reliance on Pa. R.C.P. No. 1029(c) does not excuse a failure to admit or deny a factual allegation when it is clear that the pleader must know whether a particular allegation is true or false. Cercone v. Cercone, 254 Pa. Super. 381, 386 A.2d 1 (1978); Commonwealth by Preate v. Rainbow Associates, Inc., 138 Pa. Cmwlth. 56, 587 A.2d 357 (1991). Similarly, general denials or claims of insufficient knowledge and belief as to the truth of the mortgage debt due and owing are to be deemed admissions. As the court sated in New York Guardian Mortgage Corporation v_ 17iet~el Appellants, in their answer to appellee's complaint, admitted that they were behind in their mortgage payments. Likewise, appellants' general denial that they are without information sufficient to form a belief as to the truth of appellee's averment as to the principal and interest due is to be considered an admission of those facts. See 362 Pa. Super. 426, 429, 524 A.2d 951, 952 (1987). See also, Cercone v. Cercone, 254 Pa. Super. 381, 386 A.2d 1 (1978). In the instant matter, Paragraph 6 of Plaintiff's Complaint sets forth the Defendant's default as follows: 6 The Mortgage is in default because the monthly installments of principal and interest and other charges stated below, all as authorized by the Mortgage, are due as of August 1, 2009 and have not been paid, and upon failure to make such payments when due, the whole of the principal, together with charges specifically itemized below are immediately due and payable. See Ex. "D," at ¶6. In Defendant's response, she denies this paragraph and alleges that since she is "eligible for modification under the Home Affordable Modification Program~....plaintiff is obligated to explore Defendant's eligibility...before proceeding further with foreclosure." See Ex. "E," at ¶6. Further, in her New Matter/Affirmative Defenses, Defendant alleges that pursuant to Supplemental Directive 09-1, P.14,2 under HAMP, the foreclosure process should temporarily be suspended pending Defendant's loan modification application. However, Defendant's reading of Supplemental Directive 09-1 is misplaced. The guidelines do not mandate Plaintiff cease the foreclosure action pending review of her application. Instead, it states that only the foreclosure sale cannot be conducted pending a borrower's review of eligibility under the HAMP program. See Ex. "H" at P. 14. There is nothing in the Directive which mandates Plaintiff is to cease the foreclosure action, including obtaining a judgment, prior to the sheriff sale. It is clear that Defendant knows whether she made her monthly mortgage payments, but she refuses to acknowledge such in her answer. Therefore, her refusal to answer an averment to which she clearly knows the answer to should be deemed an admission thereof. See, New York Guardian Mortgage Corporation v. Dietzel, 362 Pa. Super. 426, 524 A.2d 951, 952 (1987). 1 On February 18, 2009, the President announced the national Homeowner Affordability and Stability Plan ((hereinafter "HAMP") which was implemented by the Treasury Department to assist borrowers with applications for loan modifications. See www.makinghomeaffordable.gov. 2 Supplemental Directive 09-01 was issued by the Treasury on March 4, 2009 as a guidance to servicers for the HAMP program. See Supplemental Directive 09-01 attached hereto as Exhibit "H". 7 Moreover, such response must be viewed as an admission pursuant to Pa. R.C.P. 1029(b), which states as follows: "Averments in a pleading to which a responsive pleading is required are admitted when not denied specifically or by necessary implication. A general denial or a demand for proof, [...J, shall have the effect of an admission." See Pa. R.C.P. 1029(b). (Emphasis added). Paragraph 6 of Plaintiffs Complaint is a factual and not a legal averment. Whether the Defendant made her monthly mortgage payments to Plaintiff is a factual allegation and must be denied specifically. Defendant's response must be construed as a general denial and, thus, an admission because it does not deny Paragraph 6 "specifically" or "by necessary implication." Furthermore, in a mortgage foreclosure action, a claim based on facts which occurred after the default is certainly not based on facts pertaining to the creation of the Mortgage and must be dismissed. Chrysler First Business Credit Corp. v. Gourniak, 411 Pa.Super. 239, 601 A.2d 338 (1992); Overly v. Kass, 382 Super.Ct. 108, 554 A.2d 970 (1989); Mellon Bank, N.A. v. Joseph, 267 Pa. Super. 307, 406 A.2d 1055 (1979). Moreover, since the allegations raised by Defendant do not arise from the creation of the Mortgage, they lack merit and are not a valid defense to the Defendant's admitted default under the Note and Mortgage. Moreover, any alleged agreement is unenforceable since it is in violation of the Statute of Frauds. See P.S. § 1. The Statute of Frauds states in relevant part: ... no leases, estates or interests, either of freehold or terms of years, or any uncertain interest, of, in, to or out of any messuages, manors, lands, tenaments or hereditaments, shall at any time be by deed or note, in writing, signed by the parties so assigning, granting or surrendering the same, or their agents, thereto lawfully authorized by writing, or by act and operation of law. Id. s Defendant failed to attach a writing to her New Matter with regard to the alleged application for a loan modification. Since Plaintiff s action is an in rem mortgage foreclosure on real property, any agreement must be in writing and the absence of same is in violation of the Statute of Frauds and prohibited. See Lehner v. Montgomery, 180 Pa. Super. 493, 119 A.2d 626 (1956); Rosenblum v. New York Cent. R. Co., 162 Pa. super. 276, 57 A.2d 690 (1948); Lauffer v. Vial, 153 Pa. Super. 342, 33 A.2d 777 (1943). Even if Defendant's response is not construed as an admission, Plaintiff has provided the Affidavit of Johnna Miller, employed by Plaintiff. The Affidavit conclusively establishes that Defendant defaulted on her mortgage loan. See generally Ex. "G." Therefore, there is no issue of material fact as to Defendant's liability for her failure to pay her monthly installments of principal and interest according to the terms of the Loan Documents. 3. Total Amount Due In an action for mortgage foreclosure, the entry of summary judgment is proper if the mortgage is in default and the recorded mortgage is in a specified amount. See Landau v. Western Pa. Nat'l Bank, 445 Pa. 217, 225-6, 282 A.2d 335, 340 (1971). See also, 22 Standard Pa. Practice 2d 121:69. This is so, even if the mortgagor does not admit the total amount of the indebtedness. See id. With respect to Plaintiff s damages, Paragraph 7 of the Complaint correctly alleged the liquidated amount thereof as of the date the Complaint was prepared. See Ex. "D," at ¶7. Defendant's response is again her reliance on her allegation that she has a HAMP loan modification application pending. See Ex. "E," at ¶7. However, as indicated previously this is not a defense to a foreclosure action. Defendant as the mortgagor generally denies the total amount of her indebtedness. As such summary judgment is proper because the mortgage is in 9 default and the recorded mortgage is in a specified amount. See Landau v. Western Pa. Nat'l Bank, 445 Pa. 217, 282 A.2d 335 (1971). Additionally, the damages that the Plaintiff seeks to recover by way of the instant mortgage foreclosure proceeding are absolutely in conformity with Pennsylvania law and in accordance with Paragraph 21 of the Mortgage, which states (in pertinent part): If the default is not cured as specified, Lender at its option may require immediate payment in full of all sums secured by this Security Instrument without further demand and may foreclose this Security Instrument by judicial proceeding. Lender shall be entitled to collect all expenses incurred in pursuing the remedies provided in this Section 21, including, but not limited to, attorneys' fees and costs of title evidence to the extent permitted by Applicable Law. See Ex. "B," at ¶21. (Emphasis added). This provision allows the Plaintiff to recover all expenses associated with the Defendant's failure and/or refusal to make, tender, and/or deliver her mortgage payments. Moreover, the Pennsylvania appellate courts have repeatedly held that a mortgagee is entitled in foreclosure to recover reasonable expenses, including attorneys' fees. Citicom Mortgage Inc. v. Morrisville Hampton Village, 443 Pa. super. 595, 662 A.2d 1120 (Pa. Super. 1995); Foulke v. Hatfield Fair Grounds Bazaar, Inc., 196 Pa. Super. 155, 173 A.2d 703 (1961); Harper v Consol Rubber Co., 284 Pa. 444, 131 A. 356 (1925). In Foulke, for instance, the Pennsylvania Superior Court stated that a fixed sum of five (5) percent of the principal is a reasonable attorney's fee. I n this case, the sum of $1,753.91 as set forth in the Lender's Complaint is within that five (5) percent guideline. In support of its attorney's fees, Plaintiff has also provided the Affidavit of Johnna Miller. See Ex. "F." Summary judgment is appropriate since Plaintiffs fees are set forth in the above Affidavit and Plaintiff s attorney's fees are based on long-standing case law. io Finally, the above Affidavit is in support of Plaintiff's Motion for Summary Judgment. See Ex. "G," at ¶11. The Affidavit conclusively establishes that the following amounts are due and owing to Plaintiff under the Mortgage and Note as of June 8, 2010: Principal of Mortgage Debt Due and Unpaid $35,063.82 Interest $1,910.06 Late Charges $89.67 Escrow Advances $2,162.40 Appraisal Fees $222.00 Property Inspection $42.00 Foreclosure Fees & Costs $1,753.91 Certified Mail Cost $22.16 Title Report Fee $300.00 TOTAL $41,566.02 See Ex. "G," at ¶11. After June 8, 2010, interest accrues at a per diem rate of $5.62 until judgment in mortgage foreclosure is entered. Id. Summary judgment is appropriate since the amounts due Plaintiff are set forth in the above Affidavit. Plaintiff has established by sworn affidavit that the loan is in default; the default has not been cured, and has set forth the precise amount due. The amounts due on the loan are clearly established by the payment history for the loan, the Mortgage, and the Note, true and correct copies of which are attached to the Motion. The Affidavit of Plaintiff further verifies the amount due on the loan. Summary judgment is proper because the mortgage is in default and the recorded mortgage is in a specified amount. See Landau v. Western Pa. Nat'l Bank, 445 Pa. 217, 225-6, 282 A.2d 335, 340 (1971). There is no genuine issue of material fact and, as such summary judgment should be granted to Plaintiff. 11 II. PLAINTIFF IS ENTITLED TO ENTRY OF SUMMARY JUDGMENT IN ITS FAVOR AND AGAINST DEFENDANT AS A MATTER OF LAW The uncontroverted facts in this case establish all of the elements in a cause of action for mortgage foreclosure. Furthermore, as the Pennsylvania Superior Court has determined "Summary judgment is properly granted in a mortgage foreclosure action where the mortgagor admits that he is delinquent in mortgage payments." First Wisconsin Trust Co. v. Strausser, 439 Pa. Super. 192, 653 A.2d 688 (1995), (citing New York Guardian Mort~a~e Corp. v. Dietzel, 362 Pa. Super 426, 574 A.2d 951 (1987)). Defendant did not file any counterclaim in this foreclosure action. Moreover, the allegations contained in Defendant's Answer amount to nothing more than general denials. In addition to Defendant's admissions in her Answer to Plaintiff's Complaint, Plaintiff has established, through submission of the Loan Documents, the pleadings, and Plaintiff's Affidavit, the following material facts: (1) the existence of an obligation of the Defendant to Plaintiff; (2) the defendant's failure to pay her monthly installments of principal and interest according to the terms of the Mortgage; and (3) the total amounts due to Plaintiff for Defendant's failure to pay her monthly mortgage payments. The pleadings, exhibits thereto, together with Plaintiff s Affidavit of Amount Due and Loan History, clearly demonstrate that there is no genuine issue as to any material fact. Therefore, Plaintiff is entitled to summary judgment as a matter of law. CONCLUSION In this matter there are no issues as to any material facts and the Plaintiff is entitled to judgment as a matter of law. For the foregoing reasons, Plaintiff respectfully requests this Honorable Court grant its Motion for Summary Judgment and enter judgment of Mortgage 12 Foreclosure in rem in its favor and against Defendant, Sharon K. Landis, in the amount of $41,566.02 together with additional expenses and interest through the date of judgment and thereafter as provided by the Mortgage and applicable law, plus costs; and authorizing sale of the mortgaged property. Respectfully submitted, SHAPIRO & DENARDO, LLC Dated: ~ a BY: ~"~ Leslie J. Rase, Esquire Attorney for Plaintiff 13 Supplemental Directive 09-01 April 6, 2009 Introduction of the Home Affordable Modification Program Background On February 18, 2009, President Obama announced the Homeowner Affordability and Stability Plan to help up to 7 to 9 million families restructure or refinance their mortgages to avoid foreclosure. As part of this plan, the Treasury Department (Treasury) announced a national modification program aimed at helping 3 to 4 million at-risk homeowners - both those who are in default and those who are at imminent risk of default - by reducing monthly payments to sustainable levels. On March 4, 2009, the Treasury issued uniform guidance for loan modifications across the mortgage industry. This Supplemental Directive provides additional guidance to servicers for adoption and implementation of the Home Affordable Modification program (RAMP) for mortgage loans that are not owned or guaranteed by Fannie Mae or Freddie Mac (Non-GSE Mortgages). Under the RAMP, a servicer will use a uniform loan modification process to provide a borrower with sustainable monthly payments. The guidelines set forth in this document apply to all eligible mortgage loans secured by one- to four-unit owner-occupied single- family properties. In order for a servicer to participate in the RAMP with respect to Non-GSE Mortgages, the servicer must execute a servicer participation agreement and related documents (servicer Participation Agreement) with Fannie Mae in its capacity as financial agent for the United States (as designated by Treasury) on or before December 31, 2009. The Servicer Participation Agreement will govern servicer participation in the RAMP program for all Non-GSE Mortgages. Servicers of mortgage loans that are owned or guaranteed by Fannie Mae or Freddie Mac should refer to the RAMP announcement issued by the applicable GSE. The RAMP reflects usual and customary industry standards for mortgage loan modifications contained in typical servicing agreements, including pooling and servicing agreements (PSAs) governing private label securitizations. As detailed in the Servicer Participation Agreement, participating servicers are required to consider all eligible mortgage loans unless prohibited by the rules of the applicable PSA and/or other investor servicing agreements. Participating servicers are required to use reasonable efforts to remove any prohibitions and obtain waivers or approvals from all necessary parties in order to carry out any modification under the RAMP. Evt,~.e4 ~ N" To help servicers implement the RAMP, this Supplemental Directive covers the following topics: • HAMP Eligibility • Underwriting • Modification Process • Reporting Requirements • Fees and Compensation • Compliance HAMP Eligibility A Non-GSE Mortgage is eligible for the HAMP if the servicer verifies that all of the following criteria are met: • The mortgage loan is a first lien mortgage loan originated on or before January 1, 2009. • The mortgage loan has not been previously modified under the HAMP. • The mortgage loan is delinquent or default is reasonably foreseeable; loans currently in foreclosure are eligible. • The mortgage loan is secured by a one- to four-unit property, one unit of which is the borrower's principal residence. Cooperative share mortgages and mortgage loans secured by condominium units are eligible for the HAMP. Loans secured by manufactured housing units are eligible for the HAMP. • The property securing the mortgage loan must not be vacant or condemned. • The borrower documents a financial hardship and represents that (s)he does not have sufficient liquid assets to make the monthly mortgage payments by completing a Home Affordable Modification Program Hardship Affidavit and provides the required income documentation. The documentation supporting income may not be more than 90 days old (as of the date the servicer is determining HAMP eligibility). • The borrower has a monthly mortgage payment ratio of greater than 31 percent. • A borrower in active litigation regarding the mortgage loan is eligible for the RAMP. • The servicer may not require a borrower to waive legal rights as a condition of the HAMP. • A borrower actively involved in a bankruptcy proceeding is eligible for the HAMP at the servicer's discretion. Borrowers who have received a Chapter 7 bankruptcy discharge in a case involving the first lien mortgage who did not reaffirm the mortgage debt under applicable law are eligible, provided the Home Affordable Modification Trial Period Plan and Home Affordable Modification Agreement are revised as outlined in the Acceptable Revisions to HAMP Documents section of this Supplemental Directive. • The borrower agrees to set up an escrow account for taxes and hazard and flood insurance prior to the beginning of the trial period if one does not currently exist. • Borrowers may be accepted into the program if a fully executed Home Affordable Modification Trial Period Plan is in the servicer's possession on December 31, 2012. Supplemental Directive 09-01 Page 2 The current unpaid principal balance (UPB) of the mortgage loan prior to capitalization must be no greater than: 0 1 Unit: $729,750 0 2 Units: $934,200 0 3 Units: $1,129,250 0 4 Units: $1,403,400 Note: Mortgage loans insured, guaranteed or held by a federal government agency (e.g., FHA, HUD, VA and Rural Development) may be eligible for the HAMP, subject to guidance issued by the relevant agency. Further details regarding inclusion of these loans in the HAMP will be provided in a subsequent Supplemental Directive. The RAMP documents are available through www.tinancialstabilit~gov. Documents include the Home Affordable Modification Trial Period Plan (hereinafter referred to as Trial Period Plan), the Home Affordable Modification Agreement (hereinafter referred to as the Agreement), the Home Affordable Modification Program Hardship Affidavit (hereinafter referred to as the Hardship Affidavit) and various cover letters. Underwriting Hardship Affidavit Every borrower and co-borrower seeking a modification, whether in default or not, must sign a Hardship Affidavit that attests to and describes one or more of the following types of hardship: 1. A reduction in or loss of income that was supporting the mortgage. 2. A change in household financial circumstances. 3. A recent or upcoming increase in the monthly mortgage payment. 4. An increase in other expenses. 5. A lack of sufficient cash reserves to maintain payment on the mortgage and cover basic living expenses at the same time. Cash reserves include assets such as cash, savings, money market funds, marketable stocks or bonds (excluding retirement accounts and assets that serve as emergency fund -generally equal to three times the borrower's monthly debt payments). 6. Excessive monthly debt payments and overextension with creditors, e.g., the borrower was required to use credit cards, a home equity loan, or other credit to make the mortgage payment. 7. Other reasons for hardship detailed by the borrower. Note: The borrower is not required to have the Hardship Affidavit notarized. Reasonably Foreseeable (Imminent) Default A borrower that is current or less than 60 days delinquent who contacts the servicer for a modification, appears potentially eligible for a modification, and claims a hardship must Supplemental Directive 09-O1 Page 3 be screened for imminent default. The servicer must make a determination as to whether a payment default is imminent based on the servicer's standards for imminent default and consistent with applicable contractual agreements and accounting standards. If the servicer determines that default is imminent, the servicer must apply the Net Present Value test. In the process of making its imminent default determination, the servicer must evaluate the borrower's financial condition in light of the borrower's hardship as well as inquire as to the condition of and circumstances affecting the property securing the mortgage loan. The servicer must consider the borrower's financial condition, liquid assets, liabilities, combined monthly income from wages and all other identified sources of income, monthly obligations (including personal debts, revolving accounts, and installment loans), and a reasonable allowance for living expenses such as food, utilities, etc. The hardship and financial condition of the borrower shall be verified through documentation. Documenting the Reason for and Timing of Imminent Default A servicer must document in its servicing system the basis for its determination that a payment default is imminent and retain all documentation used to reach its conclusion. The servicer's documentation must also include information on the borrower's financial condition as well as the condition and circumstances of the property securing the mortgage loan. Net Present Value (NPV) Test All loans that meet the RAMP eligibility criteria and are either deemed to be in imminent default (as described above) or 60 or more days delinquent must be evaluated using a standardized NPV test that compares the NPV result for a modification to the NPV result for no modification. If the NPV result for the modification scenario is greater than the NPV result for no modification, the result is deemed "positive" and the servicer MUST offer the modification. If the NPV result for no modification is greater than NPV result for the modification scenario, the modification result is deemed "negative" and the servicer has the option of performing the modification in its discretion. For mortgages serviced on behalf of a third party investor for which the modification result is deemed "negative," however, the servicer may not perform the modification without express permission of the investor. If a modification is not pursued when the NPV result is "negative," the servicer must consider the borrower for other foreclosure prevention options, including alternative modification programs, deeds-in-lieu, and preforeclosure sale programs. Whether or not a modification is pursued, the servicer MUST maintain detailed documentation of the NPV model used, all NPV inputs and assumptions and the NPV results. Fannie Mae has developed a software application for servicers to submit loan files to the NPV calculator. The software application is available on the Home Affordable Supplemental Directive 09-01 Page 4 Modification servicer web portal accessible through www.tinancialstabilitv.~.~ov. On this portal, servicers will have access to the NPV calculator tool as well as detailed guidelines for submitting proposed modification data. servicers having at least a $40 billion servicing book will have the option to create a version of the NPV calculator that uses a set of cure rates and redefault rates estimated based on the experience of their own portfolios, taking into consideration, if feasible, current LTV, current monthly mortgage payment, current credit score, delinquency status and other loan or borrower attributes. Detailed guidance on required inputs for custom NPV calculations is forthcoming. For mortgages serviced on behalf of a third party investor, the servicer must use a discount rate at least as high as the rate used on the servicer's own portfolio, but in no event higher than the maximum rate permitted under the RAMP. To obtain a property valuation input for the NPV calculator, servicers may use either an automated valuation model (AVM), provided that the AVM renders a reliable confidence score, or a broker's price opinion (BPO). A servicer may use an AVM provided by one of the GSEs. As an alternative, servicers may rely on their internal AVM provided that: (i) the servicer is subject to supervision by a Federal regulatory agency; (ii) the servicer's primary Federal regulatory agency has reviewed the model; and (iii) the AVM renders a reliable confidence score. If a GSE AVM or the servicer AVM is unable to render a value with a reliable confidence score, the servicer must obtain an assessment of the property value utilizing a BPO or a property valuation method acceptable to the servicer's Federal regulatory supervisor. Such assessment must be rendered in accordance with the Interagency Appraisal and Evaluation Guidelines (as if such guidelines apply to loan modifications). In all cases, the property valuation used cannot be more than 90 days old. Verifying Borrower Income and Occupancy Status servicers may use recent verbal financial information obtained from the borrower and any co-borrower 90 days or less from the date the servicer is determining HAMP eligibility to assess the borrower's eligibility. The servicer may rely on this information to prepare and send to the borrower a solicitation for the RAMP and an offer of a Trial Period Plan. When the borrower returns the Trial Period Plan and related documents, the servicer must review them to verify the borrower's financial information and eligibility - except that documentation of income may not be more than 90 days old as of the determination of eligibility. As an alternative, a servicer may require a borrower to submit the required documentation to verify the borrower's eligibility and income prior to preparing a Trial Period Plan. Upon receipt of the documentation and determination of the borrower's Supplemental Directive 09-01 Page 5 eligibility, a servicer may prepare and send to the borrower a letter indicating that the borrower is eligible for the RAMP together with a Trial Period Plan. The borrower will only qualify for the RAMP if the verified income documentation confirms that the monthly mortgage payment ratio prior to the modification is greater than 31 percent. The "monthly mortgage payment ratio" is the ratio of the borrower's current monthly mortgage payment to the borrower's monthly gross income (or the borrowers' combined monthly gross income in the case of co-borrowers). The "monthly mortgage payment" includes the monthly payment of principal, interest, property taxes, hazard insurance, flood insurance, condominium association fees and homeowner's association fees, as applicable (including any escrow payment shortage amounts subject to a repayment plan). When determining a borrower's monthly mortgage payment ratio, servicers must adjust the borrower's current mortgage payment to include, as applicable, property taxes, hazard insurance, flood insurance, condominium association fees and homeowner's association fees if these expenses are not already included in the borrower's payment. The monthly mortgage payment does not include mortgage insurance premium payments or payments due to holders of subordinate liens. With respect to adjustable rate loans where there is a rate reset scheduled within 120 days after the date of the evaluation (a "Reset ARM"), the monthly mortgage payment used to determine eligibility will be the greater of (i) the borrower's current scheduled monthly mortgage payment or (ii) a fully amortizing monthly mortgage payment based on the note reset rate using the index value as of the date of the evaluation (the "Reset Interest Rate"). With respect to adjustable rate loans that reset more than 120 days after the date of the evaluation, the borrower's current scheduled monthly mortgage payment will be used to determine eligibility. The borrower's "monthly gross income" is the borrower's income amount before any payroll deductions and includes wages and salaries, overtime pay, commissions, fees, tips, bonuses, housing allowances, other compensation for personal services, Social Security payments, including Social Security received by adults on behalf of minors or by minors intended for their own support, and monthly income from annuities, insurance policies, retirement funds, pensions, disability or death benefits, unemployment benefits, rental income and other income. If only net income is available, the servicer must multiply the net income amount by 1.25 to estimate the monthly gross income. Servicers should include non-borrower household income in monthly gross income if it is voluntarily provided by the borrower and if there is documentary evidence that the income has been, and reasonably can continue to be, relied upon to support the mortgage payment. All non-borrower household income included in monthly gross income must be documented and verified by the servicer using the same standards for verifying a borrower's income. The servicer may not require a borrower to make an up-front cash contribution (other than the first trial period payment) for the borrower to be considered for the RAMP. Supplemental Directive 09-01 Page 6 The RAMP documents instruct the borrower (the term "borrower" includes any co- borrower) to provide the following financial information to the servicer: If the borrower is employed: • A signed copy of the most recently filed federal income tax return, including all schedules and forms, if available, • A signed IRS Form 4506-T (Request for Transcript of Tax Return), and • Copies of the two most recent paystubs indicating year-to-date earnings. • For additional income such as bonuses, commissions, fees, housing allowances, tips and overtime, a servicer must obtain a letter from the employer or other reliable third-party documentation indicating that the income will in all probability continue. If the borrower is self-employed: • A signed copy of the most recent federal income tax return, including all schedules and forms, if available, • A signed IRS Form 4506-T (Request for Transcript of Tax Return), and • The most recent quarterly or year-to-date profit and loss statement for each self- employed borrower. • Other reliable third-party documentation the borrower voluntarily provides. Note: For both a salaried or aself-employed borrower, if the borrower does not provide a signed copy of the most recently filed federal income tax return, or if the Compliance Agent so requires, the servicer must submit the Form 4506-T to the IRS to request a transcript of the return. If the borrower elects to use alimony or child support income to qualify, acceptable documentation includes: • Photocopies of the divorce decree, separation agreement, or other type of legal written agreement or court decree that provides for the payment of alimony or child support and states the amount of the award and the period of time over which it will be received. Servicers must determine that the income will continue for at least three years. • Documents supplying reasonably reliable evidence of full, regular and timely payments, such as deposit slips, bank statements or signed federal income tax returns. If the borrower has other income such as social security, disability or death benefits, or a pension: • Acceptable documentation includes letters, exhibits, a disability policy or benefits statement from the provider that states the amount, frequency, and duration of the benefit. The servicer must determine that the income will continue for at least three years. • The servicer must obtain copies of signed federal income tax returns, IRS W-2 forms, or copies of the two most recent bank statements. Supplemental Directive 09-O1 Page 7 If the borrower receives public assistance or collects unemployment: • Acceptable documentation includes letters, exhibits or a benefits statement from the provider that states the amount, frequency, and duration of the benefit. The servicer must determine that the income will continue for at least nine months. If the borrower has rental income, acceptable documentation includes: • Copies of all pages from the borrower's most recent two years of signed federal income tax returns and Schedule E -Supplemental Income and Loss. The monthly net rental income to be calculated for RAMP purposes equals 75 percent of the gross rent, with the remaining 25 percent considered vacancy loss and maintenance expense. A servicer must confirm that the property securing the mortgage loan is the borrower's primary residence as evidenced by the most recent signed federal income tax return (or transcript of tax return obtained from the IRS), a credit report and one other form of documentation that would supply reasonable evidence that the property is the borrower's primary residence (such as utility bills in the borrower's name). A servicer is not required to modify a mortgage loan if there is reasonable evidence indicating the borrower submitted false or misleading information or otherwise engaged in fraud in connection with the modification. Standard Modification Waterfall Servicers are required to consider a borrower for a refinance through the Hope for Homeowners program when feasible. Consideration for a Hope for Homeowners refinance should not delay eligible borrowers from receiving a modification offer and beginning the trial period. Servicers must use the modification options listed below to begin the HAMP modification and work to complete the Hope for Homeowners refinance during the trial period. Servicers must apply the modification steps enumerated below in the stated order of succession until the borrower's monthly mortgage payment ratio is reduced as close as possible to 31 percent, without going below 31 percent (the "target monthly mortgage payment ratio"). If the applicable PSA or other investor servicing agreement prohibits the servicer from taking a modification step, the servicer may seek approval for an exception. Servicers are not precluded under the HAMP from agreeing to a modification that reduces the borrower's monthly mortgage payment ratio below 31% as long as the modification otherwise complies with the HAMP requirements. Similarly and where otherwise permitted by the applicable PSA or other investor servicing contract, Servicers are not precluded under the RAMP from agreeing to a modification where the interest rate does not step up after five years, or where additional principal forbearance is substituted for extending the term as needed to achieve the target monthly mortgage payment ratio of 31%, so long as the modification otherwise complies with HAMP Supplemental Directive 09-01 Page 8 requirements. However, borrower, servicer and investor incentive payments for these modifications will be paid based on modification terms that reflect the target monthly mortgage payment ratio and standard modification terms. Note: If a borrower has an adjustable-rate mortgage (ARM) or interest-only mortgage, the existing interest rate will convert to a fixed interest rate, fully amortizing loan. Step 1: Capitalize accrued interest, out-of-pocket escrow advances to third parties, and any required escrow advances that will be paid to third parties by the servicer during the trial period and servicing advances (costs and expenses incurred in performing its servicing obligation, such as those related to preservation and protection of the security property and the enforcement of the mortgage) paid to third parties in the ordinary course of business and not retained by the servicer, if allowed by state law. The servicer should capitalize only those third party delinquency fees that are reasonable and necessary. Fees permitted by Fannie Mae and Freddie Mac for GSE loans shall be considered evidence of fees that would be reasonable for non-GSE loans. Late fees may not be capitalized and must be waived if the borrower satisfies all conditions of the Trial Period Plan. Step 2: Reduce the interest rate. If the loan is a fixed rate mortgage or an adjustable-rate mortgage, then the starting interest rate is the current interest rate. If the loan is a Reset ARM, the starting interest rate is the Reset Interest Rate. Reduce the starting interest rate in increments of .125 percent to get as close as possible to the target monthly mortgage payment ratio. The interest rate floor in all cases is 2.0 percent. - If the resulting rate is below the Interest Rate Cap, this reduced rate will be in effect for the first five years followed by annual increases of one percent per year (or such lesser amount as may be needed) until the interest rate reaches the Interest Rate Cap, at which time it will be fixed for the remaining loan term. - If the resulting rate exceeds the Interest Rate Cap, then that rate is the permanent rate. The "Interest Rate Cap" is the Freddie Mac Weekly Primary Mortgage Market Survey (PMMS) Rate for 30-year fixed rate conforming loans, rounded to the nearest 0.125 percent, as of the date that the Agreement is prepared. Step 3: If necessary, extend the term and reamortize the mortgage loan by up to 480 months from the modification effective date (i.e., the first day of the month following the end of the trial period) to achieve the target monthly mortgage payment ratio. If a term extension is not permitted under the applicable PSA or other investor servicing agreement, reamortize the mortgage loan based upon an amortization schedule of up to 480 months with a balloon payment due at maturity. Negative amortization after the effective date of the modification is prohibited. Step 4: If necessary, the servicer must provide for principal forbearance to achieve the target monthly mortgage payment ratio. The principal forbearance amount is non-interest Supplemental Directive 09-01 Page 9 bearing and non-amortizing. The amount of principal forbearance will result in a balloon payment fully due and payable upon the earliest of the borrower's transfer of the property, payoff of the interest bearing unpaid principal balance, or maturity of the mortgage loan. The modified interest bearing balance (i.e., the unpaid principal balance excluding the deferred principal balloon amount) must create a current mark-to-market LTV (current LTV based upon the new valuation) greater than or equal to 100 percent if the result of the NPV test is negative and the servicer elects to perform the modification. There is no requirement to forgive principal under the RAMP. However, servicers may forgive principal to achieve the target monthly mortgage payment ratio on a standalone basis or before any step in the standard waterfall process set forth above. If principal is forgiven, subsequent steps in the standard waterfall may not be skipped. If principal is forgiven and the interest rate is not reduced, the existing rate will be fixed and treated as the modified rate for the purposes of the Interest Rate Cap. Verifying Monthly Gross Expenses A servicer must obtain a credit report for each borrower or a joint report for a married couple who are co-borrowers to validate installment debt and other liens. In addition, a servicer must consider information concerning monthly obligations obtained from the borrower either orally or in writing. The "monthly gross expenses" equal the sum of the following monthly charges: • The monthly mortgage payment, taxes, property insurance, homeowner's or condominium association fee payments and assessments related to the property whether or not they are included in the mortgage payment. • Any mortgage insurance premiums. • Monthly payments on all closed-end subordinate mortgages. • Payments on all installment debts with more than ten months of payments remaining, including debts that are in a period of either deferment or forbearance. When payments on an installment debt are not on the credit report or are listed as deferred, the servicer must obtain documentation to support the payment amount included in the monthly debt payment. If no monthly payment is reported on a student loan that is deferred or is in forbearance, the servicer must obtain documentation verifying the proposed monthly payment amount, or use a minimum of 1.5 percent of the balance. • Monthly payment on revolving or open-end accounts, regardless of the balance. In the absence of a stated payment, the payment will be calculated by multiplying the outstanding balance by 3 percent. • Monthly payment on a Home Equity Line of Credit (HELOC) must be included in the payment ratio using the minimum monthly payment reported on the credit report. If the HELOC has a balance but no monthly payment is reported, the servicer must obtain documentation verifying the payment amount, or use a minimum of one percent of the balance. • Alimony, child support and separate maintenance payments with more than ten months of payments remaining, if supplied by the borrower. Supplemental Directive 09-01 Page 10 Car lease payments, regardless of the number of payments remaining. Aggregate negative net rental income from all investment properties owned, if supplied by the borrower. Monthly mortgage payment for second home (principal, interest, taxes and insurance and, when applicable, leasehold payments, homeowner association dues, condominium unit or cooperative unit maintenance fees (excluding unit utility charges)). Total Monthly Debt Ratio The borrower's total monthly debt ratio ("back-end ratio") is the ratio of the borrower's monthly gross expenses divided by the borrower's monthly gross income. Servicers will be required to send the Home Affordable Modification Program Counseling Letter to borrowers with apost-RAMP modification back-end ratio equal to or greater than 55 percent. The letter states the borrower must work with aHUD-approved housing counselor on a plan to reduce their total indebtedness below 55 percent. The letter also describes the availability and advantages of counseling and provides a list of local HUD- approved housing counseling agencies and directs the borrower to the appropriate HUD website where such information is located. The borrower must represent in writing in the RAMP documents that (s)he will obtain such counseling. Face-to-face counseling is encouraged; however, telephone counseling is also permitted from HUD-approved housing counselors provided it covers the same topics as face-to- face sessions. Telephone counseling sessions provide flexibility to borrowers who are unable to attend face-to-face sessions or who do not have an eligible provider within their area. A list of approved housing counseling agencies is available at http:J/www.hud.~=,ov/offices/hs~/sth/hcc/fc/ or by calling the toll-free housing counseling telephone referral service at 1-800-569-4287. A servicer must retain in its mortgage files evidence of the borrower notification. There is no charge to either borrowers or servicers for this counseling. Mortgages with No Due-on-Sale Provision If a mortgage that is not subject to a due-on-sale provision receives an RAMP, the borrower agrees that the RAMP will cancel the assumability feature of that mortgage. Escrow Accounts All of the borrower's monthly payments must include a monthly escrow amount unless prohibited by applicable law. The servicer must assume full responsibility for administering the borrower's escrow deposit account in accordance with the mortgage documents and all applicable laws and regulations. If the mortgage loan being considered for the RAMP is anon-escrowed mortgage loan, the servicer must establish an escrow deposit account prior to the beginning of the trial period. Servicers who do not Supplemental Directive 09-01 Page 11 have this capacity must implement an escrow process within six months of signing the Servicer Participation Agreement. However, the Servicer must ensure that the trial payments include escrow amounts and must place the escrow funds into a separate account identified for escrow deposits. Servicers are encouraged to perform an escrow analysis prior to establishing the trial period payment. When performing an escrow analysis, Servicers should take into consideration tax and insurance premiums that may come due during the trial period. When the borrower's escrow account does not have sufficient funds to cover an expense and the Servicer advances the funds necessary to pay an expense to a third party, the amount of the Servicer advance that is paid to a third party may be capitalized. In the event the initial escrow analysis identifies ashortage - a deficiency in the escrow deposits needed to pay all future tax and insurance payments -the Servicer must take steps to eliminate the shortage. Any actions taken by the Servicer to eliminate the escrow shortage must be in compliance with applicable laws, rules and regulations, including, but not limited to, the Real Estate Settlement Procedures Act and the Truth in Lending Act. Compliance with Applicable Laws Each Servicer (and any subservicer it uses) must be aware of, and in full compliance with, all federal, state, and local laws (including statutes, regulations, ordinances, administrative rules and orders that have the effect of law, and judicial rulings and opinions) -including, but not limited to, the following laws that apply to any of its practices related to the HAMP: • Section 5 of the Federal Trade Commission Act, which prohibits unfair or deceptive acts or practices. • The Equal Credit Opportunity Act and the Fair Housing Act, which prohibit discrimination on a prohibited basis in connection with mortgage transactions. Loan modification programs are subject to the fair lending laws, and Servicers and lenders should ensure that they do not treat a borrower less favorably than other borrowers on grounds such as race, religion, national origin, sex, marital or familial status, age, handicap, or receipt of public assistance income in connection with any loan modification. These laws also prohibit redlining. • The Real Estate Settlement Procedures Act, which imposes certain disclosure requirements and restrictions relating to transfers of the servicing of certain loans and escrow accounts. • The Fair Debt Collection Practices Act, which restricts certain abusive debt collection practices by collectors of debts, other than the creditor, owed or due to another. Supplemental Directive 09-01 Page 12 Modification Process Borrower Solicitation Servicers should follow their existing practices, including complying with any express contractual restrictions, with respect to solicitation of borrowers for modifications. A servicer may receive calls from current or delinquent borrowers directly inquiring about the availability of the RAMP. In that case, the servicer should work with the borrower to obtain the borrower's financial and hardship information and to determine if the HAMP is appropriate. If the servicer concludes a current borrower is in danger of imminent default, the servicer must consider an HAMP modification. When discussing the HAMP, the servicer should provide the borrower with information designed to help them understand the modification terms that are being offered and the modification process. Such communication should help minimize potential borrower confusion, foster good customer relations, and improve legal compliance and reduce other risks in connection with the transaction. A servicer also must provide a borrower with clear and understandable written information about the material terms, costs, and risks of the modified mortgage loan in a timely manner to enable borrowers to make informed decisions. The servicer should inform the borrower during discussions that the successful completion of a modification under the HAMP will cancel any assumption feature, variable or step-rate feature, or enhanced payment options in the borrower's existing loan, at the time the loan is modified. Servicers must have adequate staffing, resources, and facilities for receiving and processing the HAMP documents and any requested information that is submitted by borrowers. Servicers must also have procedures and systems in place to be able to respond to inquiries and complaints about the HAMP. Servicers should ensure that such inquiries and complaints are provided fair consideration, and timely and appropriate responses and resolution. Document Retention Servicers must retain all documents and information received during the process of determining borrower eligibility, including borrower income verification, total monthly mortgage payment and total monthly gross debt payment calculations, NPV calculations (assumptions, inputs and outputs), evidence of application of each step of the standard waterfall, escrow analysis, escrow advances, and escrow set-up. The Servicers must retain all documents and information related to the monthly payments during and after the trial period, as well as incentive payment calculations and such other required documents. Servicers must retain detailed records of borrower solicitations or borrower-initiated inquiries regarding the HAMP, the outcome of the evaluation for modification under the HAMP and specific justification with supporting details if the request for modification Supplemental Directive 09-01 Page 13 under the HAMP was denied. Records must also be retained to document the reason(s) for a trial modification failure. If an HAMP modification is not pursued when the NPV result is "negative," the servicer must document its consideration of other foreclosure prevention options. If a borrower under an RAMP modification loses good standing, the servicer must retain documentation of its consideration of the borrower for other loss mitigation alternatives. Servicers must retain required documents for a period of seven years from the date of the document collection. Temporary Suspension of Foreclosure Proceedings To ensure that a borrower currently at risk of foreclosure has the opportunity to apply for the HAMP, Servicers should not proceed with a foreclosure sale until the borrower has been evaluated for the program and, if eligible, an offer to participate in the RAMP has been made. Servicers must use reasonable efforts to contact borrowers facing foreclosure to determine their eligibility for the HAMP, including in-person contacts at the servicer's discretion. Servicers must not conduct foreclosure sales on loans previously referred to foreclosure or refer new loans to foreclosure during the 30-day period that the borrower has to submit documents evidencing an intent to accept the Trial Period Plan offer. Except as noted herein, any foreclosure sale will be suspended for the duration of the Trial Period Plan, including any period of time between the borrower's execution of the Trial Period Plan and the Trial Period Plan effective date. However, borrowers in Georgia, Hawaii, Missouri, and Virginia will be considered to have failed the trial period if they are not current under the terms of the Trial Period Plan as of the date that the foreclosure sale is scheduled. Accordingly, Servicers of HAMP loans secured by properties in these states may proceed with the foreclosure sale if the borrower has not made the trial period payments required to be made through the end of the month preceding the month in which the foreclosure sale is scheduled to occur. Mortgage Insurer Approval If applicable, a servicer must obtain mortgage insurer approval for HAMP modifications. Servicers should consult their mortgage insurance providers for specific processes related to the reporting of modified terms, payment of premiums, payment of claims, and other operational matters in connection with mortgage loans modified under the RAMP. Executing the RAMP Documents Servicers must use atwo-step process for HAMP modifications. Step one involves providing a Trial Period Plan outlining the terms of the trial period, and step two involves providing the borrower with an Agreement that outlines the terms of the final modification. Supplemental Directive 09-01 Page 14 In step one, the servicer should instruct the borrower to return the signed Trial Period Plan, together with a signed Hardship Affidavit and income verification documents (if not previously obtained from the borrower), and the first trial period payment (when not using automated drafting arrangements), to the servicer within 30 calendar days after the Trial Period Plan is sent by the servicer. The servicer is encouraged to contact the borrower before the expiration of the 30-day period if the borrower has not yet responded to encourage submission of the material. The servicer may, in its discretion, consider the offer of a Trial Period Plan to have expired at the end of 60 days if the borrower has not submitted both an executed Trial Period Plan and complete documentation as required under the Trial Period Plan. If the borrower's submission is incomplete, the servicer should work with the borrower to complete the Trial Period Plan submission. Note: The borrower is not required to have the Hardship Affidavit notarized. Upon receipt of the Trial Period Plan from the borrower, the servicer must confirm that the borrower meets the underwriting and eligibility criteria. Once the servicer makes this determination and has received good funds for the first month's trial payment, the servicer should sign and immediately return an executed copy of the Trial Period Plan to the borrower. Payments made by the borrower under the terms of the Trial Period Plan will count toward successful completion irrespective of the date of the executed copy of the Trial Period Plan. If the servicer determines that the borrower does not meet the underwriting and eligibility standards of the HAMP after the borrower has submitted a signed Trial Period Plan to the servicer, the servicer should promptly communicate that determination to the borrower in writing and consider the borrower for another foreclosure prevention alternative. In step two, servicers must calculate the terms of the modification using verified income, taking into consideration amounts to be capitalized during the trial period. servicers are encouraged to wait to send the Agreement to the borrower for execution until after receipt of the second to the last payment under the trial period. Note: the borrower is not required to have the Agreement notarized. Servicers are reminded that all RAMP documentation must be signed by an authorized representative of the servicer and reflect the actual date of signature by the servicer's representative. Acceptable Revisions to HAMP Documents Servicers are strongly encouraged to use the HAMP documents available through www.tinancialstability.~ov. Should a servicer decide to revise the HAMP documents or draft its own HAMP documents, it must obtain prior written approval from Treasury or Fannie Mae with the exception of the following circumstances: The servicer must revise the HAMP documents as necessary to comply with Federal, State and local law. For example, in the event that the HAMP results in a Supplemental Directive 09-01 Page 15 principal forbearance, servicers are obligated to modify the uniform instrument to comply with laws and regulations governing balloon disclosures. • The servicer may include, as necessary, conditional language in RAMP offers and modification agreements indicating that the RAMP will not be implemented unless the servicer receives an acceptable title endorsement, or similar title insurance product, or subordination agreements from other existing lien holders, as necessary, to ensure that the modified mortgage loan retains its first lien position and is fully enforceable. • If the borrower previously received a Chapter 7 bankruptcy discharge but did not reaffirm the mortgage debt under applicable law, the following language must be inserted in Section 1 of the Trial Period Plan and Section 1 of the Agreement: "I was discharged in a Chapter 7 bankruptcy proceeding subsequent to the execution of the Loan Documents. Based on this representation, Lender agrees that I will not have personal liability on the debt pursuant to this Agreement." • The servicer may include language in the RAMP cover letter providing instructions for borrowers who elect to use an automated payment method to make the trial period payments. Unless a borrower or co-borrower is deceased or a borrower and a co-borrower are divorced, all parties who signed the original loan documents or their duly authorized representative(s) must execute the RAMP documents. If a borrower and a co-borrower are divorced and the property has been transferred to one spouse in the divorce decree, the spouse who no longer has an interest in the property is not required to execute the RAMP documents. servicers may evaluate requests on a case-by-case basis when the borrower is unable to sign due to circumstances such as mental incapacity, military deployment, etc. Furthermore, a borrower may elect to add a new co-borrower. Use of Electronic Records Electronic records for RAMP are acceptable as long as the electronic record complies with applicable law. Assignment to MERS If the original mortgage loan was registered with Mortgage Electronic Registration Systems, Inc. (MERS) and the originator elected to name MERS as the original mortgagee of record, solely as nominee for the lender named in the security instrument and the note, the servicer MUST make the following changes to the Agreement: (a) Insert a new definition under the "Property Address" definition on page I, which reads as follows: "MERS" is Mortgage Electronic Registration Systems, Inc. MERS is a separate corporation that is acting solely as a nominee for (ender and lender's successors and assigns. MERS is the mortgagee under the Mortgage. MERS is organized and existing Supplemental Directive 09-O1 Page 16 under the laws of Delaware, and has an address and telephone number of P.O. Box 2026, Flint, MI 48501-2026, (888) 679-HERS. (b) Add as section 4.I.: That MERS holds only legal title to the interests granted by the borrower in the mortgage, but, if necessary to comply with law or custom, MERS (as nominee for lender and lender's successors and assigns) has the right: to exercise any or all of those interests, including, but not limited to, the right to foreclose and sell the Property; and to take any action required of lender including, but not limited to, releasing and canceling the mortgage loan. (c) MERS must be added to the signature lines at the end of the Agreement, as follows: Mortgage Electronic Registration Systems, Inc. -Nominee for Lender The servicer may execute the Agreement on behalf of MERS and, if applicable, submit it for recordation. Trial Payment Period Servicers may use recent verbal financial information to prepare and offer a Trial Period Plan. Servicers are not required to verify financial information prior to the effective date of the trial period. The servicer must service the mortgage loan during the trial period in the same manner as it would service a loan in forbearance. The trial period is three months in duration (or longer if necessary to comply with applicable contractual obligations). The borrower must be current under the terms of the Trial Period Plan at the end of the trial period to receive a permanent loan modification. Current in this context is defined as the borrower having made all required trial period payments no later than 30 days from the date the final payment is due. The effective date of the trial period will be set forth in the Trial Period Plan. In most cases, the effective date is the first day of the month following the servicer's mailing of the offer for the Trial Period Plan. The trial period extends for two (or more if necessary to comply with applicable contractual obligations) additional payments after the effective date. Servicers are encouraged to require automated payment methods, such as automatic payment drafting. If automatic payment drafting is required, it must be used by all RAMP borrowers, unless a borrower opts out. If the verified income evidenced by the borrower's documentation exceeds the initial income information used by the servicer to place the borrower in the trial period by more Supplemental Directive 09-01 Page 17 than 25 percent, the borrower must be reevaluated based on the program eligibility and underwriting requirements. If this reevaluation determines that the borrower is still eligible, new documents must be prepared and the borrower must restart the trial period. If the verified income evidenced by the borrower's documentation is less than the initial income information used by the servicer to place the borrower in the trial period, or if the verified income exceeds the initial income information by 25 percent or less, and the borrower is still eligible, then the trial period will not restart and the trial period payments will not change; provided, that verified income will be used to calculate the monthly mortgage payment under the Agreement. (If, based on verified income the result of the NPV test is "negative" for modification, the servicer is not obligated to perform the modification.) However, if the servicer determines the borrower is not eligible for the RAMP based on verified income, the servicer must notify the borrower of that determination and that any trial period payments made by the borrower will be applied to the mortgage loan in accordance with the borrower's current loan documents. If a servicer has information that the borrower does not meet all of the eligibility criteria for the HAMP (e.g., because the borrower has moved out of the house) the servicer should explore other foreclosure prevention alternatives prior to resuming or initiating foreclosure. Note that under the terms of the Agreement, trial payments should be applied when they equal a full contractual payment (determined as of the time the HAMP is offered). If the borrower complies with the terms and conditions of the Trial Period Plan, the loan modification will become effective on the first day of the month following the trial period as specified in the Trial Period Plan. However, because the monthly payment under the Agreement will be based on verified income documentation, the monthly payment due under the Agreement may differ from the payment amount due under the Trial Period Plan. Use of Suspense Accounts and Application of Payments If permitted by the applicable loan documents, servicers may accept and hold as "unapplied funds" (held in a T&I custodial account) amounts received which do not constitute a full monthly, contractual principal, interest, tax and insurance (PITI) payment. However, when the total of the reduced payments held as "unapplied funds" is equal to a full PITI payment, the servicer is required to apply all full payments to the mortgage loan. Any unapplied funds remaining at the end of the trial payment period that do not constitute a full monthly, contractual principal, interest, tax and insurance payment should be applied to reduce any amounts that would otherwise be capitalized onto the principal balance. Supplemental Directive 09-01 Page 18 If a principal curtailment is received on a loan that has a principal forbearance, servicers are instructed to apply the principal curtailment to the interest bearing UPB. If, however, the principal curtailment amount is greater than or equal to the interest bearing UPB, then the curtailment should be applied to the principal forbearance portion. If the curtailment satisfies the principal forbearance portion, any remaining funds should then be applied to the interest bearing UPB. Recording the Modification For all mortgage loans that are modified pursuant to the HAMP, the servicer must follow investor guidance with respect to ensuring that the modified mortgage loan retains its first lien position and is fully enforceable. Monthly Statements For modifications that include principal forbearance, servicers are encouraged to include the amount of the gross UPB on the borrower's monthly payment statement. In addition, the borrower should receive information on a monthly basis regarding the accrual of "pay for performance" principal balance reduction payments. Redefault and Loss of Good Standing If, following a successful trial period, a borrower defaults on a loan modification executed under the HAMP (three monthly payments are due and unpaid on the last day of the third month), the loan is no longer considered to be in "good standing." Once lost, good standing cannot be restored even if the borrower subsequently cures the default. A loan that is not in good standing is not eligible to receive borrower, servicer or investor incentives and reimbursements and these payments will no longer accrue for that mortgage. Further, the mortgage is not eligible for another HAMP modification. In the event a borrower defaults, the servicer must work with the borrower to cure the modified loan, or if that is not feasible, evaluate the borrower for any other available loss mitigation alternatives prior to commencing foreclosure proceedings. The servicer must retain documentation of its consideration of the borrower for other loss mitigation alternatives. Reportin>s Requirements Each servicer will be required to register with Fannie Mae to participate in the HAMP. Fannie Mae will provide an HAMP Registration form to facilitate registration. Additionally, servicers will be required to provide periodic HAMP loan level data to Fannie Mae. The data must be accurate, complete, and in agreement with the servicer's records. Data should be reported by a servicer at the start of the modification trial period and during the modification trial period, for loan set up of the approved modification, and Supplemental Directive 09-01 Page 19 monthly after the modification is set up on Fannie Mae's system. servicers will be required to submit three separate data files as described below. Note: The following data files can be delivered through a data collection tool on the servicer web portal available through www.tinancialstabilitv.gov. Detailed guidelines for submitting data files are available at the servicer web portal. For those servicers who cannot use this process, an alternate process to submit data via a spreadsheet will be made available. More information on the alternative process for submitting data in a spreadsheet will be provided in the future. Trial Period Servicers will be required to provide loan level data in order to establish loans for processing during the HAMP trial period. See Exhibit A for trial period set up attributes. In addition, servicers will be required to report activity during the RAMP trial period in order to substantiate the receipt of proceeds during the trial period and to record modification details. See Exhibit B for trial period reporting attributes. Loan Setup A one time loan set up is required to establish the approved modified RAMP loan on Fannie Mae's system. The file layout is the same that is used for establishing loans for processing during the trial period. See Exhibit A for loan set up attributes. servicers are required to provide the set up file the business day after the modification closes. The set up file should reflect the status of the loan after the final trial period payment is applied. The set up file will contain data for the current reporting period (e.g., prior month balances). Monthly Loan Activity Reporting The month after the loan set up file is provided, servicers must begin reporting activity on all RAMP loans on a monthly basis (e.g., loan set up file provided in July, the first loan activity report is due in August for July activity). See Exhibit C for monthly reporting attributes. The RAMP loan activity report (LAR) is due by the 4th business day each month. Servicers will have until the 15th calendar day of each month to clear up any edits and have a final LAR reported to Fannie Mae. The Fannie Mae system will validate that the borrower payment has been made as expected and that the last paid installment (LPI) date is current before accruing the appropriate monthly compensation due. If a loan becomes past due (the LPI date does not advance), the monthly compensation on that loan will not be accrued. If the loan is brought current, compensation will not be caught up (e.g., if a loan was two months past due, and then the borrower makes the Supplemental Directive 09-01 Page 20 payments and brings the loan current, the annual compensation provided would be for ten months. The two months of compensation associated with the period of delinquency is not recoverable). Additional Data Requirements Additional data elements must be collected and reported as specified in Exhibit D. Some of these elements must be collected for all completed modifications regardless of the date of completion; guidance for collecting these elements will be forthcoming shortly. The requirement to collect these elements for trial modifications and for loans evaluated for a modification will be phased in as specified in Exhibit D. Reporting to Mortgage Insurers Servicers must maintain their mortgage insurance processes and comply with all reporting required by the mortgage insurer for loans modified under the HAMP. Servicers should consult with the mortgage insurer for specific processes related to the reporting of modified terms, payment of premiums, payment of claims, and other operational matters in connection with mortgage loans modified under the RAMP. Servicers are required to report successful RAMP modifications and the terms of those modifications to the appropriate mortgage insurers, if applicable, within 30 days following the end of the trial period and in accordance with procedures that currently exist or may be agreed to between servicers and the mortgage insurers. Servicers must include the mortgage insurance premium in the borrower's modified payment, and must ensure that any existing mortgage insurance is maintained. Among other things, the servicer must ensure that the mortgage insurance premium is paid. In addition, servicers must adapt their systems to ensure proper reporting of modified loan terms and avoid impairing coverage for any existing mortgage insurance. For example, in the event that the modification includes principal forbearance, servicers must continue to pay the correct mortgage insurance premiums based on the gross UPB, including any principal forbearance amount, must include the gross UPB in their delinquency reporting to the mortgage insurer, and must ensure any principal forbearance does not erroneously trigger automatic mortgage insurance cancellation or termination. Transfers of Servicing When a transfer of servicing includes mortgages modified under the RAMP, the transferor servicer must provide special notification to the transferee servicer. Specifically, the transferor servicer must advise the transferee servicer that loans modified under the HAMP are part of the portfolio being transferred and must confirm that the transferee servicer is aware of the special requirements for these loans, and agrees to assume the additional responsibilities associated with servicing them. A required form of assignment and assumption agreement must be used and is a part of the servicer Participation Agreement. Supplemental Directive 09-01 Page 21 Credit Bureau Reporting The servicer should continue to report a "full-file" status report to the four major credit repositories for each loan under the HAMP in accordance with the Fair Credit Reporting Act and credit bureau requirements as provided by the Consumer Data Industry Association (the "CDIA") on the basis of the following: (i) for borrowers who are current when they enter the trial period, the servicer should report the borrower current but on a modified payment if the borrower makes timely payments by the 30th day of each trial period month at the modified amount during the trial period, as well as report the modification when completed, and (ii) for borrowers who are delinquent when they enter the trial period, the servicer should continue to report in such a manner that accurately reflects the borrower's delinquency and workout status following usual and customary reporting standards, as well as report the modification when completed. More detailed guidance on these reporting requirements will be published by the CDIA. "Full-file" reporting means that the servicer must describe the exact status of each mortgage it is servicing as of the last business day of each month. Fees and Compensation Late Fees All late charges, penalties, stop-payment fees, or similar fees must be waived upon successful completion of the trial period. Administrative Costs Servicers may not charge the borrower to cover the administrative processing costs incurred in connection with a HAMP. The servicer must pay any actual out-of-pocket expenses such as any required notary fees, recordation fees, title costs, property valuation fees, credit report fees, or other allowable and documented expenses. Servicers will not be reimbursed for the cost of the credit report(s). Incentive Compensation No incentives of any kind will be paid if (i) the servicer has not executed the servicer Participation Agreement, or (ii) the borrower's monthly mortgage payment ratio starts below 31 percent prior to the implementation of the HAMP. The calculation and payment of all incentive compensation will be based strictly on the borrower's verified income. Each servicer must promptly apply or remit, as applicable, all borrower and investor compensation it receives with respect to any modified loan. With respect to payment of any incentive that is predicated on a six percent reduction in the borrower's monthly mortgage payment, the reduction will be calculated by comparing the monthly mortgage payment used to determine eligibility (adjusted as applicable to Supplemental Directive 09-01 Page 22 include property taxes, hazard insurance, flood insurance, condominium association fees and homeowner's association fees) and the borrower's payment under HAMP. The amount of funds available to pay servicer, borrower and investor compensation in connection with each servicer's modifications will be capped pursuant to each servicer's servicer Participation Agreement (Program Participation Cap). Treasury will establish each servicer's initial Program Participation Cap by estimating the number of HAMP modifications expected to be performed by each servicer during the term of the RAMP. The Program Participation Cap could be adjusted based on Treasury's full book analysis of the servicer's loans. The funds remaining available for a servicer's modifications under that servicer's Program Participation Cap will be reduced by the maximum amount of compensation payments potentially payable with respect to each loan modification upon entering into a trial period. In the event the compensation actually paid with respect to a loan modification is less than the maximum amount of compensation payments potentially payable, the funds remaining available for a servicer's modifications under the HAMP will be increased by the difference between such amounts. Treasury may, from time to time and in its sole discretion, revise a servicer's Program Participation Cap. Fannie Mae will provide written notification to a servicer of all changes made to the servicer's Program Participation Cap. Once a servicer's Program Participation Cap is reached, a servicer must not enter into any agreements with borrowers intended to result in new loan modifications, and no payments will be made with respect to any new loan modifications. servicer Incentive Compensation A servicer will receive compensation of $1,000 for each completed modification under the HAMP. In addition, if a borrower was current under the original mortgage loan, a servicer will receive an additional compensation amount of $500. All such servicer incentive compensation shall be earned and payable once the borrower successfully completes the trial payment period, provided that the servicer has signed and delivered to Fannie Mae a servicer Participation Agreement, any related documentation and any required servicer or loan set up data prior to the effective date of the loan modification. If a particular borrower's monthly mortgage payment (principal, interest, taxes, all related property insurance and homeowner's or condominium association fees but excluding mortgage insurance) is reduced through the HAMP by six percent or more, a servicer will also receive an annual "pay for success" fee for a period of three years. The fee will be equal to the lesser of: (i) $1,000 ($83.33/month), or (ii) one-half of the reduction in the borrower's annualized monthly payment. The "pay for success" fee will be payable annually for each of the first three years after the anniversary of the month in which a Trial Period Plan was executed. If the loan ceases to be in good standing, the servicer will cease to be eligible for any further incentive payments after that time, even if the borrower subsequently cures his or her delinquency. Supplemental Directive 09-01 Page 23 Borrower's Incentive Compensation To provide an additional incentive for borrowers to keep their modified loan current, borrowers whose monthly mortgage payment (principal, interest, taxes, all related property insurance and homeowner's or condominium association fees but excluding mortgage insurance) is reduced through the RAMP by six percent or more and who make timely monthly payments will earn an annual "pay for performance" principal balance reduction payment equal to the lesser of (i) $1,000 ($83.33/month), or (ii) one-half of the reduction in the borrower's annualized monthly payment for each month a timely payment is made. A borrower can earn the right to receive a "pay for performance" principal balance reduction payment for payments made during the first five years following execution of the Agreement provided the loan continues to be in good standing as of the date the payment is made. The "pay for performance" principal balance reduction payment will accrue monthly but will be applied annually for each of the five years in which this incentive payment accrues, prior to the first payment due date after the anniversary of the month in which the Trial Period Plan was executed. This payment will be paid to the mortgage servicer to be applied first towards reducing the interest bearing UPB on the mortgage loan and then to any principal forbearance amount (if applicable). Any applicable prepayment penalties on partial principal prepayments made by the government must be waived. Borrower incentive payments do not accrue during the Trial Period; however, on the first month of the modification, the borrower will accrue incentive payments equal to the number of months in the trial period. If and when the loan ceases to be in good standing, the borrower will cease to be eligible for any further incentive payments after that time, even if the borrower subsequently cures his or her delinquency. The borrower will lose his or her right to any accrued incentive compensation when the loan ceases to be in good standing. Investor Payment Reduction Cost Share and Up Front Incentives If the target monthly mortgage payment ratio is achieved, investors in Non-GSE Mortgages are entitled to payment reduction cost share compensation. This compensation equals one-half of the dollar difference between the borrower's monthly payment under the modification at the target monthly mortgage payment ratio and the lesser of (i) what the borrower's monthly payment would be at a 38 percent monthly mortgage payment ratio; or (ii) the borrower's pre-modification monthly payment. Payment reduction cost share compensation shall accrue monthly as the borrower makes each payment so long as the loan is in good standing as defined in these guidelines. This compensation will be provided for up to five years or until the loan is paid off, whichever is earlier. Additionally, investors will receive aone-time incentive of $1,500 for each Agreement executed with a borrower who was current prior to the start of the Trial Period Plan. The one-time incentive is conditional upon at least a six percent reduction in the borrower's monthly mortgage payment. Supplemental Directive 09-01 Page 24 Neither the payment reduction share nor the up-front incentive shall be payable if the Trial Period Plan is not successfully completed. Compliance Servicers must comply with the RAMP requirements and must document the execution of loan evaluation, loan modification and accounting processes. Servicers must develop and execute a quality assurance program that includes either a statistically based (with a 95 percent confidence level) or a ten percent stratified sample of loans modified, drawn within 30-45 days of final modification and reported on within 30-45 days of review. In addition, a trending analysis must be performed on a rolling 12-month basis. Treasury has selected Freddie Mac to serve as its compliance agent for the HAMP. In its role as compliance agent, Freddie Mac will utilize Freddie Mac employees and contractors to conduct independent compliance assessments. In addition, loan level data will be reviewed for eligibility and fraud. The scope of the assessments will include, among other things, an evaluation of documented evidence to confirm adherence (e.g., accuracy and timeliness) to HAMP requirements with respect to the following: • Evaluation of Borrower and Property Eligibility • Compliance with Underwriting Guidelines • Execution of NPV/Waterfall processes • Completion of Borrower Incentive Payments • Investor Subsidy Calculations • Data Integrity The review will also evaluate the effectiveness of the servicer's quality assurance program; such evaluation will include, without limitation, the timing and size of the sample selection, the scope of the quality assurance reviews, and the reporting and remediation process. There will be two types of compliance assessments: on-site and remote. Both on-site and remote reviews will consist of the following activities (among others): notification, scheduling, self assessments, documentation submission, interviews, file reviews, and reporting. For on-site reviews, Freddie Mac will strive to provide the servicer with (i) a 30-day advance notification of a pending review and (ii) subsequent confirmation of the dates of the review. However, Freddie Mac reserves the right to arrive at the servicer's site unannounced. Freddie Mac will request the servicer to make available documentation, including, without limitation, policies and procedures, management reports, loan files and a risk control self assessment ready for review. Additionally, Freddie Mac may request additional loan files during the review. Interviews will usually be conducted in-person. Supplemental Directive 09-01 Page 25 During the review window, Freddie Mac will review loan files and other requested documentation to evaluate compliance with RAMP terms. Upon the completion of the review, Freddie Mac will conduct an exit interview with the servicer to discuss preliminary assessment results. For remote reviews, Freddie Mac will request the servicer to send documentation, including, without limitation, policies and procedures, management reports, loan files and a risk control self assessment within 30 days of the request. In addition, time will be scheduled for phone interviews, including a results summary call after the compliance review is completed to discuss preliminary results. The targeted time frame for publishing the servicer assessment report is 30 days after the completion of the review. Treasury will receive a copy of the report five business days prior to the release of the report to the servicer. There will be an issue/resolution appeal process for servicer assessments. Servicers will be able to submit concerns or disputes to an independent quality assurance team within Freddie Mac. A draft rating and implication methodology for the compliance assessments will be published in a subsequent Supplemental Directive and servicer feedback will be solicited prior to the finalization of the methodology. Supplemental Directive 09-O1 Page 26 Exhibit A: RAMP Trial Modification and Official Modification Loan Setup Data Elements The following data elements are necessary for the RAMP Loan Setup for Trial Modification and Official Modification transactions. Loan Setup for Official TrialPeriod 71Todification Allownble Mandatory I htaudatorv / Numc Definition Uala Tv ~'alucs Conditional Conditional GSE Servicer The Fannie Mae or Freddie Mac unique Servicer Number identifier. Text (30) C C Servicer Loan The unique (for the lender) identifier assigned to the Number loan by the -ender that is servicing the loan. Text (30) M M RAMP Servicer A unique identifier assigned to each Servicer that is Text (30) M M Number artici atin in the HAMP ro am. GSE Loan A unique number assigned to each -oan by a GSE Number (Fannie or Freddie) Text (30) C C This is the CUSIP associated with the security. A Underlying unique identification number assigned to a security Trust [dentifier by CUSP (Committee on Uniform Security Text (9) C C Identification Procedures for tradin . HMPI - HMP Delinquent, HMP2 - HMP Imminent Default HMP3 - Deed- Program Type/ Anew program type that will identify campaign in-lieu Campaign ID q'pes. The unique identifier of a Loan Workout Text (14) HMP4 -Deed- M M Campaign. in-lieu with Jr. Lien HMPS -Short Sale HMP6 -Short Sale With Jr. Lien 1 -Fannie Mae 2 -Freddie Mac Numeric 3 -Private 4 - InvestorCode Owner of the mortgage. Portfolio M M (4 0) 5-GNMA6- FHLMC Borcower First Name First Name of the Borrower of record Text (100) M M Borrower Last The last name of the Borzower. This is also known Name as the family name or surname. Text (100) M M Borzower Social Security The Social Security Number of the borcower Numeric (9) M M Number Co-Borrower First Name First Name of the co-borcower of record Text (100) C C Supplemental Directive 09-01 Page 27 Loan SetupYor Official Trial PeHod . ~ 34totjification Allowable Mandatory! Maud~tory/ Name Definition i}ata T Values Conditional Conditional Co-Borrower Last Name Last Name of the co- borrower of record Text (100) C C Co-Borrower Social Security The Social Security Number of the Co-Borrower Numeric (9) O O Number Borrower Execution This is the date that the borrower signs the initial Date documentation for a modification (CCYY-MM- M M Date . DD) 1-Trial 2-Borrower Disqualified Submission Status ofloan data being submitted Numeric 3-Official M M Status (4,0) 4-Foreclosure Mitigation 5-Cancel Date of The date on which the original loan funding was Date Original Note dispersed to the borrower(s). (CCYY-MM- M M DD The total principal amount outstanding as of the end Unpaid of the month. The UPB should not reflect any Principal accounting based write-downs and should only be Currency Balance before reduced to zero when the loan has been liquidated - (20,2) M M modification either paid-in-full, charged-off, REO sold or Service transferred before modification 1 -FHA -Loans insured by the Federal Housing Administration 2 - VA -Loans insured by the Department of Veteran's Affairs, 3 -Conventional with PMI - Non- Loan Mort a e The code that specifies the type of mortgage being Numeric government i d g g T e C d applied for or that has been granted. (4 0) nsure M M yp o e mortgages insured by a private (non- government) insurer. 4 -Conventional w/o PMI - Mortgages with neither government nor private mortgage insurance. Las[ Paid Installment Date Date before The due date of the last paid installment of the loan. (CCYV-MM- M M modification DD) First Lien Indicator Indicates if loan is first lien. Boolean True/False M M The date that the mortgage was referred to an attorney for the purpose of initiating foreclosure Foreclosure proceedings. This date should reflect the referral Date Referral Date date of currently active foreclosure process. Loans (CCYY-MM- O O cured from foreclosure should not have a referral DD) date. Supplemental Directive 09-01 Page 28 Loan Setup for Officioi Tel Period A1odification Albw~able i`faodatory I Mandatory / Nume Aefiaitlun D~tu T Values Conditio~pal Cooditio~kal Projected Foreclosure projected date for foreclosure sale ofsubject Date Sale Date proPettY' (CCYY-MM- DD) O O 1 -Death of borzower, 2 - ^Iness of principal borrower, 3 - Illness of borrower family member, 4 - Death of borrower family member, 5 - Martial difficulties, 6 - Curtailment of income, 7 - Excessive obligation, 8 - Abandonment of property, 9 - Distant employment transfer, 10 - Property problem, l l - Hardship Identifies the reason for the borrower's hardship on Numeric Inability to sell Reason Code their mortgage payment obligations. (4,0) property, l2 - M M [nability to rent property, 13 - Military service, 14 -Other, 15 - Unemployment, 16 -Business failure, l 7 - Casualty Loss, 18 -Energy environment costs, 19 - Servicing problems, 20 - Payment adjustment, 21 - Paymentdispute, 22 - Transfer of ownership pending, 23 - Fraud, 24 - Unable to contact borrower,25 - Incarceration Monthly Gross Total monthly income in dollars for all borrowers on Currency Income the loan. This is the gross income for all borrowers. (20,2) M M Monthly Debt Payments Total amount of monthly debt payments excluding excluding principal, Interest, Taxes, Insurance and Association Currency 20 2 M M PITIA Dues(PITIA) , ) ( Date NPV Date Net Present Value -calculation date (CCYY-MM- M M DD Supplemental Directive 09-01 Page 29 Loan Setup for O(ffcfal Trial Period Modification Piame Detnition Date T Albwgble Values Mandatoryl Conditional Mandatory/ Conditional NPV Model su lt A mount Net Present Value amount generated from the model Currency N l d P e More modification ( ) 20,2 M M NPV Model ount I Net Present Value amount generated from the model Currency Post Mod after modification ( ) 20,2 M M Represents the number of months on which Amortization installment payments are based. Example: Balloon Term before loans have a seven year life (Loan Term = 84) but a Numeric modification 30 year amortization period (Amortization Term = (4,0) M M 360). Installment payments are determined based on the 360 month term. Interest Rate The interest rate in the month prior to loan before modification. Please report as rounded to nearest Numeric M M modification 8th. e. .4.125 (6 4) Principal and Interest Payment The scheduled principal and interest amount in the Currency before month prior to loan modification. (20,2) M M modification The escrow amount in the month prior to loan modification. The amount of money that is collected from [added on to] the regular monthly mortgage Escrow payment to cover periodic payments of property Payment taxes, private mortgage insurance and hazard Currency before insurance by the servicer on behalf of the (20,2) C C modification mortgagee. Depending on the mortgage terms, this amount may or may not be collected. Generally, if the down payment is less than 20%, then these amounts are collected b the servicer. Association Dues/ Fees Existing monthly payment for association dues/fees Currency before before modification (20,2) C C modification Principal Payment If borrower has contributed any cash or amounts in Currency Owed or Not suspense (20 2) C C Re rted Other Contributions If there are any amounts contributed by the Currency C C borrower due to Hazard Claims (20,2) Attomey Fees Estimated legal fee not in escrow for advances Currency Not in Escrow capitalization and liquidation expense calculation (20,2) C C Escrow Shortage for Any Escrow advance amounts to be capitalized. Currency C C Advances (20,2) Other Other advances for advances capitalization other Advances than escrow. Example: Attomey fees, Servicing Currency C C Fees, etc. (20 2) Borrower If the borrower is contributing any amounts, they Curzency Contributions must be reported here (2p 2) C C servicer sign otTatthe officer level for the loan Modified Loan modification. This is the date the servicer's ofFicer Term -Officer approved the loan modification. This column will be Date Signature Date populated for modification cases that need (CCYV-MM- DD C C reclassification. There is no conversion needed for ) existin cases Supplemental Directive 09-01 Page 30 I,uan Setup for Official - Trial Period 1ltudification Narl~e Detmition DaWTv Albwabk ~'alne~ Mandatory/ Cuudtional Mpudatory / Cooditionat Disbursement If there are any Forgiven disbursement for advances Currency Forgiven capitalization (20,2) C C Monthly The dollar amount per month of the borrower's Housing present housing expense .May be used for their Expense primary or non-primary residence. This must be Currency M M before Principal, Interest, Taxes, Insurance and Association (20 2) modification Dues (PITTA). Delinquent interest for interest capitalization. [t is Delinquent the amount of delinquent interest from the Currency Interest delinquent loan's LPI date to the workout execution (20,2) M M date. Interest Owed If there is Interest owed/received but not reported or Payment for interest capitalization, this field must be Currency C C Not Reported populated. (20 2) Servicing Fee Percent after percentage of servicing Fee after loan modification ( Numeric modification e.g.0.25) (4,2) M M 1-ARM,2- Fixed Rate, 3 - Step Rate, 4 - One Step Variable, 5 - Two Step Variable, 6 - Three Step Variable, 7 -Four Step Variable, 8 - Five Step Variable,9 -Six Product before The mortgage product of the loan before the Numeric Step Variable, 10 Modification modification. (4 0) -Seven Step M M Variable,l l - Eight Step Variable, 12 - Nine Step Variable, l3 - Ten Step Variable, 14 - Eleven Step Variable, 15 - Twelve Step Variable, 16 - Thirteen Step Variable, 17 - Fourteen The date on which the mortgage obligation is scheduled to be paid off, according to the mortgage Maturity Date note. Maturity Date is commonly called Balloon Date before Date for balloon loans, for which scheduled (CCYY-MM- M M Modification amortization does not pay off the balance of the DD) loan, so that there is a final, large "balloon" payment at the end. Supplemental Directive 09-01 Page 31 I,oao Situp for Official Trial Period Atodincation Allowable titandatory I Mandatory / Namc itlon Data 'f ~'alue~ Condiloual Caoditional The number of months until the loan will be paid off, assuming that scheduled payments are made. This will equal lesser of 1. The number of months Remaining until the actual balance of the loan will amortize to Term before zero; or 2. the number of months difference Numeric Modification between the Loan Extended Term and the number of (4,0) M M payments made by the borrower, where number of payments made by the borrower is derived by: Actual Last Paid Installment Date -First Installment Due Date - 1 in months . Front Ratio The refreshed Front-end DTI (Principal, Interest, before Taxes, Insurance and Association Dues (PITTA)) Numeric M M Modification housin ratio. (4 2) Percentage of borrower's PITTA plus debts to Back Ratio income ratio. Borrower Total Debt To Income before Ratio Percent. The monthly expenses divided by Numeric M M Modification the total monthly income for the Borrower (e.g. (4,2) 30.25) Principal and Interest Principal and Interest payable fora 31 % Debt to Currency Payment at Income ratio (20,2) M M 31 % DT[ Principal and Interest Principal and Interest payable fora 38% Debt to Currency Payment at Income ratio (2p,2) M M 38% DTI Property - Number of Number of units in subject property (Valid values Numeric Units are 1, 2, 3 or 4) (q 0 ) M M Property - Street Address The street address of the subject property Text (100) M M Property-City The name of the city where the subject property is Text (100) M M located Property - The Z-character postal abbreviation of the state State , province, or region of the subject property. Text (2) M M The code designated by the postal service to direct Property -Zip the delivery of physical mail or which corresponds Code ~ a physical location. [n the USA, this can take Text (9) M M either a 5 digit form (ZIP Code) or a 9-digit form ZIP+4. I -Full appraisal -Prepared by a certified appraiser; 2 - Limited appraisal - Prepared by a certified Pro rt ~ y appraiser; 3 - Valuation - Type of value analysis. Numeric Broker Price M M Method (4,0) Opinion "BPO" -Prepared by a real estate broker or agent; 4 - Desktop Valuation - Prepared by bank employee; 5 - Automated Valuation Model Supplemental Directive 09-01 Page 32 -,oau Sctup fur Official Trial Period Atudification Alloffahle bhudatory! ltaudatory/ Nagre De(utition Data T ~ Values C:oedltional Cortditional "AVM" 6- Automated Valuation Model "AVM" -Other Property Date Valuation - Date of the property value analysis (CCYY-MM- M M Date DD) Property Valuation - As property as-is value determined by the property Currency M Is Value valuation (20,2) M I -Excellent Property 2 -Good, Condition A code denoting the condition of the subject Numeric 3 - Fair M M Code property. (4,0) 4 -Poor 5 -Condemned 6 - Inaccessible 1- Vacant 2 -Borrower Occupied Pr°PertY Occupancy A code identifying the occupancy by the borrower Numeric 3 -Tenant Occupied M M Status Code of the subject property. (4,0) 4 -Unknown 5 -Occupied by Unknown I -Principal Property Residence Usage Type A code identifying the intended use by the borrower Numeric 2 -Second or M M Code of the property. (4,0) Vacation Home 3 -Investment Pro Modification Date Effective Date The date on which the loan terms will be modified. (CCYY-MM- M M DD 1-ARM, 2 - Fixed Rate, 3 - Step Rate, 4 - One Step Variable, 5 - Two Step Variable, 6 - Three Step Variable, 7 -Four Step Variable, 8 - Five Step Variable,9 -Six Product After The mortgage product of the loan, after the Numeric Step Variable, 10 Modification modification (Fixed or Step). (4 0) -Seven Step M M Variable,l i - Eight Step Variable, 12 - Nine Step Variable,l3 - Ten Step Variable, 14 - Eleven Step Variable, 15 - Twelve Step Variable, 16 - Thirteen Step Variable, 17 - Fourteen Supplemental Directive 09-O1 Page 33 Loan Setup for OfIIciel Trial Period Modification Allowabld Mandatory / btyndatory / Name I?efinltion DntaT V81ue~ Conditional Conditional Amortization The number of months used to calculate the periodic Term after payments of both principal and interest that will be Numeric M M Modification sufficient to retire a mort a e obli ation. (4 0) Unpaid The unpaid principal balance of a loan after the loan Principal modification. The unpaid principal balance after Currency Balance after modification excludes any applicable forbearance (20 2) M M modification amount and can also be referred to as Net UPB Amount. Last Paid Installment Date Date after The due date of the last paid installment of the loan. (CCYY-MM- M M modification DD) Interest Rate after The interest rate in the month after loan Numeric modification modification. (6,4) M M Interest Rate The date that the rate lock was applied - in reference Date Lock Date for to modification of loan terms (CCYY-MM- M M Modification DD) First Payment Date Due Date after First payment due date under the modified terms (CCYY-MM- M M modification DD) Principal and Interest The P&I amount after modification Currency M M Payment after (20,2) modification Escrow Payment after Existing monthly payment to escrow-after Currency M modification modification (20,2) M Monthly The dollar amount per month of the borrowers Housing housing expense after modification .May be used for Currency Expense After their primary or non-primary residence. This must 2) (20 M M Modification be Principal, Interest, Taxes, Insurance and ' Association Dues PITTA . Maturity Date Date after The maturity date ofthe loan after modification (CCYY-MM- M M modification DD) Principal Forbearance The total amount in dollars of the principal that was Currency Amount deferred through loss mitigation. (20,2) C C For loans where the term of the loan can be extended rather than increasing the principal and Term after interest payment, this is the total term of the loan Numeric Modification including any extension. For all non-extendable (4,0) M M loans, the extended term defaults to the original term. Front Ratio after Percentage of borrower's PITTA to income ratio Numeric M M modification (4,2) Back Ratio after percentage of borrowers PITTA plus debts to Numeric modification income ratio (4,2) M M Principal Write-Down Amount of principal written-down or forgiven Currency C C For iveness (20 2) Paydown or Payoff of Subordinate Have sub-ordinate liens been paid ofPor paid down? Boolean True/False C C Liens Paydown or Payoff of Amount of paydown or payoff of subordinate liens Currency C C Subordinate (20 2) Supplemental Directive 09-01 Page 34 Loan Setup for , Official ;~ Tr1a1 Period ]11ndi1icatioo Allpµuhle Mandatory / Mandatory / Narpe IJefinitlon DalaTY Vatuea C itional Conditional Liens Amount Max Interest Number Rate after Interest rate cap for the loan. (6 4) M M modification Length of Trial The length of the trial period Numeric M M Period (3 0) 1" Trial The date the 1st payment is due during the trial Date Payment Due period (CCYY-MM- M O Date DD) 1"Trial The date the first payment posted during the Trial Date Payment period (CCYY-MM- M O Posted Date DD) 1"Trial Payment This is the actual amount of the Payment received Currency Received from the Borrower to the Servicer for the 1st Trial (20,2) M O Amount payment. Ifthe Praduct'fypi~ Auer Modification is Step R&te then at lust one acurrznce oflle tollowine group of fields mast exist. The lust o~wrrence musthave a stc effective date of 5 years for tha'first effective dua date after modification. Step -Interest The sequence is used to uniquely identify and order Rate Step Loan Interest Rate Adjustment schedule records Numeric (4) M M Number s ecific to the loan's ste rate schedule. Step - Date Payment The date the payment will be effective. (CCYY-MM- M M Effective Date DD) Step -Note The interest rate in the month after loan Numeric Rate modification. (6,4) M M Step -New After modification step duration. [f this step is the Interest Rate - last step and will be the rate and payment effective Numeric (4) M M Step Duration for the life of the loan, then duration is not required. Step - Principal and p&I Amount -The amount of the principal and/or Currency Interest interest payment due on the loan for each (20 2) M M Payment installment, beginning on the efFective date. ' Supplemental Directive 09-01 Page 35 Exhibit B: RAMP Monthly Trial Data Collection Elements The following data elements are necessary for recording borrower payments during the trial period. Name lletlnitlo^ Data Type ,~IMwable Diaudatory/ Values Cogs[ nal 1-IAMP Servicer Number A unique identifier assigned to each Text (3U) M Servicer that is participating in the RAMP ro ram. Servicer Loan Number The unique (for the lender) identifier Text (30) M assigned to the loan by the lender that is servicin the loan. GSE Loan Number A unique number assigned to each Text (30) C loan b a GSE Fannie or Freddie GSE Servicer Number The Fannie Mae or Freddie Mac Text (30) C uni ue Servicer identifier. Trial Payment Number The number of the trial payment being Numeric (4,0) M reported. The code that is used to define a single payment number that will be one of a series of payments that together will complete a loan trial a ment eriod. Trial Payment Received The actual dollaz amount of the Currency (20,2) M Amount payment received from the borrower to the Servicer for the trial a ment. Trial Payment Posted Date The date the payment was posted Date M durin the trial rind. CCYY-MM-DD Supplemental Directive 09-01 Page 36 Exhibit C: Monthly Loan Activity Records The following data elements are required for monthly loan activity records (CABs). Step rate attributes (interest rate, rate effective date, P&I payment) will only be reported on the LAR the month before the rate change is effective. The Action Code and Action Date are only reported when a loan is being removed (e.g., payoff, repurchase). i~'ame Definition Uata Type AlWwablc Values Siundaton,' Conditional HAMY Servicer Number A unique identifier assigned to each Text (30) M Servicer that is participating in the RAMP ro ram. Servicer Loan Number The unique (for the lender) identifier Text (30) M assigned to the loan by the lender that is servicin the loan. Last Paid Installment Date The due date of the last paid installment Date M After Modification of the loan. (CCYY-MM-DD) Unpaid Principal Balance After The unpaid principal balance of a loan Currency(20,2) M Modification after the loan modification. The unpaid principal balance after modification excludes any applicable forbearance amount and can also be referred to as Net UPB Amount. Interest Pa ment Interest rtion of the P&I remitted Currenc 20,2 -yI Princi al Pa ment Princi al onion of the P&[ remitted Currenc 20,2 M Step -Payment Effective Date The date the payment will be effective. Date C CCYY-MM-DD Step -Note Rate The interest rate in the month after loan Numeric (6,4) C modification. Step -Principal and Interest P&I Amount -The amount of the Currency(20,2) C Payment principal and/or interest payment due on the loan for each installment, beginning on the effective date. Action Code A code reported by the lender to update Numeric 60 (payotl) C the loan that indicates the action that 65 (repurchase) occurred during the reporting period 70 (liquidation held for sale) 71 (liquidation 3`a parry sale/ condemnation/ assigned to FFIA/VA) 72 (liquidated- pending conveyance) 76 (Deed in Lieu) 77 (Deed-in-Lieu with Jr. 1 ien) 78 (Short Sale) 79 (Short Sale with Jr. Lien Action Code Date The effective date of the action Date N/A C associated with the action code. The (CCYY-MM-DD) action date is required for certain action codes. Supplemental Directive 09-01 Page 37 Exhibit D RAMP Additional Data Requirements Data required to be collected as specified below must be re orted on a loan by loan basis starting on October 1, 2009. This document does not describe all of the data that the servicer must retain; it addresses only the data that must be reported. Must be reported starting October 1 2009 for transactions occurring before October 1, 2009 ^ Race, ethnicity, sex of borrower and co-borrower (submission by borrower is voluntary) ^ Middle name of borrower and co-borrower ^ Date of birth of borrower and co-borrower ^ Credit score of borrower and co-borrower ^ NPV Model inputs, e.g., discount rate, flag for nonstandard model, non-standard re-default rate, non-standard cure rate ^ Selected data on loan, borrower, and property characteristics as of origination, to the extent already required by OCC or OTS to be reported under "Mortgage Metrics" The above fields must be collected as follows and reported starting October 1, 2009: • all completed modifications; • trial modifications commenced on or after July 1, 2009; and • starting on October 1, 2009, loans evaluated for a modification (to be defined) that do not enter trial modifications. Must be reported starting October 1 2009 (detailed definitions to be provided by June I, 2009) ^ Reason loans evaluated for a modification were not modified, or that trial modification was not completed ^ Status and disposition of eligible loans not modified, including trial mods not completed ^ Status and disposition of loans that were modified but failed to remain in good standing because they became 90 or more days delinquent ^ Second liens -flag for presence of a second lien; source of information (e.g., credit report); available terms (e.g., fixed vs. ARM; closed- vs. open-end); owner; and payoff. Continuous tracking of second lien status is not required. ^ Purpose of loan (e.g., home purchase, refinance, cash-out refs) ^ Information about foreclosure suspension ^ Information about reliance on non-borrower household income ^ Flag for borrower in bankruptcy at time of modification ^ Flag for borrower in loss mitigation prior to modification ^ Information about involvement of a third party representing the borrower ^ Information about mortgage insurance Supplemental Directive 09-01 Page 38 SHAPIRO & DeNARDO, LLC BY: LESLIE J. RASE, ESQUIRE ATTORNEY I.D. NO: PA Bar # 58365 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-036823 U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC 1 PLAINTIFF VS. Sharon K. Landis DEFENDANT COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 10-2859 CERTIFICATE OF SERVICE I hereby certify that I have served a true and correct copy of the Motion for Summary Judgment, Memorandum of Law and Affidavit in Support of same, together with any other documentation specifically referenced in the transmittal letter, on '~ 1 tp to all parties named herein at their last known address or upon their attorney of record as below listed by regular mail, postage prepaid: Geoffrey M. Biringer, Esquire MidPenn Legal Services 401 East Louther Street, Suite 103 Carlisle, PA 17013 SHAPIRO & DeNARDO, LLC BY: Leslie J. Rase, Esquire Attorney for Plaintiff ~,~ ~ c~ PRAECIPE FOR LISTING CASE FOR ARGUMF.d~' F11_~r~ f r. r-, (Must be typewritten and submitted in duplicatQ~`D .~~L "7 ~l'1 ~ ~ ; i~ TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the within matter for the next Argument Court. -------------------------------------------------------------------------------------- CAPTION OF CASE entire caption must best ted in ffull .S. Bank, N.A. as ~ruste~e ~or the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC1 (Plaintiff) vs. Sharon K. Landis (Defendant) No. 10-2859 Civil Term 1. State matter to be argued (i.e., plaintiff's motion for new trial, defendant's demurrer to complaint, etc.): Plaintiff's Motion for Summary Judgment 2. Identify counsel who will azgue cases: (a} for plaintiff: Leslie J. Rase, Esquire Shapiro & DeNardo,LLC (Name and Address) 3604 Horizon Drive, Suite 150, King. of Prussia, PA 19406 (b) for defendant: Geoffrey M. Biringer, Esquire MidPenn Legal Services (Name and Address 401 East Louther Street, Suite 10~, Carlisle, PA 17013 3. I will notify all parties in writing within two days that this case has been listed for argument. 4. Argumen/t~Court Date: ~, a ~-y (~ t Signature Leslie J. Rase, Esquire Print your name Date: ~ ~ l ~ ( 0 Plaintiff Attorney for ~„ 'rt(~:,~~'v~~~:';~,j ~" SHAPIRO & DeNARDO, LLC BY: LESLIE J. RASE, ESQUIRE ATTORNEY I.D. NO: PA Bar # 58365 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE N0.09-036823 U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC 1 PLAINTIFF v. Sharon K. Landis DEFENDANT(S) Z~lQ JE~1. 20 c:~.~ (:4~ ,~ COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 10-2859 CERTIFICATE OF SERVICE I, Leslie J. Rase, Esquire, Counsel for Plaintiff, hereby certify that on July I l , 2010, a true and correct copy of the attached Praecipe for Listing Case for Argument advising of August 18, 2010 Argument Date was served by mailed same by regular mail, postage prepaid, to: Geoffrey M. Biringer, Esquire MidPenn Legal Services 401 East Louther Street, Suite 103 Carlisle, PA 17013 SHAPIRO & DENARDO, LLC BY: ~- Leslie J. Rase, Esquire PRAECIPE FOR LLSTING CASE FOR ARGUMENT ~~ (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the within matter for the next Argument Court. ------------------------------------------------- ----------------- ---- ----------------------------------------------- CAPTION OF CASE ((entire caption must be st~ted ine full t1.S. Bank, N.A. as rust a or.the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC1 ~? e.a a :`; n (Plaintiff) ~ o vs. rn~`~ ~ ~ '`~ ~_' < _C (7" <A1 ~7 Sharon K. Landis _ =~ `~' '~ `-~'~'~ (Defendant) ~ ~~; ~. `" -, ' ~' No. 10-•2859 Civil :e'er , 1. State matter to be azgued (i.e., plavniiff s motion for new trial, defendant's demurrer to complaint, etc.}: Plaintiff's Motion for Summary Judgment 2. Identify counsel who will argue cases: (a) for plaintiff: Leslie J. Rase, Esquire Shapiro & DeNardo,LLC (Name and Address) 3600 Horizon Drive, Suite 150, King of Prussia, PA 19406 (b) for defendant: Geoffrey M. Biringer, Esquire MidPenn Legal Services (Name and Address) 401 East Louther Street, Suite 103, Carlisle, PA 17013 3. I will notify all parties in writing within two days that this case has been listed for argument. 4. Argument Court Date: ~4.5~~ o~U Signature Date:~l~l uu Leslie J. Rase, Esquire Pont your name Plaintiff Attorney for ~_ SHAPIRO & DeNARDO, LLC BY: LESLIE J. RASE, ESQUIRE ATTORNEY I.D. NO: PA Bar # 58365 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-036823 U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC 1 PLAINTIFF VS. RLEa-Ql-r ~ ~Y P~~-ALL:; ~-nTARY e0 SEP -9 Pty l~ 10 ~~PENNSYLVANIP-~ COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 10-2859 Sharon K. Landis DEFENDANT(S) JUDGMENT BY STIPULATION BETWEEN PARTIES It is hereby stipulated and agreed by and between Plaintiff, U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC 1 and Defendant Sharon K. Landis subject to Court approval as follows: 1. That the premises located at 1809 Letchworth Drive, Camp Hill, PA 17011 ("Mortgaged Property") as more fully described in paragraph " 3" of the Complaint, is owned by the Defendant subject to the Mortgage in favor of Plaintiff. 2. That Judgment in rem shall be entered in the above entitled mortgage foreclosure action against the Defendant, Sharon K. Landis, and in favor of the Plaintiff in the amount of $41,566.02 plus interest at the per diem rate of $5.62 for each day after June 8, 2010 through the date of judgment and assessed as follows: ~ ~ • Principal Balance due and owing $35,063.82 Interest $1,910.06 Late Charges $89.67 Escrow Advances $2,162.40 Appraisal Fees $222.00 Property Inspections $42.00 Certified Mail Cost $22.16 Title Report Fee $300.00 Attorneys' Fees $1,753.91 TOTAL IN REM JUDGMENT AMOUNT $41,566.02 3. That Defendant retains all rights, pursuant to Pennsylvania law, to reinstate or pay-off the Mortgage and Note as described in the Complaint. 4. That Plaintiff reserves its rights and interests to pursue any deficiency judgment and/or the enforcement of any in personam action under the Note against Defendant. 5. That Defendant hereby accepts service of all subsequent pleadings and notices in the manner prescribed under Pa. R.C.P. 440(a). 6. That Defendant agrees to vacate the Mortgaged Property on or before thirty (30) days after the date of Sheriffs Sale, and further agree to surrender said property broom clean and in like condition as property is this date, normal wear and tear excluded. .- Consented to by: BY: . <% `~~20w'~ ~~ ~ Dated: g I ~ 6 I t o ~~ Sharon K. Landis, Defendant BY: t.!^,c.0~,dc~ Dated: ~/ Z 3 ~/0 Brenda Zim rman, Esquire Attorney for Defendant SHAPIRO & DENARDO on behalf of U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC 1 BY: Dated: ~`"~~ S I~'a Leslie .Rase, Esquire Counsel for Plaintiff "r , r SHAPIRO & DeNARDO, LLC BY: LESLIE J. RASE, ESQUIRE ATTORNEY I.D. NO: PA Bar # 58365 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-036823 U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC 1 PLAINTIFF VS. Sharon K. Landis DEFENDANT(S) SE' /02010 COURT OF COMMON PLEAS CUMBERLAND COUNTY -) -ti p ; NO: 10-2859 r. 0 LA ORDER 07- - AND NOW, this --L day of 10, upon consideration of the parties' Judgment by Stipulation, it is hereby ORDERED and DECREED that Judgment be entered in favor of Plaintiff, U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TCI, and against Defendant, Sharon K. Landis, in rem, in the amount of $41,566.02. It is further ORDERED and DECREED that interest is to be added to this judgment and will be calculated at the per diem rate of $5.62 for each day after June 8, 2010, through the date of judgment. It is further ORDERED and DECREED that all remaining terms of the said Judgment by Stipulation be and hereby are incorporated within this Order of Court. BY THE COURT: iFs ?n? c lam. J. WY00?dC .44 CEc4 as. 1 7, r/ N SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-036823 U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC 1 PLAINTIFF n S M,. `? COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:10-2859 VS. Sharon K. Landis DEFENDANT PRAECIPE FOR ENTRY OF JUDGMENT IN ACCORDANCE WITH COURT ORDER TO: PROTHONOTARY Kindly enter Judgment pursuant to the Order of Court dated September 10, 2010, in the above-captioned matter, granting Consent Judgment in favor of Plaintiff and against Defendant in the sum of $41,566.02, plus interest at the rate of $5.62 per diem from June 8, 2010, through September 10, 2010, the date of judgment, in the sum of $533.90. A true and correct copy of said order is attached hereto, made a part hereof and marked Exhibit "A". SHAPIRO & DeNARDO, LLC BY: Y)/-? n ?? Michael I. Clark, Esquire I?00 PO ATT-( 0,11 35&0(P 8 0 a097,5_ SEP 10 2010 SHAPIRO & DeNARDO, LLC BY: LESLIE J. RASE, ESQUIRE ATTORNEY I.D. NO: PA Bar # 58365 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-036823 U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC 1 PLAINTIFF VS. Sharon K. Landis DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 10-2859 ORDER AND NOW, this day o 2010, upon consideration of the parties' Judgment by Stipulation, it is hereby ORDERED and DECREED that Judgment be entered in favor of Plaintiff, U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC1, and against Defendant, Sharon K. Landis, in rem, in the amount of $41,566.02. It is further ORDERED and DECREED that interest is to be added to this judgment and will be calculated at the per diem rate of $5.62 for each day after June 8, 2010, through the date of judgment. It is further ORDERED and DECREED that all remaining terms of the said Judgment by Stipulation be and hereby are incorporated within this Order of Court. BY THE COURT: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: () Confessed Judgment {) Other U.S. Bank, N.A. as Trustee for the registered File No. 2859 holders of Structured Asset Securities Amount Due $41,566.02 Corporation Mortgage Pass-Through Interest June 8 2010 to March 2, 20 ice, Certificates, Series 2007-TC1 $1,506.16 =C PLAINTIFF Atty's Comm _ r Costs E" .., vs. ., t Sharon K. Landis DEFENDANT(S) TO THE PROTHONOTARY OF THE SAID COURT: c:3 q -1 -,-, ` ri The undersigned hereby certifies that the below does not arise out of a retail installment safe, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant(s) See attached Legal Description PRAECIPE FOR ATTACHEMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date: bo Signature:. s Print Name: Mic el J. Clark Esquire 40.o Pa ATTY Address: 3600 Horizon Drive, Suite 150 &2.5o G? BF ga. ao King of Prussia, PA 19406 ?4. oo Attorney for: Plaintiff ?4. oo a.50 Supreme Court ID # PA Bar # 202929 ao9. oo ' P° A Ty 0_NS'55(v8 401-00 Quec'o P 2097,T - 50 LL PX a SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-036823 U.S. Bank, N.A. as Trustee for the registered ; holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC 1 PLAINTIFF VS. ; Sharon K. Landis DEFENDANT COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:10-2859 CERTIFICATION OF ADDRESS c.? r- N, C3 ?-a I hereby certify that the correct address of the judgment creditor (Plaintiff) is: r a? LL. +? -V-? n U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TCI c/o Ocwen Loan Servicing, LLC 1661 Worthington Road West Palm Beach, FL 33415 and that the last known address of the judgment debtor (Defendant) is: Sharon K. Landis 1809 Letchworth Drive Camp Hill, PA 17011 SHAPIRO & DeNARDO, LLC BY: V-V A k Michael J Clark, Esquire Attorney for Plaintiff 09-036823 SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-036823 U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC 1 PLAINTIFF VS. Sharon K. Landis DEFENDANT F1,F"-r FICF _ B 1 1.. 1 k;J T i 0T?}tip 1 ` r. r "t J g a 1n: T L . U ... vi I i,. i 4{14 wl ;{ r?l.iitl COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 10-2859 AFFIDAVIT PURSUANT TO RULE 3129.1 U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC1, Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 1809 Letchworth Drive, Camp Hill, PA 17011. Name and address of Owner(s) or Reputed Owner(s) 2. 3 Sharon K. Landis 1809 Letchworth Drive Camp Hill, PA 17011 Name and address of Defendant in the judgment: Sharon K. Landis 1809 Letchworth Drive Camp Hill, PA 17011 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC1 c/o Ocwen Loan Servicing, LLC 1661 Worthington Road West Palm Beach, FL 33415 Capitol One PO Box 85147 Richmond, VA 23285 Capitol One c/o William T. Molczan, Esq. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 Mary A. Etter-Dissinger Dissinger & Dissinger 400 S. State Road Marysville, PA 17053 Mary A. Etter-Dissinger, Esq. 28 North Thirty-second Street Camp Hill, PA 17011 4. Name and address of the last recorded holder of every mortgage of record: U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC1, Plaintiff c/o. Ocwen Loan Servicing, LLC 1661 Worthington Road West Palm Beach, FL 33415 Pennsylvania Housing Finance Agency 211 North Front Street PO Box 15530 Harrisburg, PA 17105-5530 5. Name and address of every other person who has any record lien on the property: Lower Allen Township Authority 120 Limekiln Road New Cumberland, PA 17070 Lower Allen Township 2233 Gettysburg Road Camp Hill, PA 17011 Lower Allen Township Authority c/o Steven P. Miner, Esq. PO Box 5300 Harrisburg, PA 17110-0300 Lower Allen Township Authority c/o Steven P. Minor, Esq. 1035 Mumma Road, Suite 101 Wormleysburg, PA 17043 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: Cumberland County Domestic Relations 13 North Hanover Street Carlisle, PA 17013 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: TENANT OR OCCUPANT 1809 Letchworth Drive 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. Section 4904 relating to unsworn falsification to authorities. SHAPIRO DeNARDO, LLC BY: Michae . Clark, Esquire 09-036823 FILFC-0rr ICE SHAPIRO & DeNARDO, LLC 4.g r' sl i T " BY: MICHAEL J. CLARK, ESQUIRE r r t ?? }; ?: ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 ECCR'- ^. i 00;;? ,? KING OF PRUSSIA, PA 19406 r?F E Y, , jk N a TELEPHONE: (610)278-6800 S & D FILE NO. 09-036823 U.S. Bank, N.A. as Trustee for the registered COURT OF COMMON PLEAS holders of Structured Asset Securities CIVIL DIVISION Corporation Mortgage Pass-Through CUMBERLAND COUNTY Certificates, Series 2007-TC 1 PLAINTIFF NO: 10-2859 VS. ' Sharon K. Landis DEFENDANT NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Sharon K. Landis c/o Brenda Zimmerman, Esquire MidPenn Legal Services 401 East Louther Street, Suite 103 Carlisle, PA 17013 Your house (real estate) at: 1809 Letchworth Drive, Camp Hill, PA 17011 13-23-0547-230 is scheduled to be sold at Sheriffs Sale on March 2, 2011 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00AM to enforce the court judgment of $41,566.02 obtained by U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC 1 against you. 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: I. The sale will be cancelled if you pay back to U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC 1 the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call:(610)278-6800. 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 be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two of 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. 5. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610)278-6800. 6. 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. 7. 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 717-240-6390. 8. 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. 9. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 10. 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 no later than thirty days after the Sheriff Sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 11. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 09-036823 ALL THAT CERTAIN lot or piece of ground with the buildings and improvements thereon erected, situate in the Township of Lower Allen, County of Cumberland and State of Pennsylvania, being known as Lot No. 26, Block "C", on Plan No. 5 of Highland Estates Development, made by D.P. Raffensperger, Registered surveyor, Lemoyne, Pa., dated May 4, 1950, and recorded in Plan Book 4, Page 100, more fully described as follows: BEGINNING at a point on the Southeasterly side of Letchworth Drive, fifty (50) feet wide, at the distance of two hundred sixty-seven and thirty-nine hundredths (267.39) feet measured Northeastwardly and Eastwardly along the Southeasterly and Southerly side of Letchworth Drive from the eastern-most terminus of a radial round corner connecting the Southerly side of Letchworth Drive with the easterly side of Nineteenth Street, sixty (60) feet wide; THENCE in a Northeasterly direction along the Southeasterly side of Letchworth Drive on the arc of a circle on a line curving to the left having a radius of Two hundred Fifteen (215) feet, the arc distances of fifty (50) feet to a point; THENCE extending N 89 Degrees 39'48.5" East Two Hundred and Fifty Eight hundredths (200.58) feet to a point; Thence extending Southwardly one hundred six and forty-three hundredths (106.43) feet to a point; THENCE extending N 77 degrees 09'41.2" West two hundred thirty-five and ninety-four hundredths (235.94) feet to the Southeasterly side of Letchworth Drive, the first mentioned point and Place of BEGINNING. BEING Lot No. 26, Block "C", Plan No. 5 of Highland Estates. HAVING THEREON ERECTED a one and one-half story single dwelling known as 1809 Letchworth Drive, Camp Hill, Pa. BEING the same premises which Donald E. Landis and Sharon K. Landis, husband and wife, by Deed dated May 13, 1981 and recorded in the Cumberland County Recorder of Deeds Office on May 15, 1981 in Deed Book K29, page 316, granted and conveyed unto Sharon K. Landis. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-2859 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due US BANK NA, as Trustee for the registered holders of STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-TC1, Plaintiff (s) From SHARON K. LANDIS (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 $41,566.02 L.L. $.50 Interest from 6/8/10 to 3/2/11 -- $1,506.16 Atty's Comm % Due Prothy $2.00 Atty Paid $209.00 Other Costs Plaintiff Paid Date: 9/30/10 .? David D. uell, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: MICHAEL J. CLARK, ESQUIQRE Address: SHAPIRO & DeNARDO, LLC 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 Supreme Court ID No. 202929 SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-036823 U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC 1 PLAINTIFF VS. Sharon K. Landis DEFENDANT FIEED-OFFICE OF THE PROTHONOTARY 2011 Js.; [U. 25 CUMBE; '_ : .lN TY PE r' !A COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 10-2859 CERTIFICATION OF NOTICE TO LIENHOLDERS . PURSUANT TO PA R.C.P 3129.2 (C) (2) I, Meghan Williams, Legal Assistant for Shapiro & DeNardo, LLC, attorneys for the Plaintiff, U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC1, hereby certify that Notice of Sale was served on all persons appearing on Exhibit "A" attached hereto, by United States mail, first class, postage prepaid, with Certificates of Mailing on December 14, 2010, the originals of which are attached and that each of said persons appears on Plaintiffs Affidavit pursuant to Pa. R.C.P. 3129.1. The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, SHAPIRO & DeNARDO, LLC BY: Megh Williams Legal Assistant 09-036823 U) O X a) Ln o Y U. W Z , V ^ F- ou l I s?, w 0 ^ i Bui u and w 11 to a I0 LO m .21 ?i .- ? uoi uuguoD 3.injuu2iS t . uoiILuug oD Ctani co a. D N o o 0 L ? V F ? C 1 N? 7 1 ? N 3 Q Z Cl)? _ o) o? L = U IL W a10o m <y O N O .? C N d C m d P c C 00 v C Q ,qq?? O 8 W W QQ a! co m a°i v c W a> d ???? a ? O o 1?j?. ? V V C a ? Qy T ? T 2 € ,°. 7 0 '= o ,rte o WE = m y o c'' ?' ? > E ? r ? ? ?c M 3v'g?" y.G ?° y ?c •o b ? F? ?°" ?a?4° ? '" o¢ ?o cv v Nv ?? v m= EE a `o rG> a U °? ?Q j?aQ AQxoa AQ x Mc< °" H ?Q [-° Q E°- t mp c °xQ CL a ?w n°' _g=?3 yo d°a _v E n' ?a (UU ? 'o vr= xo O> m?•5 x yoy a?9 ?4x aXa' a? o`x x ????? Q o o,. °° ouh a Q e? ao 0 o N U C7 o y ?z A? z 0z K? 3c 3M g?'? 3Mc E v u-U U,aNVC.C]vNv aNRx °a-z 3NU 3R x°3 F?v E U N .1 ? .-7 O O O Q ° •> as p LD z a M yy A Q N eo ? FBI N Q ?°?!'ooa O o ?ox?o O N M CO I i? I co d d d c O c C m mE P Q V R > a c m a c 0 CL lV m Y C w H a a? E'a z'> a 0? 0o N m N 2 Li v d oo E M c d U- a SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-036823 U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC 1 PLAINTIFF VS. Sharon K. Landis DEFENDANT FILED-OFF( OF THE PROTHO?i A 2011 CUMEM.- COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 10-2859 VERIFICATION OF SERVICE PURSUANT TO Pa.R.C.P. 440 The undersigned hereby verifies that she is a legal assistant for Shapiro & DeNardo, LLC, attorneys for the Plaintiff in the above case and that pursuant to Pa.R.C.P 3129.2(c)(1)(ii) and 440, she mailed a true and correct copy of the Notice of Sale in the above-captioned case to Defendant's Attorney by regular, postage pre-paid, on October 6, 2010. I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties set forth in 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. DATED: SHAPIRO & DeNARDO, LLC v 1c,LC BY: Meghan Williams Legal Assistant 09-036823 MW d9-030993 U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT Received From: Shapiro and Kreisman, L King Of Prussia, PA 19406\ as e One piece of ordinary mail addressed b: Sharon K. Landis c/o Brenda Zimmerman, Esquire MidPenn Legal Services 401 East Louther Street, Suite 103 Carlisle, PA 17013 PS Form 3817, January 2001 p o (D G vi to C7 V ?ie? N tJl ©~o ,® N LL V J d3 ° d 1M(1 0 0 v" SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-036823 U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC1 PLAINTIFF VS. Sharon K. Landis DEFENDANT COURT OF COMMON PLEAS CIVIL DIVISION z CUMBERLAND COUNTY NO: 10-2859 PRAECIPE TO SATISFY MORTGAGE FORECLOSURE JUDGMENT ENTERED SEPTEMBER 10, 2010 TO THE PROTHONOTARY: Kindly mark the Judgment of record in this matter satisfied. -0 co Ln CD J i SHAPIRO & DeNARDO, LLC BY: Michael J. lark, squire Attorney 4 Plaintiff ?ci. o?.oo eyti mol, jyk 5o? -7 -73 s SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I. D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-036823 U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC1 PLAINTIFF VS. Sharon K. Landis DEFENDANT COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 10-2859 CERTIFICATE OF SERVICE I hereby certify that I have served a true and correct copy of the Praecipe to Satisfy Mortgage Foreclosure Judgment on to all parties named herein at their last known address or upon their attorney of record as below listed by regular mail, postage prepaid: Sharon K. Landis 1809 Letchworth Drive Camp Hill, PA 17011 Brenda Zimmerman, Esquire MidPenn Legal Services 401 East Louther Street, Suite 103 Carlisle, PA 17013 SHAPIRO & DeNARDO, LLC BY: V?q ? k Michael . Clark, Esquire Attorne for Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith ?.: s " - ¢ r . •, ;; Chief Deputy f / +? t j Richard W Stewart Solicitor ,F ;; ! r US Bank NA ND Case Number vs. Sharon K. Landis 2010-2859 SHERIFF'S RETURN OF SERVICE 01/03/2011 04:16 PM - Deputy Ryan Burgett, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 1809 Letchworth Drive, Camp Hill, PA 17011, Cumberland County. 02/02/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney Clark on 3/2/11. SHERIFF COST: $1,500.00 SO ANSWERS, March 16, 2011 RON R ANDERSON, SHERIFF DU Pd - C'v S? 1-t Pd ` ell-4 -5- ?S >3? !c! ;9u't'yJuite Jh@t"i f 7E;i ci$: ( inn, SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-036823 U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC1 PLAINTIFF VS. Sharon K. Landis DEFENDANT COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 10-2859 AFFIDAVIT PURSUANT TO RULE 3129.1 U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC1, Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 1809 Letchworth Drive, Camp Hill, PA 17011. Name and address of Owner(s) or Reputed Owner(s) Sharon K. Landis 1809 Letchworth Drive Camp Hill, PA 17011 2. Name and address of Defendant in the judgment: Sharon K. Landis 1809 Letchworth Drive Camp Hill, PA 17011 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC 1 c/o Ocwen Loan Servicing, LLC 1661 Worthington Road West Palm Beach, FL 33415 Capitol One PO Box 85147 Richmond, VA 23285 Capitol One c/o William T. Molczan, Esq. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 Mary A. Etter-Dissinger Dissinger & Dissinger 400 S. State Road Marysville, PA 17053 Mary A. Etter-Dissinger, Esq. 28 North Thirty-second Street Camp Hill, PA 17011 4. Name and address of the last recorded holder of every mortgage of record: U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC1, Plaintiff c/o. Ocwen Loan Servicing, LLC 1661 Worthington Road West Palm Beach, FL 33415 Pennsylvania Housing Finance Agency 211 North Front Street PO Box 15530 Harrisburg, PA 17105-5530 Name and address of every other person who has any record lien on the property: Lower Allen Township Authority 120 Limekiln Road New Cumberland, PA 17070 Lower Allen Township 2233 Gettysburg Road Camp Hill, PA 17011 Lower Allen Township Authority c/o Steven P. Miner, Esq. PO Box 5300 Harrisburg, PA 17110-0300 Lower Allen Township Authority c/o Steven P. Minor, Esq. 1035 Mumma Road, Suite 101 Wormleysburg, PA 17043 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: Cumberland County Domestic Relations 13 North Hanover Street Carlisle, PA 17013 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: TENANT OR OCCUPANT 1809 Letchworth Drive 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. Section 4904 relating to unsworn falsification to authorities. SHAPIRO DeNARDO, LLC BY: Michae . Clark, Esquire 09-036823 SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-036823 U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC 1 PLAINTIFF VS. COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 10-2859 Sharon K. Landis DEFENDANT NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Sharon K. Landis c/o Brenda Zimmerman, Esquire MidPenn Legal Services 401 East Louther Street, Suite 103 Carlisle, PA 17013 Your house (real estate) at: 1809 Letchworth Drive, Camp Hill, PA 17011 13-23-0547-230 is scheduled to be sold at Sheriff s Sale on March 2, 2011 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00AM to enforce the court judgment of $41,566.02 obtained by U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC1 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: The sale will be cancelled if you pay back to U.S. Bank, N.A. as Trustee for the registered holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC1 the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610)278-6800. 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 be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two of 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. 5. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610)278-6800. 6. 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. 7. 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 717-240-6390. 8. 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. 9. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 10. 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 no later than thirty days after the Sheriff Sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 11. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 09-036823 ALL THAT CERTAIN lot or piece of ground with the buildings and improvements thereon erected, situate in the Township of Lower Allen, County of Cumberland and State of Pennsylvania, being known as Lot No. 26, Block "C", on Plan No. 5 of Highland Estates Development, made by D.P. Raffensperger, Registered surveyor, Lemoyne, Pa., dated May 4, 1950, and recorded in Plan Book 4, Page 100, more fully described as follows: BEGINNING at a point on the Southeasterly side of Letchworth Drive, fifty (50) feet wide, at the distance of two hundred sixty-seven and thirty-nine hundredths (267.39) feet measured Northeastwardly and Eastwardly along the Southeasterly and Southerly side of Letchworth Drive from the eastern-most terminus of a radial round corner connecting the Southerly side of Letchworth Drive with the easterly side of Nineteenth Street, sixty (60) feet wide; THENCE in a Northeasterly direction along the Southeasterly side of Letchworth Drive on the arc of a circle on a line curving to the left having a radius of Two hundred Fifteen (215) feet, the arc distances of fifty (50) feet to a point; THENCE extending N 89 Degrees 39'48.5" East Two Hundred and Fifty Eight hundredths (200.58) feet to a point; Thence extending Southwardly one hundred six and forty-three hundredths (106.43) feet to a point; THENCE extending N 77 degrees 09'41.2" West two hundred thirty-five and ninety-four hundredths (235.94) feet to the Southeasterly side of Letchworth Drive, the first mentioned point and Place of BEGINNING. BEING Lot No. 26, Block "C", Plan No. 5 of Highland Estates. HAVING THEREON ERECTED a one and one-half story single dwelling known as 1809 Letchworth Drive, Camp Hill, Pa. BEING the same premises which Donald E. Landis and Sharon K. Landis, husband and wife, by Deed dated May 13, 1981 and recorded in the Cumberland County Recorder of Deeds Office on May 15, 1981 in Deed Book K29, page 316, granted and conveyed unto Sharon K. Landis. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-2859 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due US BANK NA, as Trustee for the registered holders of STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-TC1, Plaintiff (s) From SHARON K. LANDIS (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 $41,566.02 L.L. $30 Interest from 6/8/10 to 3/2/11 -- $1,506.16 Atty's Comm % Due Prothy $2.00 Atty Paid $209.00 Other Costs Plaintiff Paid Date: 9/30/10 David D. Buell, Prothonotary (Seal) B Deputy REQUESTING PARTY: Name: MICHAEL J. CLARK, ESQUIQRE Address: SHAPIRO & DeNARDO, LLC 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 Supreme Court ID No. 202929 TRUE COP",! FROM RECORD b Testimony w,a ec.-, ; e,nto set my hand 00 the seal of sari court at Carlisle, Pa. _-W±da of 2010 k . P ftnctwy I Moz- 61- On November 22, 2010 the Sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA, Known and numbered 1809 Letchworth Drive, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 22, 2010 By: Real Estate Coordinator 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: January 28 and February 4, 2011 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. r L sa Marie Coyn , Editor SWORN TO AND SUBSCRIBED before me this 4 day February 2011 - -, ?-) z e- -'; ?A z ) /,/ - Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 V2 CUMBERLAND LAW JOURNAL Writ No. 2010-2859 civil US Bank NA vs. Sharon K. Landis Atty.: Michael J. Clark ALL THAT CERTAIN lot or piece of ground with the buildings and improvements thereon erected, situ- ate in the Township of Lower Allen, County of Cumberland and State of Pennsylvania, being known as Lot No. 26, Block "C", on Plan No. 5 of Highland Estates Development, made by D.P. Raffensperger, Registered surveyor, Lemoyne, Pa., dated May 4, 1950, and recorded in Plan Book 4, Page 100, more fully described as follows: BEGINNING at a point on the Southeasterly side of Letchworth Drive, fifty (50) feet wide, at the dis- tance of two hundred sixty-seven and thirty-nine hundredths (267.39) feet measured Northeastwardly and East- wardly along the Southeasterly and Southerly side of Letchworth Drive from the eastern-most terminus of a radial round corner connecting the Southerly side of Letchworth Drive with the easterly side of Nineteenth Street, sixty (60) feet wide; THENCE in a Northeasterly direction along the Southeasterly side of Letchworth Drive on the arc of a circle on a line curving to the left having a radius of Two hundred Fifteen (215) feet, the arc distances of fifty (50) feet to a point; THENCE extending N 89 Degrees 39'48.5" East Two Hundred and Fifty Eight hundredths (200.58) feet to a point; Thence extending Southwardly one hundred six and forty-three hundredths (106.43) feet to a point; THENCE extending N 77 degrees 0941.2" West two hundred thirty-five and ninety-four hun- dredths (235.94) feet to the South- easterly side of Letchworth Drive, the first mentioned point and Place of BEGINNING. BEING Lot No. 26, Block "C", Plan No. 5 of Highland Estates. HAVING THEREON ERECTED a one and one-half story single dwell- ing known as 1809 Letchworth Drive, Camp Hill, Pa. BEING the same premises which Donald E. Landis and Sharon K. Landis, husband and wife, by Deed dated May 13, 1981 and recorded in the Cumberland County Recorder of Deeds Office on May 15, 1981 in Deed Book K29, page 316, granted and conveyed unto Sharon K. Landis. 34 The Patriot-flews Co. ?- 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE the patriot News 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 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds 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: 1/28/11 i Sworn to and subscribed bet'bm'me this 22 day of Februanr, 2011 A D. Notary Public t Lr! OTQ VEALT!_I OF PENNSYLVANIA Notarial Seal j Sherrie L Kisner, Notary Public EJ tower Paxton 1'wp., Dauphin County My COmmisslOr, Expires Nov. 26, 2011 M?mhAr °enn;ytvanlz; Nssociation of Notaries 2010-31159 CM1 Tana us Bank HA VS Sharon K. Lartdls MW. Mleh" J Clark ALL THAT CERTAIN lot or piece of ground with thebuildings and improvements thereon erected, situate in the Township of Lower Allen, County of Cumberland and State of Pennsylvania, being known as Lot No. 26, Block "C", on Plan No. 5 of Highland Estates Development, made by D.P. Raffensperger, Registered surveyor, Lemoyne, Pa., dated May 4, 1950, and recorded in Plan Book 4, Page 100, more fully described as follows: BEGINNING at a point on the Southeasterly side of Letchworth Drive, fifty (50) feetwide, at the distance of two hundred sixty-seven and thirty-nine hundredths (267.39) feet measured Northeastwardly and Eastwardly along the Southeasterly and Southerly side of Letchworth Drive from the eastem-most terminus of a radial round corner connecting the Southerly side of Letchworth Drive with the easterly side of Nineteenth Street, sixty (60) feet wide; THENCE in a Northeasterly direction along the Southeasterly side of Letchworth Drive on the arc of a circle on a line curving to the left having a radius of lWo hundred Fifteen (215) feet, the are distances of fifty (50) feet to a point; THENCE extending N 89 Degrees.39' 48.5" East 7tvo Hundred and Fifty Eight hundredths (200.58) feet to a point; Thence extending'Southwardly one hundred six and three hundredths (106.43) feet to a poin=CE wending N 77 degrees 09'41.2" West two hundred thirty-five and ninety-four hundredths (235.94) feet to the Southeasterly side of Letchworth Drive, the fust mentioned point and Place of BEGINNING. BEING Lot No. 26, Block "C" Plan No. 5 of HighlandEstates. HAVING THEREON ERECTED a one and onF-half story single dwelling known as 1809 Letchworth Drive, Camp Hill, Pa. BEING the same premises which Donald E. Landis and Sharon IK. Landis, husband and wife, by Deed dated' May 13, 1981 and recorded in the Cumberland County Recorder of Deeds Office on May 15, 1981 in Deed Book K29, page 316, granted and conveyed unto Sharon K Landis..