HomeMy WebLinkAbout10-3814~A ~
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302 C ~
STUART WINNEG, ESQUIRE - ID #45362 _fi
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LORRAINE DOYLE, ESQUIRE - ID #34 57 6 _
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ALAN M. MINATO, ESQUIRE - ID #75860 _
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CHANDRA M. ARKEMA, ESQUIRE - ID #203437 ,"-~
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LOUIS A. SIMONI, ESQUIRE - ID #200869
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ADAM L. KAYES, ESQUIRE - ID #86408 y_.- '
MARGUERITE L. THOMAS, ESQUIRE - ID #204460 `~~ ~ ''~
WOODCREST CORPORATE CENTER ~ "~ '
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadingsCudren.com
Deutsche Bank National Trust `:COURT OF COMMON PLEAS
Company as Trustee for the :CIVIL DIVISION
Registered Holder of Soundview €
Home Loan Trust 2006-EQl :Cumberland Country
Asset-Backed Certificates,
Series 2006-EQl
12650 Ingenuity Drive
Orlando, FL 32826
Plaintiff
v.
Steve W. Clark
`
Kristi K. Clark NO. (!~ - 3S(
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13 92 Lowther Road ~
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Camp Hill, PA 17011
Defendant(s)
COMPLAINT IN MORTGAGE FORECLOSURE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the
claims set forth in the following pages, you must take action
within twenty (20) days after this Complaint and Notice are served,
by entering a written appearance personally or by attorney and
filing in writing with the Court your defenses or objections to the
claims set forth against you. You are warned that: if you fail to
do so the case may proceed without you and a .judgment may be
entered against you by the Court without further notice for any
money claimed in the Complaint or for any other claim or relief
requested by the Plaintiff. You may lose money or property or
other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
~'4a -ov l~a~~
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OFFICE CAN PROVIDE YOU WITH INFORMATION ABOIIT HIRING A LAWYER. IF
YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES TFIAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYERS REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17031
717-249-3166
Avlso
Le han demandado a usted en la Corte. Si usted quiere defenderse
de estas demandas expuestas en las paginas siguientes, usted tiene
veinte (20) dias de plazo al partir de la fecha de la demanda y la
notificacion. Hace falta ascentar una comparencia escrita o en
persona o con un abogado y entregar a la Corte en forma escrita sus
defensas o sus objeciones a las demandas en contra de su persona.
Sea avisado que si usted no se dafiende, la Corte tomara medidas y
puede continuar la demanda en contra suya sin previo aviso 0
notificacion. Ademas, la Corte puede decidir a favor del
demandante y requiere que usted cumpla con todas las provisioner de
esta demanda. Usted puede perder dinero o sus propiedades u otros
derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO INa~DIATAMENTE, 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 Bar Association
2 Liberty Avenue
Carlisle, PA 17031
717-249-3166
NOTICE
The amount of your debt is as stated in the attached document. The name of the creditor
to whom the debt is owed is as named in the attached document. Unless you notify us within
30 days after receipt of this Notice and the attached document that the validity of the stated
debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify
us in writing of a dispute within the 30 day period, we will obtain verification of the debt or
a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not
an admission of liability on your part. Also, upon your written request within the 30 day
period, we will provide you with the name and address of the original creditor if different from
the current creditor.
If you notify us in writing within the 30 day period as stated above, we will cease collection
of your debt, or any disputed portion of it, until we obtain the information that is required
and mail it to you. Once we have mailed to you the required information, we will then
continue the collection of your debt.
This law firm is deemed to be a debt collector and this Notice and the attached document is
an attempt to collect a debt, and any information obtained will be used for that purpose.
UDREN LAW OFFICES, P.C.
/s/ Mark J. Udren, Esquire
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill, NJ 08003-3620
(856) 669-5400
1. Plaintiff is the Corporation designated as such in the
caption on a preceding page. Plaintiff is the legal holder of the
Mortgage that is the subject of this action. Current assignments of
mortgage of record are as follows.
Assignor: Mortgage Electronic Registration Systems, Inc.
Assignments of Record to: Deutsche Bank National Trust Company, as
Trustee for Soundview Home Loan Trust 2006-EQ1
Recording Date: 12/22/08 Document No. 200840164
Plaintiff is in the process of formalizing the assignment of
mortgage in its favor for recording.
2. Defendant(s) is the individual designated as such on the
caption on a preceding page, whose last known address is as set
forth in the caption, and unless designated otherwise, is the real
owner(s) and mortgagor(s) of the premises being foreclosed.
3. On or about the date appearing on the Mortgage
hereinafter described, at the instance and request of Defendant (s) ,
Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned
to the Defendant(s) the sum appearing on said Mortgage, which
Mortgage was executed and delivered to Plaintiff as security for
the indebtedness. Said Mortgage is incorporated herein by
reference in accordance with Pa.R.C.P. 1019 (g).
The information regarding the Mortgage being foreclosed is as
follows:
MORTGAGED PREMISES: 1392 Lowther Road
MUNICIPALITY/TOWNSHIP/BOROUGH: Lower Allen Township
COUNTY: Cumberland
DATE EXECUTED: 06/30/06
DATE RECORDED: 07/10/06 BOOK: 1957 PAGE: 4304
The legal description of the mortgaged premises is attached hereto
and made part hereof.
4. Said Mortgage is in default because the required payments
have not been made as set forth below, and by :its terms, upon
breach and failure to cure said breach after notice, all sums
secured by said Mortgage, together with other charges authorized by
said Mortgage itemized below, shall be immediately due.
5. After demand, the Defendant(s) continues to fail or
refuses to comply with the terms of the Mortgage as follows:
(a) by failing or refusing to pay the installments of
principal and interest when due in the amounts indicated
below;
(b) by failing or refusing to pay other charges, if any,
indicated below.
6. The following amounts are due on the said Mortgage as of
04/27/10:
Principal of debt due $108,700.46
Unpaid Interest at 7.25*~
from 07/01/09 to 04/27/10
(the per diem interest accruing on
this debt is $21.69 and that sum
should be added each day after 04/27/10) 6,450.35
Title Report 325.00
Court Costs (anticipated, excluding
Sheriff's Sale costs) 280.00
Escrow Overdraft/(Balance)
(The monthly escrow on this account
is $257.11 and that sum should
be added on the first of each
month after 04/27/10) 5,036.43
Late Charges
(monthly late charge of $38.31
should be added in accordance
with the terms of the note
each month after 04/27/10) 114.93
Property Inspection 31.50
Prior Servicer Cost & Fee 379.00
Attorneys Fees (anticipated and actual
to 5o of principal) 5,435.02
TOTAL
$126,752.60
*This interest rate is subject to adjustment as more fully
described in the note and mortgage.
7. The attorney's fee set forth above are in conformity with
the mortgage documents and Pennsylvania law, and will be collected
in the event of a third party purchaser at Sheriff's Sale. If the
mortgage is reinstated prior to the sale, reasonable attorney's
fees will be charged in accordance with the reduction provisions of
Act 6, if applicable.
8. The combined notice specified by tYie Pennsylvania
Homeowner's Emergency Mortgage Assistance Program,, Act 91 of 1983
and Notice of Intention to Foreclose under Act 6 of 1974 has been
sent to each defendant, via certified and regular mail, in
accordance with the requirements of those acts, on the date
appearing on the copy attached hereto as Exhibit "A." , and made part
hereof, and defendant(s) have failed to proceed within the time
limits, or have been determined ineligible, or Plaintiff has not
been notified in a timely manner of Defendant(s) eligibility.
WHEREFORE, the Plaintiff demands judgment, i.n rem, against
the Defendant(s) herein in the sum of $126,752.60 plus interest,
costs and attorneys fees as more fully set forth in the Complaint,
and for foreclosure and sale of the Mortgaged premises.
UDREN j,LtiAW /(~FFIC:ES , P . C .
BY': `
Atto eys for Plaintiff
MARK EN, ESQUIRE
STUART EG, ESQUIRE
LORRAINE DO_ LE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
ADAM L. KAYES, ESQUIRE
MARGUERITE L. 'T'HOMAS, ESQUIRE
ALL THAT CERTAII~1-tract or Parx1 of land sod promises, sittu4e, lying sad being in
the Township of Lower Alley in the Canty of Cumberland and Cotttmottvresith of
Pegasyivania, more part;wlarly dt.scn'bed as follows:
BEGINAiING at a poiai on the northern lice of Lowther Road, on the dividing tiro
betwaa Lot Nos, 24 and 35, Hlock "L", on the hertinaftez memioned Plan of Lots;
thence in a northerly direction along said dividing line one hundred twenty (124) fret to
Lot No. 9, Block "L", on said Platt; thence in as easterly direction along the southerly
litre of said Lot No. 9, frflyf:vc (35) fat to Lot Na. 36, Block L, on acid Plan; thence is a
saathetfy direction along the western Fine of said Lot DIa. 36, oac hundred twenty (120}
fat to Lowther Road 5fty-flue to the point or PLACE OF 13EGlNNING.
BEWG LOT NO.35, Block "L" on the Plan of Gteaur Highland Park, Lowct Alley
Township. Cumberland County, Pdmsylvanis, recorded is the Cttmberlaad County
Recanlcr of Deeds Offitx, in Plan Book A, Page 89.
I•IAVING THEREON ERECTED a one story frame dwelling house.
TOgttht~r With all and singular the buildings and improvements, ways, stteeta, alleys, driveways,
passages, waters, water-courses, rights, liberties. ptivsleges, hcxditaments and appurtenances, whatsoever
unto the hereby granted premises belonging, or its anywise appertaining, and the reversions and
D~fli( 2~J`J PdCE,`~?~
7
Ocwen Loan Servicing, LLC
P.O. Box 24737
-~-~ - • ~ West Palm Beach, Florida 33416-4737
O C W E N
(Do not send correspondence or payments to the above address.) ~'Ot'~~'.OC'~h'EN.C'O;~-1
January 16, 2010
VIA First Class Mail
VIA Certified Mail (return receipt requested)
Certified Number: 71069017515130847685
Reference Code: 0908
Steve W. Clark
1392 Lowther Road
Camp Hill, PA 17011-0000
Loan Number: 71041636
Property Address: 1392 Lowther Road ,Camp Hill, PA 1 70 1 1-0000
PLEASE SEE THE ENCLOSED DOCUMENT
DACT91.16
This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that
purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not
intended as and does not constitute an attempt to collect a debt
Ocwen Loan Servicing, LLC
P.O. Box 24737
O C W E N West Palm Beach, Florida 33416-4737
(Do not send correspondence or payments to the above address.)
January 16, 2010
APPENDIX A
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
Vv~'u~.OCWEN C'OM
This is an official notice that the mortgage o n your home is in default, and the l ender intends t o foreclose pecific
information about the nature of the default is provided in the attached pages
The HOMEOWNER' MORT A E A I TANCE PROGRAM (HEMAPI may
be able to help
to save your home
This Notice explains how the program works
To see if HEMAP can help you must MEET WITH A .
ONSUMER REDIT COUN ELIN A EN Y WITHIN
THIRTY (30) DAYS OF THE DATE OF THI NOTI E Take this Notice w ith you when you meet with the
Counseling Agency
The name address and phone number of on
umer redit
oun eling Agencies se
rving your Cou _
ntv are listed at the
end of this Notice If you have any questions you may call t he Pennsylvania Housin g Finance Agenc y toll free at
(800) 342-2397 (Persons with impaired hearin
This Notice contains important legal informa g can call L717
tion If you ha ) 780 18691
ve any questions, repre
sentatives at th
e Consumer Credit
('ounseLing Agencv may be able to help expla in it You ma y also want to contact a n attorne in y our area The local
bar association may be able to help you find a lawyer
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A
CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION, OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO A ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. USTED PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL
PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM"
EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
HOMEOWNER'S NAME(S):
PROPERTY ADDRESS:
LOAN ACCT. NO.:
ORIGINAL LENDER:
CURRENT LENDER/SERVICER:
Steve W. Clark
1392 Lowther Road
Camp Hill, PA 17011-0000
71041636
OCWEN
DACT91.16
This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that
purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not
intended as and does not constitute an attempt to collect a debt
Ocwen Loan Servicing, LLC
• P.O. Box 24737
°-----° ' West Palm Beach, Florida 33416-4737
O C W E N
(Do not send correspondence or payments to the above address.) ~'1~'u .C)CN'EN.CC)M
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL A I TANCE WHI H CAN SAVE YO R HOME FROM
FORECLOSURE AND HELP YOU MAKE F TURE MORT A E PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE
ASSISTANCE:
IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES
BEYOND YOUR CONTROL,
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY
THE PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORFCLO U F Under the Ac t, you are entitled to a tem porary stay of foreclosure on
your mortgage for thirt~(301 days from th
e date of this Notic
e During that time you m .
ust arrange and attend a "face-
~ace" meeting with one of the consume r credit counseling agencies listed at the end o f thi Notice THI ME TIN .
MUST OCCUR WITHIN THE NEXT (3 0) DAYS IF YOU DO NOT APPLY FOR EM R EN Y MORT A
ASSISTANCE, YOU MUST BRING Y OUR MORT A E UP TO DAT TH PART OF THI NOTI E
CALLED"HOW TO CURE YOUR MOR
T A DEFAU
T" EXP AIN NOW TO _
BRIN YOUR MORTGAGE
UP TO DATE.
CONSUMER CREDIT COUN i IN A NCI - If you meet with one of the consumer credit counseling agency
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 telgphone numbers of designated consumer credit coon a ing agencies for the_
county in which the ro e~rty is located are set forth at the end of thi Notice. It is only necessary to schedule one face-
to-face meeting. Advise your lender immediatelX of your intentions.
APPLICATION FOR MORTGAGE A IST NCE -Your mortgage is in default for the reasons set forth later in
this Notice (see following pages for specific information about the nature of your default.) If you have tried and are
unable to resolve this problem with the lender, you have the right to apply for financial assistance from the
Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed
Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling
agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program
and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your
application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW
THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST
YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE
DENIED.
AGENCY ACTION -Available funds for emergency mortgage assistance are very limited. They will be disbursed by
the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty
(60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be
pursued against you if you have met the time requirements set forth above. You will be notified directly by the
Pennsylvania Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE
FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE
CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance).
DACT91.16
This communication is from a debt collector attempting to collect a debt; any information obtained will be used for• that
purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not
intended as and does not constitute an attempt to collect a debt
Ocwen Loan Servicing, LLC
P.O. Box 24737
°•---~°• ~ West Palm Beach, Florida 33416-4737
O C W E N
(Do not send correspondence or payments to the above address.)
!~'~' V~'.OC WEN.C'0~1
HOW TO CU F YO R MORT A E DEFA T T Bring it up to date,
NATURE OF TH DEFAU T -The MORTGAGE debt held by the above lender on your property located at: 1392
Lowther Road ,Camp Hill, PA 17011-0000
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following
amounts are now past due:
6 payments in the amount of $ 1,023.24 from August Ol. 2009 through ,Tanuary 16.2010
DETAIL SUM A1tY
Principal and Interest ................................. $ 4,596.78
Interest Arrearage ..................................... $ 0.00
Escrow .................................................. $ 1,542.66
Late Charges ........................................... $ 0.00
Insufficient Funds Charges ........................... $ 0.00
Fees /Expenses ........................................ $ 389.50
Suspense Balance (CREDIT) ........................ $ 0.00
Interest Reserve Balance (CREDIT) ................ $ 0.00
TOTAL DUE .......................................... $ 6,528.94
HOW TO CU F TH DEFAU T -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 $6,528.94, PLUS ANY
MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY
PERIOD. Payments must be made either by Money Gram Cashier' heck, Certified Check or Money Order made.
payable and sent to:
OCWEN
P.O. BOX 6440
CAROL STREAM, IL 60197-6440
IF YOU DO NOT CURE TH D FA Ti T - If you do not cure the default within THIRTY (30) DAYS of the date of
this Notice, the lender intends to exercise it 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 MORT A EIS FORECLO ED PON -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' fee
OTHER LENDER RFMFDIF -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 P OR TO HERIFF' AL - 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
Drevent the sale at anv time up to one hour before the heriff ale You may do so b~paying the total amount then.
east due ulus anv late or other charge then d e reasonable attorney's fees and costs connected with the foreclosure
stele and anv other costs connected with the sheriff ale ac cpe~ified in writing by the lender and by perform-ng anv.
9ther requirementc nndPr 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.
DACT91.16
This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that
purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not
intended as and does not constitute an attempt to collect a debt
Ocwen Loan Servicing, LLC
P.O. Box 24737
`--~--~--- -' West Palm Beach, Florida 33416-4737
O C W E N
(Do not send correspondence or payments to the above address.) ~'~1'~~ .OC~`EN.COM
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 six (6) months from the date of this Notice. A notice of
the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default
will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by
contacting the services.
HOW TO CONTACT THE SERVICER:
Name of Services: OCWEN
re P.O. BOX 24737
WEST PALM BEACH, FL 33416-4737
Phone Number: 877-596-8580
Fax Number: 407-737-5693
Contact: Early Intervention Dept
EFFECT OF SHERIFF'S SALE -You should realize that a Sheriffs Sale will end your ownership of the mortgaged
property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to
remove you and your furnishings and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE -You may or a may not (CHECK ONE) sell or transfer your home to a buyer or
transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees
and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW
MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
TO HAVE THIS DEFAULT CURED BY ANY THHtD 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 (3) 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 AGENCIE ERVIN YO R O NTY
DACT91.16
This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that
purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not
intended as and does not constitute an attempt to collect a debt
Apri127, 2010
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
The NnMF.nWNFR~~ MnRT(iA(':F A44iSTANC'F PRn("RAI~~ (7FA~AP~ may p 1
e n n cave ~nnr nme_ Thic NntiCP pxnlainc hnw the ,gram ~ ~^,ar~
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 fmd a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL
CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION
INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING
FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES
SER ELEGIBLE PARR UN PRESTAMO POR EL PROGRAMA LLAMADO
~HOMEOWNER~S EMERGENCY MORTGAGE ASSISTANCE PROGRAMS EL CURL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU
HIPOTECA.
EXH~~~ A;-
Page 1 of 1
HOMEOWNER'S NAME(S):
PROPERTY ADDRESS:
LOAN ACCT. NO.:
ORIGINAL LENDER:
CURRENT LENDER:
HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM
Yni1 MAY RF F,i.i(aRi.F, F(lR FiNANCiAi. ASSiSTANCF
WHiCH CAN SAVF. YniTR HnMF, FRnM FnRF.Ci.nSiTRF. AND
HF.i.P Yni1 MAKF, FiTTiTRF, MnRT(iAf_'F PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNEROS
EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE DACTD), YOU MAY BE
ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
IF YOUR DEFAULT HAS BEEN CAUSED BY CHtCUMSTANCES 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.
TF.MPnRARY STAY nF FnRF.Ci.nSiTRF. -Under the Act, you are entitled to a temporary
stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that
time you must arrange and attend a Oface-to-faced meeting with one of the consumer credit
counseling agencies listed at the end of this Notice. THiS MF,F.TiN(: Mi1ST nCCiTR WiTHiN
SOW Tn CTTRF. YnT1R MnRTGA(TF I~FFATTT TD
RT(TAGF. T JP T(7 I~ATF.
CnNSiTMF.R CRF,niT CniTNSFi,iN(~ Af'F.NCTF.S - 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, addrec~e~ and t lenh~ne nnmherc
are set t~rth at the enci c,t~ th;~ Net; It is only necessary to schedule one face-to-face meeting.
Advise your lender;mm~;ate1T of your intentions.
APPi.iC.ATinN FnR MnRT(:A(':F, ASSiSTAN(`F __ your mortgage is in default for the
reasons set forth later in this Notice (see following pages for specific information about the nature
of your default.) If you have tried and are unable to resolve this problem with the lender, you have
the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance
Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency
Assistance Program Application with one of the designated consumer credit counseling agencies
listed at the end of this Notice. Only consumer credit counseling agencies have applications for the
program and they will assist you in submitting a complete application to the Pennsylvania Housing
Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your
Page 2 of 2
face- to-face meeting.
YOU MiTST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIIa TO DO SO OR IF YOU
DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER,
FORECLOSURE MAY PROCEED AGAINST YOUR HOME IM117EDIATELY AND YOUR
APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
A(:F.NC'Y A('TinN -- Available funds for emergency mortgage assistance are very limited. They will
be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing
Finance Agency has sixty (60) days to make a decision after it receives your application. During that time,
no foreclosure proceedings will be pursued against you if you have met the time requirements set forth
above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your
application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO
COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
NATiTRF, nF TNF, 11F.FAiTi,T _ The MORTGAGE debt held by the above lender on your property
located at:
1392 Lowther Road
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:
_Monthly_Payments_of..$1023,24.._for August..l,,. 2009._through._April..l,_2010.._._=...$9209.16 ............................
._Monthly.Late Charges of $38..31 for..August 1, 2009 through April 1, 2010 ........ X114._93 ..........................._.._.... .
Other charges (explain/itemize): Prior Servicer=$379.00
Property Inspection=$31.50
_Escrow_Adyance=$503634_.........,
..................
....................._AL_AMOiJNT,_PAST._DUE.~.............._............................_..........................._ . SL4,ZZ4,2~....
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Dn not ns . if not ~n In icahl~); ]y~~
HnW Tn CiTRF TuF. nFFerrr.T _ 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 ~14770.9'~ PLUS
ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIIZTY (30)
DAY PERIOD. PavmentG must h mad either h~ cash cachier'S he k, cerrifi d ch cl. ~r m~ne~ order made ~~g}Zl__
and cent t~•
You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of
this letter: (Dn nit uce if not aT nliZahh l; rJ(A
Page 3 of 3
TF YnI1 T)n NC1T (_'T1RI' '~'~' n~~ ~ rrr m __ ~' you do not cure the default within THIRTY (30) DAYS
of the date of this Notice, the lender int .nds to ex rcis i s rightc to a 1 rat the mnrtggge debt- T1us
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
fnreclognoon ynnr mnrtgag~d, rnngrt~=-
IF THE Mf7RTf A(iF. m FnRFr~r .nc~n rron,v __ 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 a nu cure +he ~efAll~t within the TATR7`V ~~pl WAY ~d~ yon, kill not he
re~nir .d n ~~ attnrne 'v c~f~c_
nTHF,R T.F,NT)F.R RFMFnTFS -- The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage. If your debt has been discharged in bankruptcy without
your having reaffirmed it, then lender cannot pursue this remedy.
RTGHT Tn C'TTRF THF, T)F.FATIT T PRTnR Tn 4NFRTFF'S SAT F - If you have not cured the default
within the THIRTY (30) DAY period and foreclosure proceedings have begun, yoL still hav th rightht to
Wore the defanlt and prevent the calf at any time inn to one h~nr h for th Sh riffs Sale Yrni may nc
axing the total amount th .n act do .~ hn ~s any late nr oth .r .barges then dam, reasonable attorn .y's fees and
costs connPc_.ted with the for loser cal and any other costs ono ted ~x~ith th Sh riffs Sal ac SpeCjTlPd
in wrlting~~ th . 1 ndPr and h~.ng~~, other rP~i~irP,,,A„rc ,,,,rla,~ rl,A mnrf n~pp 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.
F.ART,TF.RT PnSSTRi.F, SHRRTFF~C e ~ t ~' n ~ m~ __ It is estimated that the earliest date that such a
Sheriff s Sale of the mortgaged property could be held would be approximately ~ 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.
Name of Lender/Servicer: _Ocwen._Federal._Bank .............__._.,.................
Address: 12650 Integrity Drive
_Orlando.,._FL. 3.2....826 ..............................
Phone Number: ._..1.-877-596.-8580 ........................
Fax Number: 1-4.07.-737,-5693._ ...............
Contact Person: _Customer.. Seryice ...................._..........................................................
F,FFF(''T <7F SHF,RTFF'4 4AT F -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 Sheriff's
Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at
any time.
ASSTIMPTTnN nF MnRT('Af F __ you may not 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.
Page 4 of 4
NOTICE
The amount of your debt is as stated in the attached document. The name of the creditor
to whom the debt is owed is as named in the attached document. Unless you notify us within
30 days after receipt of this Notice and the attached document that the validity of the stated
debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us
in writing of a dispute within the 30 day period, we will obtain verification of the debt or a
copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an
admission of Lability on your part. Also, upon your written request within the 30 day period,
we will provide you with the name and address of the original creditor if different from the
current creditor.
If you notify us in writing within the 30 day period as stated above, we will cease collection
of your debt, or any disputed portion of it, until we obtain the information that is required
and mail it to you. Once we have mailed to you the required information, we will then
continue the collection of your debt.
This law firm is deemed to be a debt collector and this Notice and the attached document is
an attempt to collect a debt, and any information obtained will be used for that purpose.
UDREN LAW OFFICES, P.C.
/s/Mark J. Udren, Esquire
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill, NJ 08003-3620
(856) 669-5400
Page 5 of 5
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 TIiREE 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.
Page 6 of 6
HEMAP Consumer Credit Counseling Agencies
CUMBERLAND County
Report last updated: 10/15/2007 10:03:08 AM
Adams County Interfaith Housing Authority
40 E High Street
Gettysburg, PA 17325
717.334.1518
CCCS of Western PA
2000 Linglestown Road
Harrisburg, PA 17102
888.511.2227
Community Action Commission of Captial Region
1514 Deny Street
Harrisburg, PA 17104
717.232.9757
Loveship, Inc.
2320 North 5th Street
Harrisburg, PA 17110
717.232.2207
Maranatha
43 Philadelphia Avenue
Waynesboro, PA 17268
717.762.3285
PHFA
211 North Front Street
Harrisburg, PA 17110
717.780.3940
800.342.2397
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V E R I F I C A T I O N
The undersigned, hereby states that he/she is the attorney for
the Plaintiff, a corporation unless designated otherwise; that
he/she is authorized to make this Verification and does so because
of the exigencies regarding this matter, and because Plaintiff must
verify much of the information through agents, and because he/she
has personal knowledge of some of the facts averred in the
foregoing pleading; and that the statements made in the foregoing
pleading are true and correct to the best of his/her knowledge,
information and belief and the source of his information is public
records and reports of Plaintiff's agents. The undersigned
understands that this statement herein is made subject to the
penalties of 18 Pa.C.S. Section 4904 relating to unsworn
falsification to authorities.
UD~£EN LAW -OFF CES , P . C .
BY:~
Attor fob Plaintiff
MARK ~REN, ESQUIRE
STUAR ~~ NNEG, ESQUIRE
LORRAINE OYLE, ESQUIRE
ALAN M. M ATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
LOUIS A. SIMONI, ESQUIRE
ADAM L. KAYES, ESQUIRE
MARGUERITE L. THOMAS, ESQUIRE
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #043 02
STUART WINNEG, ESQUIRE - ID #453 62
LORRAINE DOYLE, ESQUIRE - ID #34 576
ALAN M. MINATO, ESQUIRE - ID #75 860
CHANDRA M. ARREMA, ESQUIRE - ID #203437
ADAM RAYES, ESQUIRE - ID #86408
MARGUERITE THOMAS, ESQUIRE - ID #204460
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400 pleadings@udren.com
Deutsche Bank National Trust :COURT OF COMMON PLEAS
Company as .Trustee for the :CIVIL DIVISION
Registered Holder of Soundview :Cumberland County
Home Loan Trust 2006-EQ1
Asset-Backed Certificates,
Series 2006-EQ1 NO. 10-3814
12650 Ingenuity Drive
Orlando, FL 32826 ..~.
C3
Plaintiff ,~
-
v . ~-
~
`
Steve W. Clark ~. ~
Kristi K. Clark
~~" --n a
;
1392 Lowther Road
~~~~ ~ ~
~?'~+
Camp Hill, PA 17011
D
f
d ~''C W ~~
e
en
ant (s )
SUGGESTION OF SAN&RUPTCY
To the Prothonotary:
Kindly note on the record that the above Defendant, Steve Willard
Clark d.b.a. C.W. Clark has filed Chapter 13 Bankruptcy in the
Middle District of Pennsylvania on 08/26/2010, Bankruptcy Case No.
10-06974.
UDREN LAW OFFICES, P.C.
BY:~
Attorneys or Plaintiff
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
ADAM KAYES, ESQUIRE
MARGUERITE THOMAS, ESQUIRE
o ~ i~c~c~a -~
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
?f?tp ui ?umbrt?
y.
O MG5 : _-ERIFF
FILED-OFFICE
'F TAE P R 0 T H0 0 fAI
2010 SEP 23 PM 3:4 2
CUMBEREAt II CGIMT',,'
°EPMSY VAMA
Deutsche Bank National Trust Company Case Number
vs. 2010-3814
Steve W Clark (et al.)
SHERIFF'S RETURN OF SERVICE
09/21/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ is returned
STAYED, per letter of instruction from Attorney Udren on 8/27/10
SHERIFF COST: $74.38
September 23, 2010
SO ANSWERS,
RON R ANDERSON, SHERIFF
- UD Pot. C'0 .
4'7 &L Pd
7? --, 11o 9
a4(f,70)
Ic CountySuite Shedfi, Te eoso8 Inc.
r+
i
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
Deutsche Bank National Trust : COURT OF COMMON PLEAS
Company as Trustee for the : CIVIL DIVISION
Registered Holder of Soundview : Cumberland County
Home Loan Trust 2006-EQ1 C w
Asset-Backed Certificates,
rn mCrii _
Series 2006-EQ1 NO. 10-3814 = -� ,
Plaintiff co
V. x�..�
Steve W. Clark
Kristi K. Clark o
Defendant (s)
PRAECIPE TO FILE PROOF OF SERVICE
TO THE PROTHONOTARY:
Kindly file the attached Proofs of Service with regard to
the captioned matter.
Date: March e , 2013
UDREN LAW ES, P.C.
BY:
A r laintiff
ttPA j
T - _
' Service of Process by
Dt utWhe flank National Trust Company,as Trustee,et.al., -
Plaintiff(s) APS International, Ltd.
VS. 1-800-328-7171
Steve W.Clark,et,al.,Defendant(s)
_ W_ x APS International Plaza
7800 Glenroy Road
Minneapolis,MN 55439-3122
APS File H: 121707-0001
_ AFFIDAVIT OF DUE AND DILIGENT ATTEMPT
Service of Process on:
i UDREN LAW OFFICES --Kristi K.Clark
Ms.Henni Crommartv Court Case No.Cumberland Co 10-3814
111 Woodcrest Rd.,Ste.200
Cherry Hill,NJ 08003-3620
Customer File: N08120062-2
State of. 1 V �I ss.
County of:
Name of Server: (_'4'r,-5+i& , 'L e.,'e , undersigned, being duly sworn,deposes and says
that at all times mentioned herein,s/he was of legal age and was not a party to this action;
Documents Served: the undersigned attempted to serve the documents described as:
Notice of Sheriff's Sale of Real Property
Service of Process on: The undersigned attempted to serve the documents on
Kristi K.Clark
and after due and diligent efforts,was unable to effect service.
Attempts: The following is a list of the attempts made to effect service:
Datesrrime/Address Attempted: 6 Pennsylvania Ave.,Apt A,Camp Hill,PA 17011 rr I
Reason for Non-Service: -'2 �A z '!y f ph . P_r i r e rr7n� y_.? f..re )y 4o F
Dates(rime/Address Attempted: A10 rf h ho LA Z ter.5 0&4 S i at J
Reason for Non-Service:
DateslTime/Address Attempted:
Reason for Non-Service:
❑ Based upon the above stated facts,Affiant believes the defendant is avoiding service.
Signature of Server: Undersigned declares under penalty of perjury Subscribed and swxn to before me this
that the foregoing is true and correct. j5d r�f 2
Signature of Server Pu t Commis n xpires)
APS International,Ltd.
COMMONWEALTH OF PENNSYLVANIA
Notarial seal
M.Michelle Q*m,Notary Publk
Cattbk Dom,Qanfa:tiand Cotahty
GOttlf114lilon Bcphas 9,2016
MOCK PEtaiS VMA AMMKIM OF NOTARIES
• Service of Process by
e .Deutsche Bank National Trust Company,as Trustee,et.al., �,.---.,
Plaintiff(s) APS International, Ltd.
VS. _ 1-800-328-7171
Steve W.Clark,et.al.,Defendant(s) APS International Plaza
j. 7800 Clenroy Road
Minneapolis,MN 55439-3122
APS File N: 121707-0001
_ AFFIDAVIT OF DUE AND DILIGENT ATTEMPT
Service of Process on:
UDREN LAW OFFICES I --Steve W.Clark
Ms.Henni Crommarty Court Case No.Cumberland Co 10-3814
11 l Woodcrest Rd.,Ste.200
Cherry Hill,NJ 08003-3620
Customer File: N08120062-2
State of:qf
ss. — — --- .— — — -- -- — — — - — — — — — — -- — -- -- — - — - -
County
Name of Server: r Lf al 41 A„ J undersigned, being duly sworn,deposes and says
that at all times mentioned herein,s/he was of legal age and was not a party to this action;
Documents Served: the undersigned attempted to serve the documents described as:
Notice of Sheriff's Sale of Real Property
Service of Process on: The undersigned attempted to serve the documents on
Steve W. Clark
and after due and diligent efforts,was unable to effect service.
Attempts: The following is a list of the attempts made to effect service:
Daicsfrime/Address Attempted: 6 Pennsylvania Ave.,Apt A,Camp Hill,PTAs 17011 f
Reason for Von-Service:�� �? o!%yr?M -' JL°C.krG� yn �" �hTYtsnLt he AI t
Dates[Iime/AddressAttempled: ill0 e0 4C_';6 I IUD b1.Z7_tr4 04�Sjr.�Q
Reason for Non-Service:
DatesiTime/Address Attempted:
Reason for Non-Service:
❑ Based upon the above stated facts,Affiant believes the defendant is avoiding service.
Signature of Server: Undersigned declares under penalty of perjury rKdlda d nd swo to before me this
that the oregoing is tru nd correct. 20
Signature of Server 5otary Public (Commission xpires)
APS International, Ltd.
W104 NWEALTM Of Pat'Tl-wanes►
NoWai seal
Notary public
9 X16
EmL. Commisslon t8�,FBtNSMMBA AS,90MM01 OF NOTARIES
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
Deutsche Bank National Trust Company, COURT OF COMMON PLEAS
As Trustee for Soundview Home Loan CIVIL DIVISION
Trust 2006-EQ1 Asset-Backed Certificates, CUMBERLAND County
Series 2006-EQ1, Pooling and Servicing ` --
Agreement dated as of September 1, 2006
Plaintiff NO. 10-3814
V.
Kristi K. Clark; ET AL
Defendant(s) �j a
MOTION FOR SPECIAL SERVICE PURSUANT
TO SPECIAL ORDER OF COURT
Plaintiff, by its counsel, moves this Honorable Court for an Order directing service of the
Notice of Sale upon Defendant(s):
STEVE WILLARD CLARK DBA C.W. CLARK, KRISTI K. CLARK,
by regular mail and certified mail, and by posting the mortgaged premises and in support thereof
avers the following:
1. Process was unable to be served at the then last known address of said Defendant(s) as
follows:
STEVE WILLARD CLARK DBA C.W. CLARK
1392 LOWTHER ROAD
CAMP HILL, PA 17011
KRISTI K. CLARK
1392 LOWTHER ROAD
CAMP HILL, PA 17011
A copy of the Return of Service is attached hereto as Exhibit"A".
2. Process was unable to be served at the then last known address of said Defendant(s) as
follows:
STEVE WILLARD CLARK DBA C.W. CLARK
6 PENNSYLVANIA AVE,APT.A
CAMP HILL, PA 17011
KRISTI K. CLARK
6 PENNSYLVANIA AVE,APT. A
CAMP HILL, PA 17011
A copy of the Return of Service is attached hereto as Exhibit`B".
3. Pursuant to Pa.R.C.P. 430, Plaintiff made a Good Faith Investigation, the report thereof
being attached hereto as Exhibit"C".
4. Said investigation was unable to determine an alternate address for said Defendant(s).
5. Plaintiff conducted a Postal Search Inquiry which did not reveal any new addresses or
information. A copy of the Postal Search results is attached hereto as Exhibit"D".
6. The last known address of Defendant(s) is as set forth in the attached Exhibits.
WHEREFORE, Plaintiff prays and respectfully requests that this Honorable Court enter
an Order pursuant to Pa.R.C.P. 430 directing service of the Notice of Sale upon said in paragraph
1, by regular mail and certified mail, and by posting the mortgaged premises.
UDREN LAW OFFICES, P.C.
B
Attorneys for Plaintiff
SALVATORE CAROLLO, ESQUIRE
PA 1D 311050
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
Deutsche Bank National Trust Company Case Number
vs.
Steve W Clark(et al.) 2010-3814
SHERIFF'S RETURN OF SERVICE
01/03/2013 07:35 PM-Deputy William Cline, being duly sworn according to law,states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the
above titled action, upon the property located at 1392 Lowther Road, Camp Hill, PA 17011, Cumberland
County.
02/06/2013 Ronny R. Anderson, being duly sworn according to law, states he made diligent search and inquiry for the
within named Defendant to wit: Steve W. Clark, but was unable to locate the Defendant in his bailiwick.
The Sheriff therefore returns the within requested Real Estate Writ, Notice of Sale, Legal Description as
"Not Served"at 1392 Lowther Road, Camp Hill, PA 17011, per neighbor the couple is not longer together
and rarely seen at this address, 8 service attempts were made,
but defendant could not be located prior to expiration date.
02/06/2013 Ronny R.Anderson, being duly sworn according to law, states he made diligent search and inquiry for the
within named Defendant to wit: Kristi K. Clark, but was unable to locate the Defendant in his bailiwick.
The Sheriff therefore returns the within requested Real Estate Writ, Notice of Sale, Legal Description as
"Not Served"at 1392 Lowther Road, Camp Hill, PA 17011, per neighbor the couple is not longer together
and rarely seen at this address, 8 service attempts were made,
but defendant could not be located prior to expiration date.
SHERIFF COST: $923.70 SO ANSWERS,
February 06, 2013 RONNY R ANDERSON, SHERIFF
EXHIBITA
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor -
Deutsche Bank National Trust Company Case Number
vs.
Steve W Clark(et al.) 2010-3814
SHERIFF'S RETURN OF SERVICE
01/03/2013 07:35 PM-Deputy William Cline, being duly swom according to law,states service was performed by
posting a true copy of the requested Real Estate Writ,Notice and Description,and Sale Handbill in the
above titled action, upon the property located at 1392 Lowther Road,Camp Hill, PA 17011, Cumberland
County.
SHERIFF COST: $908.70 SO ANSWERS,
2z 7
January 22,2013 RONW R ANDERSON,SHERIFF
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Commonwealth County of Cumberland Court of Common Pleas
Of Pennsylvania Civil Division
Plaintiff(s)
Deutsche Bank National Trust Company
vs
Defendant(s)
Steve Clark,Kristi K.Clark
AFFIDAVIT OF DILIGENT SEARCH AND INQUIRY
I,Randy Sheppard,II,do hereby swear and affirm that I made the following
diligent search and inquiry on defendant,Steve Clark:
1. On February 7, 2013,I conducted a Skip Trace,the results of which indicated the
defendant's current residence is 1392 Lowther Road,Camp Hill,PA,17011.
2. On February 7,2013,I conducted an Internet search for the Death Records of the
Defendant,the results of which indicated that the defendant is not deceased.
3. On February 7,2013,I conducted an Internet search for the Voter Registration
Records of the Defendant,the results of which indicated that the defendant is a
registered voter at the address of 1392 Lowther Road,Camp Hill,PA,17o11.
4. On February 7,2013,I conducted an Internet search for the Motor Vehicle
Records of the Defendant,with no results obtained from the search.
5. On February 7,2013,I conducted an Internet search of Facebook,Twitter,
Yahoo!,Google and Bing with results from mylife.com indicating the defendant
has an address in Camp Hill,PA.
6. On February 7,2013 at 7:17pn1 I placed a phone call to the defendant's neighbor,
S.Campbell(717-763-1245),of 1393 Lowther Road,Camp Hill,PA,17o11 to
inquire about the defendant's last known address.There was no answer.
7. On February 7,2013 at 7:17pm I placed a phone call to the defendant's neighbor,
Joan Knadler(717-737-6292),of 1390 Lowther Road,Camp Hill,PA, 17011 to
inquire about the defendant's last known address. A woman answered and did
not recognize the name.
I SOLEMNLY swear and affirm that the foregoing statements 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.Section 4904
relating to unsworn falsification to authorities.
7- 3
Date RindfSh4p II
Skip Trace Manager
De Nova Attorney Services,Inc.
P.O. Box 20215
Baltimore,MD 21284
Our Job Serial Number: NOV-2013000752
Ref: 08120o62-2
EXHIBIT C
Commonwealth County of Cumberland Court of Common Pleas
Of Pennsylvania Civil Division
Plaintiff(s)
Deutsche Bank National Trust Company
vs
Defendant(s)
Steve Clark, Kristi K.Clark
AFFIDAVIT OF DILIGENT SEARCH AND INQUIRY
I,Randy Sheppard,II,do hereby swear and affirm that I made the following
diligent search and inquiry on defendant,Kristi K.Clark:
i. On February 7,2013,I conducted a Skip Trace,the results of which indicated the
defendant's current residence is 1392 Lowther Road,Camp Hill,PA,17o11.
2. On February 7,2013, I conducted an Internet search for the Death Records of the
Defendant,the results of which indicated that the defendant is not deceased
3. On February 7,2013,I conducted an Internet search for the Voter Registration
Records of the Defendant,the results of which indicated that the defendant is a
registered voter at the address of 1392 Lowther Road,Camp Hill,PA, 17011.
4. On February 7,2013,I conducted an Internet search for the Motor Vehicle
Records of the Defendant,with no results obtained from the search.
5. On February 7,2013,I conducted an Internet search of Facebook,Twitter,
Yahoo!,Google and Bing with results from mylife.com indicating the defendant
has an address in Camp Hill,PA.
6. On February 7,2013 at 7:17Pm I placed a phone call to the defendant's neighbor,
S.Campbell(717-763-1245),of 1393 Lowther Road,Camp Hill,PA,17011 to
inquire about the defendant's last known address.There was no answer.
7. On February 7,2013 at 7:17Pm I placed a phone call to the defendant's neighbor,
Joan Knadler(727-737-6292),of 1390 Lowther Road,Camp Hill,PA,17o11 to
inquire about the defendant's last known address. A woman answered and did
not recognize the name.
I SOLEMNLY swear and affirm that the foregoing statements 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.Section 4904
relating to unworn falsification to authorities.
Date AwQy A4g paR II
Skip Trace Manager
De Novo Attorney Services,Inc.
P.O. Box 20215
Baltimore,MD 21284
Our Job Serial Number: NOV-2013000753
Ref: 08120062-2
Udren Law Offices, PC.
Woodcrest Corporate Center
111 Wooderest Road
Cherry Hill, New Jersey 08003
TO:POSTMASTER DATE: February 11,2013
Camp H94 PA,17011 CASE No.:08120062-2
Please furnish the new address or the name and street address(if a boxholder)for the following. Please take special
note that this request deals with a matter pending in Court and,therefore,any information available would be greatly
appreciated,even if any existing forwarding order has expired.
NAME:Kristi K.Clark
LAST KNOWN ADDRESS: 1392 Lowther Road,Camp Hill,PA 17011
NOTE. The name and last known address are required for change of address information. The name, if kwown, and post
office box address are required for boxholder information.
The following information is provided in accordance with 39CFR 265.6(d)(6)(ii). There is no fee for providing
boxholder information. The fee for providing change of address information is waived in accordance with 39CFR 265.6(d)(1)
and(2)and corresponding Administrative Support Manual 352.44a and b.
1. Capacity of requester: Attorney at Law
2. Statute/regulation that empowers me to serve process(not required if requester is an attorney)
3. The names of known parties to the litigation:(Ocwen Loan Servicing,LLC) vs.NAME:Kristi K.Clark
4. The Court in which the case has been or will be heard: Cumberland County Pennsylvania
5. The docket or other identifying number if one has been issued: 10-3814
6. The capacity in which this individual is to be served(defendant,witness): Defendant(s)
WARNING
THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR
BOXHOLDER INFORMATION FOR ANY OTHER PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN
CONNECTION WITH ACTUAL OR PROSPECTIVE LIITGA77ON COULD RESULT IN CRIMINAL PENALTIES
INCLUDING A FINE OF UP TO,$10,000 OR IMPRISONMENT OR(2) TO AVOID PAYMENT OF THE FEE FOR CHANGE
OF ADDRESS INFORMATION OF NOT MORE THAN FIVE YEARS, OR BOTH. (TITLE 18 U.S.C. SECTION 1001)
I certify that the above information is true and that the address information is needed and will be used solely for
service of legal process in connection with actual or prospective litigation.
U en Law Offices,PC.
dcrest Corporate Center
111 WoodcreskRoad
C Hill,Ne 8003
POST OFFICE USE ONLY
NEW ADDRESS/SOXHOLDER'S NAME AND STREET ADDRESS u A(� YSa
Not known at address given _No such number AFFIX POSTMARK HERE
Left no forwarding _No change of address on file Q
No such street _GOOD AS ADDRESSED (a T 01as i!�{ipu a, Ave, Apk A
d '� 7
/0'4f
i s z'
EXHIBIT D
Udren Law Offices, PC.
Woodcrest Corporate Center
111 Woodcrest Road
Cherry Hill, New Jersey 08003
TO: POSTMASTER DATE: February 11,2013
Camp Hill,PA,17011 CASE No.:0$120062-2
Please furnish the new address or the name and street address(if a boxholder)for the following. Please take special
note that this request deals with a matter pending in Court and,therefore,any information available would be greatly
appreciated,even if any existing forwarding order has expired.
NAME: Steve Willard Clark dba C.W. Clark
LAST KNOWN ADDRESS: 1392 Lowther Road,Camp Rill,PA 17011
NOTE. The namv and last lmol r*_address are reauired for change of address information. The name, if known, and post
office box address are required for boxholder information.
The following information is provided in accordance with 39CFR 265.6(d)(6)(ii). There is no fee for providing
boxholder information. The fee for providing change of address information is waived in accordance with 39CFR 265.6(d)(1)
and(2)and corresponding Administrative Support Manual 352.44a and b.
1. Capacity of requester: Attorney at Law
2. Statute/regulation that empowers me to serve process(not required if requester is an attorney)
3. The names of known parties to the litigation:(Oewen Loan Servicing,LLC) vs.NAME: Steve Willard Clark dba
C.W.Clark
4. The Court in which the case has been or will be heard: Cumberland County Pennsylvania
5. The docket or other identifying number if one has been issued: 10-3814
6. The capacity in which this individual is to be served(defendant,witness): Defendant(s)
WARNING
THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR
BOXHOLDER INFORMATION FOR ANY OTHER PURPOSE OTHER TIL4N THE SERVICE OF LEGAL PROCESS I'V
CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES
INCLUDING A FINE OF UP TO$10,000 OR IMPRISONMENT OR(2) TO AVOID PAYMENT OF THE FEE FOR CHANGE
OF ADDRESS INFORMATION OF NOT MORE THAN FIVE YEARS, OR BOTH. (TITLE 18 U.S.C.SECTION 1001)
I certify that the above information is true and that the address information is needed and will be used solely for
service of legal process in connection with actual or prospective litigation.
Udren Law Offices,PC.
Woodcrest Corporate Center
111 Woodcrest Road
New Terse 8003
BY: . / 5211,
.
POST OFFICE USE ONLY
NEW ADDRESSBOXHOLDER'S NAME AND STREET ADDRESS
_Not known at address given _No such number AFFIX POSTMARK HERE
_Left no forwarding No change of address on file
No such street GOOD AS ADDRESSED
'C:�(Er Hoz I i q3-j
�`cl`1�1Q�'
Udren Law Offices, PC.
Woodcrest Corporate Center
111 Woodcrest Road
Cherry Mill, New Jersey 08003
TO:POSTMASTER DATE: March 13,2013
Camp Hill,PA,17011 CASE No.:08120062-2
Please furnish the new address or the name and street address(if a boxholder)for the following. Please take special
note that this request deals with a matter pending in Court and,therefore,any information available would be greatly
appreciated,even if any existing forwarding order has expired.
NAME: Steve W.Clark
LAST KNOWN ADDRESS: 6 Pennsylvania Avenue,Apt.A,Camp Hilt,PA 17011
NOTE: The name and last known address are required for change of address information. The name, if known, and post
office box address are required,for boxholder information.
The following information is provided in accordance with 39CFR 265.6(d)(6)(ii), There is no fee for providing
boxholder information. The fee for providing change of address information is waived in accordance with 39CFR 265.6(d)(1)
and(2)and corresponding Administrative Support Manual 352.44a and b.
I. Capacity of requester. Attorney at Law
2. Statute/regulation that empowers me to serve process(not required if requester is an attorney)
3. The names of known parties to the Iitigation: (Ocwen Loan Servicing,LLC) vs.NAME:Steve W.Clark
4, The Court in which.the case has been or will be heard: Cumberland County Pennsylvania
5. The docket or other identifying number if one has been issued: 10-381.4
6. The capacity in which this individual is to be served(defendant,witness): Defendant(s)
WARNING
THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR
BOXHOLDER INFORMATION FOR ANY OTHER PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN
CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES
INCL UDING A FINE OF UP TO$10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE
OF ADDRESS INFORMATION OF NOT MORE THAN FIVE YEARS, OR BOTH. (TITLE 18 U.S.C. SECTION 1001)
1 certify that the above information is true and that the address information is needed and will be used solely for
service of legal process in connection with actual or prospective litigation.
Udren Law Offices,PC.
Woodcrest Corporate Center
"}1 Woodc oad
Ferry Hill, ew ers y 08,003
By
— sure Specialist
L
POST OFFICE USE ONLY
NEW ADDRESSBOXHOLDER'S NAME AND ST D�tESS
�
�[Not known at address given No such number
� y
`�"�► Left no forwarding —_No change of address on file F
No such street GOOD AS ADDRESSED
ti
i
Udren Law Offices, PC.
Woodcrest Corporate Center
111 Woodcrest Road
Cherry Hill, New Jersey 08003
TO: POSTMASTER DATE: March 13,2013
Camp Hill,PA,17011 CASE No.:08120062-2
Please furnish the new address or the name and street address(if a boxholder)for the following. Please take special
note that this request deals with a matter pending in Court and,therefore,any information available would be greatly
appreciated,even if any existing forwarding order has expired.
NAME: Kristi K.Clark
LAST KNOWN ADDRESS: 6 Pennsylvania Avenue,Apt.A,Camp Hill,PA 17011
NOTE: The name and last known address are required for change or address information. The name, if known, and post
office box address are required for boxholder information.
The following information is provided in accordance with 39CFR 265.6(d)(6)(ii). There is no fee for providing
boxholder information. The fee for providing change of address information is waived in accordance with 39CFR 265.6(d)(1)
and(2)mid corresponding Administrative Support Manual 352.44a and b.
1. Capacity of requester: Attorney at Law
2. Statute/regulation that empowers me to serve process(not required if requester is an attorney)
3. The names of known parties to the litigation: (Ocwen Loan Servicing,LLC) vs.NAME:Kristi K.Clark
4. The Court in which the case has been or will be heard: Cumberland County PennsyLyania
5. The docket or other identifying number if one has been issued: 10-3814
6. The capacity in which this individual is to be served(defendant,witness): Defendant(s)
WARNING
THE SUBMISSION OF FALSE INFORMATION TO OBTAINAND USE CHANGE OF ADDRESS INFORMATION OR
BOXHOLDER INFORMATION FOR ANY OTHER PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN
CONNECTION WITHACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENAL77ES
INCLUDING A FINE OF UP TO$10,000 OR IMPRISONMENT OR(2)TO AVOID PAYMENT OF THE FEE FOR CHANGE
OF ADDRESS INFORMATION OF NOT MORE THAN FIVE YEARS, OR BOTH. (TITLE 18 U.S.C.SECTION 1001)
I certify that the above information is true and that the address information is needed and will be used solely for
service of legal process in connection with actual or prospective litigation.
tidren Law Offices,PC.
Woodcrest Corporate Center
11 Woodcrest Road
Hill,New Jersey O 03
t _
BY:
—/4t F closure Specia ist
POST OFI+ICE USE ONLY
NEW ADDRESS/BOXHOLDER'S NAME AND STREET ADDRESS
Not known at address given —No such number -A3ies-FAct HERE.
_Left no forwarding _No change of address on file
No such street GOOD AS ADDRESSED
\ t- t
UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
I
Deutsche Bank National Trust Company, COURT OF COMMON PLEAS
As Trustee for Soundview Home Loan CIVIL DIVISION
Trust 2006-EQ1 Asset-Backed Certificates, CUMBERLAND County
Series 2006-EQ1, Pooling and Servicing
Agreement dated as of September 1, 2006
Plaintiff NO. 10-3814
V.
Kristi K. Clark; ET AL
Defendant(s)
MEMORANDUM OF LAW
Pennsylvania Rule of Civil Procedure 430(a) specifically provides:
(a) If service cannot be made under the applicable rule the plaintiff may move
the court for a special order directing the method of service. The motion shall be
accompanied by an affidavit stating the nature and extent of the investigation
which has been made to determine the whereabouts of the defendant and the
reasons why service cannot be made.
NOTE: A sheriffs return of"not found" or the fact that a defendant has moved
without leaving a new forwarding address is insufficient evidence of concealment.
Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). Notice of intended
adoption mailed to last known address requires a "good faith effort" to discover
the correct address. Adoption of Walker, 468 Pa. 165, 360 A2d 603 (1976).
An illustration of a good faith effort to locate the defendant includes (1) inquiries
of postal authorities including inquiries pursuant to the Freedom of Information
Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and
employers of the defendant and (3) examinations of local telephone directories,
voter registration records, local tax records, and motor vehicle records.
As set forth in the Returns of Service marked Exhibits "A" and `B" the Sheriff and/or Process
Server has been unable to serve the following Defendant(s) at their last known addresses.
A good faith effort to discover the whereabouts of the Defendant(s) has been made as evidenced
by the attached Affidavit of Good Faith Investigation marked Exhibit "C".
Plaintiff conducted a Postal Search Inquiry which did not reveal any new addresses or
information. A copy of the Postal Search results is attached hereto as Exhibit"D".
WHEREFORE, Plaintiff prays and respectfully requests service of the Notice of Sale
upon Defendant(s)by regular mail and certified mail, and by posting the mortgaged premises.
UDREN LAW OFFICES, P.C.
BY-
Attorneys for Plaintiff
SALVATORE CAROLLO, ESQUIRE
PAID 311050
VERIFICATION
The undersigned hereby states that he/she is the Attorney for
the Plaintiff in this action, that he/she is authorized to make
this Verification, and that the statements made in the foregoing
MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT are
true and correct to the best of his/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 .
Date: 3
UDREN LAW OFFICES, P . C.
BY:
Attorneys for Plaintiff
SALVATORE CAROLLO, ESQUIRE
PA 1D 311050
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
Deutsche Bank National Trust Company, COURT OF COMMON PLEAS
As Trustee for Soundview Home Loan CIVIL DIVISION
Trust 2006-EQ1 Asset-Backed Certificates, CUMBERLAND County
Series 2006-EQ1, Pooling and Servicing
Agreement dated as of September 1, 2006
Plaintiff NO. 10-3814
V.
Kristi K. Clark; ET AL
Defendant(s)
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing was served by U.S. mail on
each of the attached parties or their attorneys this 27TH day of March, 2013.
Udren Law Offices, P.C.
Attorney for Plaintiff
By:
SALVATORE CAROLLO, ESQUIRE
PA 1D 311050
SERVICE LIST
CUMBERLAND COUNTY, PENNSYLVANIA
CCP. No. Docket Number: 10-3814
NAME: STEVE WILLARD CLARK DBA C.W. CLARK
MAILING ADDRESS: 1392 LOWTHER ROAD
CAMP HILL, PA 17011
NAME: KRISTI K. CLARK
MAILING ADDRESS: 1392 LOWTHER ROAD
CAMP HILL, PA 17011
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL TRIAL DIVISION
Deutsche Bank National Trust Company,
As Trustee for Soundview Home Loan ; —_
Trust 2006-EQ1 Asset-Backed Certificates, r°
Series 2006-EQ1, Pooling and Servicing
Agreement dated as of September 1,2006
Plaintiff ,
V. _
Kristi K. Clark; ET AL NO. 10-3814 �1
Defendant(s) -�
ORDER
AND NOW, this Z 4 day of t'»1 , 2013, uponVonsideration of Plaintiffs Motion and
the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of
the Notice of Sale on Defendant(s), Steve Willard Clark dba C.W.dark, Kristi K. Clark,
shall be complete when Plaintiff or its counsel or agent has served true and correct copies of the
Notice of Sale by posting the mortgage premises at:
1392 LOWTHER ROAD
CAMP HILL, PA 17011
And by mailing by certified mail and regular mail to the last known address of Defendant(s) as
follows:
STEVE WILLARD CLARK DBA C.W. CLARK
1392 LOWTHER ROAD
CAMP HILL, PA 17011
KRISTI K. CLARK
1392 LOWTHER ROAD
CAMP HILL, PA 17011
BY TH COURT:
J.
✓ Ukeo Lav- �`C
f 3/j�
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
Ill WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
Deutsche Bank National Trust Company as : COURT OF COMMON PLEAS
Trustee for the Registered Holder of : CIVIL DIVISION
Soundview Home Loan Trust 2006-EQ1 Asset- ", Cumberland County C)
Backed Certificates, Series 2006-EQ1
Plaintiff rn
:;r_ -,Urn
v mac)
Steve W. Clark
C--
Kristi K. Clark :-- NO. 10-3814
Defendant (s)
AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1
Plaintiff, by its/his/her Attorney hereby verifies that:
1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is
attached hereto as Exhibit "A" , was sent to every recorded lienholder and every
other interested party known as of the date of the filing of the Praecipe for the
Writ of Execution, on the date (s) appearing on the attached Certificates of
Mailing.
2 . A Notice of Sheriff ' s Sale was sent to Defendant (s) by regular mail and
certified mail on the date appearing on the attached Return Receipt, which was
signed for by Defendant (s) on the date specified on the said Return Receipt.
Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B" .
3 . If a Return Receipt is not attached hereto, then service was by personal
service on the date specified on the attached Return of Service, attached hereto
as Exhibit "B" .
4. If service was by Order of Court, then proof of compliance with said order
is attached hereto as Exhibit 1113" .
All Notices were served within the time limits set forth by Pa Rule C.P. 3129.
This Affidavit .is made subject to the penalties of 18 Pa.C.S. Section 4904
relating to unsworn falsification to authorities.
Dated: May/7 2013 UDREN LAW OFFICES, P.C.
BY:
- <W
At r ' s for Plaintiff
I Eric Kishhll'IFlh, rsquire
PA ;U sjoila
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings @udren.com
Deutsche Bank National Trust : COURT OF COMMON PLEAS
Company as Trustee for the : CIVIL DIVISION
Registered Holder of Soundview : Cumberland County
Home Loan Trust 2006-EQ1
Asset-Backed Certificates, : MORTGAGE FORECLOSURE
Series 2006-EQ1
Plaintiff
V.
Steve W. Clark : NO. 10-3814
Kristi K. Clark
Defendant (s)
AMENDED AFFIDAVIT PURSUANT TO RULE 3129 . 1
AND RULE 76
Deutsche Bank National Trust Company as Trustee for the
Registered Holder of Soundview Home Loan Trust 2006-EQ1 Asset-
Backed Certificates, Series 2006-EQ1, Plaintiff in the above
action, by its undersigned attorney, upon information and belief,
Udren Law Offices, P.C. , sets forth, as of the date the Praecipe
for the Writ of Execution was filed, the following information
concerning the real property located at: 1392 Lowther Road, Camp
Hill, PA 17011
1 . Name and address of Owner(s) or reputed Owner(s) :
Name Address
Steve W. Clark 1392 Lowther Road
Camp Hill, PA 17011
Kristi K. Clark 1392 Lowther Road
Camp Hill, PA 17011
2 . Name and address of Defendant (s) in the judgment:
Name Address
SAME AS #1 ABOVE
3 . Name and address of every judgment creditor whose judgment is
a record lien on the real property to be sold:
Name Address
Capital One Bank 15000 Capital One Drive
Richmond, VA 23238
c/o James C. Warmbrodt, Esquire
Weltman Weinberg & Reis Co. LPA
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
4 . Name and address of the last recorded holder of every mortgage
of record:
Name Address
Deutsche Bank National Trust 12650 Ingenuity Drive
Company as Trustee for the Orlando, FL 32826
Registered Holder of
Soundview Home Loan Trust
2006-EQ1 Asset-Backed
Certificates, Series 2006-EQ1
Pennsylvania Housing Finance 211 North Front Street
Agency Harrisburg, PA 17101
MERS as Nominee for P.O. Box 2026
EquiFirst Corporation Flint, MI 48501-2026
S . Name and address of every other person who has any record lien
on the property:
Name Address
None
6 . Name and address of every other person who has any record
interest in the property and whose interest may be affected by
the sale:
Name Address
Real Estate Tax Dept . 1 Courthouse Square
Carlisle, PA 17013
Domestic Relations Section 13 North Hanover Street
Carlisle, PA 17013
Commonwealth of PA, Bureau of Compliance, PO Box 281230
Department of Revenue Harrisburg, PA 17128-1230
7 . Name and address of every other person of whom the plaintiff
has knowledge who has any interest in the property which may be
affected by the sale:
Name Address
Tenants/Occupants 1392 Lowther Road,
Camp Hill, PA 17011
I verify that the statements made in this affidavit are true and
correct to the best of my information and belief . I understand
that false statements herein are made subject to the penalties of
18 Pa.C.S . sec . 4904 relating to unsworn falsification to
authorities.
DATED: May )7 2013
UDREN LAW OFFICES, P.C.
I Eric Kishhat.igh, r5gL,I;i
BY: PA J .3J0 i 8
A n s for Plaintiff
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
Deutsche Bank National Trust Company COURT OF COMMON PLEAS
as Trustee for the Registered Holder of € CIVIL DIVISION
Soundview Home Loan Trust 2006-EQ1 '_ Cumberland County
Asset-Backed Certificates, Series 2006-
EQ1
Plaintiff € NO. 10-3814
V.
Steve W. Clark
Kristi K. Clark
Defendant(s)
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
OWNER(S): Steve W. Clark and Kristi K. Clark
PROPERTY: 1392 Lowther Road, Camp Hill, PA 17011
Improvements: RESIDENTIAL DWELLING .
The above captioned property is scheduled to be sold at the Cumberland County
Sheriffs Sale on March 6, 2013, at 10:00am, at the Cumberland County Courthouse
Commissioners Hearing Room, 2ND Floor, Carlisle, PA 17013. Our records indicate
that you may hold a mortgage or judgment on the property which will be extinguished by
the sale. You may wish to attend the sale to protect your interests.
A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff
not later than 30 days after sale. Distribution will be made in accordance with the
schedule unless exceptions are filed thereto within 10 days after the filing of the
schedule.
EKNbE A
Name and
Address Henrietta Crommarty Registered Affix stamp here if issued as
of Sender Return Receipt for Check appropriate block for certificate of mailing or for
UDREN LAW OFFICES,P.C. �Insured Merchandise Registered Mail:
111 Woodcrest Road,Suite 200 g additional copies of this bill.
Cher Hill NJ 08003 ❑COD ❑Int-I Recorded Del. ❑With Postal Insurance
Cherry � Postmark and Date of
Certified ❑Express Mail ❑Without postal Insurance Receipt
Article Handling Ad' Insured Due R.R. S.D. S.H.
Line Number Name of Addressee,Street,and Post Office Address Postage Fee Charge Value Value Sender Fee Fee Fee Remarks
(If Renic.) If COD
1 CUMBERLAND COUNTY REAL ESTATE TAX DEPT
1 COURTHOUSE SQUARE,CARLISLE,PA 17013 LU
2 DOMESTIC RELATIONS SECTION crc O I N '00
13 N.HANOVER STREET,CARLISLE,PA 17103 cl 00
3 PA DEPT OF REV,BUREAU OF COMPLIANCE, LN N o Fd-
P.O.BOX 281230,HARRISBURG,PA 17128-1230 N M 0 o O
4 10-3814 Tenants/Occupants 7 Q N d( L mt�
1392 Lowther Road,Camp Hill PA 17011 0 � jn
5 k-- o e t�
6 03/06/2013 PHFA
211 North Front Street,Harrisburg,PA 17101 aa�seH
7 MERS,as Nominee for Equifirst Corporation fl s
P.O.Box 2026, Flint,MI 48501-2026 f�J
8 Capital One Bank ;
15000 Capital One Drive,Richmond,VA 23238
9 Capital One Bank Go James C.Warmbrodt,Esquire
Weltman Weinberg&Reis Co LPA
436 Seventh Avenue,Suite 1400
Piftsbuigh,PA 15219
10
11
CQ,tsT
12 3p0�
13
14 r�i
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Total number of Pieces Total Number of Pieces Postmaster,Per(Name of Receiving Employee) The full declaration of value is required on all domestic and international registered mail.The maximum indemnity
Listed by Sender Received at Post Office payable for the raconstrui�iop�,nonnegotiable documents under Express Mail document reconstruction insurance is
$50,000 per piece subjec'tq_9li4t of$50q,000,per occurrence.The maximum indemnity payable on Express Mail
merchandise is$500.The ig> um indemnity payable Is$25,000 for registered mail,sent with optional postal
insurance.See bdtnestic Mail Manual R900,S913,and 8921 for limitations of
coverage on insured and COD mail.See International Mail Manual for limitations of coverage on international mail.
Special handling charges apply only to third and forth class parcels.
PS Form 3877, February 1994 Form Must be Completed by Typewriter,-ink or.Ball-Point Pen
Steve W. Clark; MJU # 08120062-2(Cumberiand County) and Kristi K. Clark; MJU # 08120062-2(Cumberland County)
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400 pleadings @udren.com
Deutsche Bank National Trust : COURT OF COMMON PLEAS
Company as Trustee for the : CIVIL DIVISION
Registered Holder of Soundview : Cumberland County
Home Loan Trust 2006-EQ1
Asset-Backed Certificates,
Series 2006-EQ1
Plaintiff
V.
Steve W. Clark
Kristi K. Clark :: NO. 10-3814
Defendant (s)
VERIFICATION OF SERVICE BY CERTIFIED MAIL AND
REGULAR MAIL PURSUANT TO COURT ORDER
The undersigned hereby verifies that he is counsel for Plaintiff in
the above case and that pursuant to the Court order issued in this
matter a true and correct copy of the Notice of Sale was mailed to
Defendant (s) , by certified mail and regular first class mail, to
the last known address of Defendant (s) as follows:
DATE MAILED: April 5, 2013
Steve Willard Clark dba C.W. Clark
Kristi K. Clark
1392 Lowther Road
Camp Hill, PA 17011
I verify that the statements made herein are true and correct and
I understand that false statements made herein are subject to the
penalties of 18 . Pa.C.S. Section 4904 relating to unsworn
falsification to authorities .
Dated: May 2013
UDREN LAW FFICES; P.C.
BY:
ey for Plaintiff
I Eric Kishbaugh, Esquire
PA ID 33078
a�a� no
Apr. 5. 2013 10:57AM Cumberland County Sherrif No. 5541 P. 2
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNT''
CIVIL TRIAL DIVISION
i
Deutsche Bank National Trust Compaluy,
As Trustee for Soundviem,Home Loan r
Trust 2006-EQ1 Asset-Backed Certificates, w =
Series 2006-EQ1,Pooling and Servicing m 'M F
Agreement dated$s of September 1,2006 5E� ��
t
Plaintiff rw L,
V.
Kristi K. Clark; ET AL ! NO. 10-3514 _
5 y
Defendant(s)
ORDER
e
AND NOW, this ) day of ,2013,upon consideration of Plaintiffs Motion and
the Affidavit of Good Faith investigation attached hereto, it is hereby.ORDERED that service of
the Notice of Sale on Defendant(s),Steve Willard Clark dba C.W. C14xk,Kristi K. Clark,
shall be complete when Plaintiff or its counsel or agent has served true and correct copies of the
Notice of Sale by posting the mortgage premises at:
1392 LOWTHER ROAD
CAMP HILT..,PA 17011
And by mailing by certified mail and regular mail to the last known address of Defendant(s) as
follows:
STEVE WILLARD CLARK DBA C.W.CLARK
1392 LOWTHER ROAD
CAMP HILL, PA 17011
IMSTI K.CLARK
1392 LOWTHE R ROAD
CAMP HILL,PA 17011
BY THE COURT:
o
TRUE COPY FROM f-:f„r.ORD
In Testimony Whereof,i here unto set my hared
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NOTICE OF SHERIFF' S SALT OF ,
TO: Kristi K. Clark
1392 Lowther Road
Camp Hill, PA 17011
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of Sender UDREN LAW OFFICES,P.C. ❑Insured Merchandise Registered Mail:
certificate of mailing or for
111 Wooderest Road,Suite 200 1:1 COD Fl Intl Recorded Del. 1:1 With Postal Insurance additional copies of this bill.
Cherry Hill,NJ 08003
Certified Express Mail E]Without postal Insurance Postmark and Date o Receipt
Article Handling Act.Value Insured Due R.R. S.D. S.H. Rst.Del.Fee
Line Number Name of Addressee,Street,and Post Office Address Postage Fee Charge (If Regis.) Value Sender Fee Fee Fee Remarks
1 10-3814 Steve Willard Clark dba C.W.Clark
If
1392 Lowther Road
Camp Hill,PA 17011
2 Kristi K.Clark
1392 Lowther Road
Camp Hill,PA 17011
3 06/05/2013 c� LU
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$500,000 per occurrence.The maximum indemnity payable on Express Mail merchandise is$500.The maximum indemnity payable is
$25,000 for registered mail,sent with optional postal insurance.See Domestic Mail Manual R900,5913,and 5921 for limitations of
2 coverage on insured and COD mail.See International Mail Manual for limitations of coverage on international mail.Special handling
charges apply only to thrd and forth class parcels.
PS Form 3877,February 1994 Form Must be Completed by Typewriter,Ink or Ball Point Pen
Steve W. Clark—MJU#08120062-2 (Cumberland County) and Kristi K. Clark-MJU# 08120062-2 (Cumberland County)
` SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
�$�rit@ of�'.irunbre"-0ry�
Jody S Smith t�.
Chief Deputy ' ,a
Richard W Stewart
Solicitor OFFICE OF THE SHERIFF
Deutsche Bank National Trust Company
Case Number
vs.
Steve W Clark(et al.) 2010-3814
SHERIFF'S RETURN OF SERVICE
01/03/2013 07:35 PM- Deputy William Cline, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the
above titled action, upon the property located at 1392 Lowther Road, Camp Hill, PA 17011, Cumberland
County.
SHERIFF COST: $908.70 SO ANSWERS,
January 22, 2013 RONWY R ANDERSON, SHERIFF
(c)CountySuite Sheriff,Teleosoft,Inc. EM O
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400 pleadings @udren.com
Deutsche Bank National Trust : COURT OF COMMON PLEAS
Company as Trustee for the : CIVIL DIVISION
Registered Holder of Soundview : Cumberland County
Home Loan Trust 2006-EQ1
Asset-Backed Certificates,
Series 2006-EQ1
Plaintiff "
r- CI)t:?
V.
Steve W. Clark
Kristi K. Clark NO. 10-3814 ?_yam C)
Y c o/
Defendant (s)
VERIFICATION OF SERVICE BY CERTIFIED MAIL AND
REGULAR MAIL PURSUANT TO COURT ORDER
The undersigned hereby verifies that he is counsel for Plaintiff in
the above case and that pursuant to the Court order issued in this
matter a true and correct copy of the Notice of Sale was mailed to
Defendant (s) , by certified mail and regular first class mail, to
the last known address of Defendant (s) as follows :
DATE MAILED: April 5, 2013
Steve Willard Clark dba C.W. Clark
Kristi K. Clark .
1392 Lowther Road
Camp Hill, PA 17011
I verify that the statements made herein are true and correct and
I understand that false statements made herein are subject to the
penalties of 18 Pa.C. S . Section 4904 relating to unsworn
falsification to authorities..
Dated: May /7 , 2013
UDREN LAW FFICES; P. C.
BY:
ey for Plaintiff
I Eric Kishbaugh, Esquire
PA ID 33078
, Apr. 5. 2013 10:57AM Cumberland County Sherrif No. 5541 P. 2
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL TRIAL DIVISION
Deutsche Bank National Trust Company,
As Trustee for Soundvievi, Home Loan M 7
Trust 2006-EQ1 Asset-Backed Certificates,
Series 2006-EQ1,Pooling and Servicing
Z�
Mg,reement dated as of September 1,2006 C?
Cn
Plaintiff —40
7:-n.
V.
Kristi K. Clark;ET AL NO. 10-3814 &-C)
C-- --irTi
Defendant(s)
ORDER
AND NOW,this day of a j 2013,upon consideration of Plaintiffs Motion and
the Affidavit of Good Faith investigation attached hereto,it is hereby ORDERED that service of
the Notice of Sale on Defendant(s), Steve Willard Clark dba C.W. Clark,Kristi K. Clark,
shall be complete when Plaintiff or its counsel or agent has served true and correct copies of the
Notice of Sale by posting the mortgage premises at:
1392 LOWTHER ROAD
CAW JIILL,PA 17011
And by mailing by certified mail and regular mail to the last known address of Defendant(s) as
follows:
STENT WILLARD CLARK DBA C.W.CLARK
1392 LOWTHER ROAD
CAMP HILL,PA 17011
KUSTI K.CLARK
1392 LOWTHER.ROAD
CAMP HILL,PA 17011
BY THE COURT:
TRUE COPY Mom rzr,.r,0RD
in Testimony whereof,i nere unto set my hand
and the seal f slid C 0arlislo. pn.
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Camp Hill, PA 17011
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endorsement'Restricted Delivery".
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receipt is not needed,detach and affix label with postage and mail. R '� o
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NOTICE OF SHERIFF' S SALE OF �•
TO: Kristi K. Clark
1392 Lowther Road
Camp Hill, PA 17011
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delivery. o obtain Return Receipt service,please complete and attach a Return
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• If a postmark on the Certified Mail receipt is desired,please present the arti-
cle at the post office for postmarking. If a postmark on the Certified Mail
receipt is not needed,detach and affix label with postage and mail.
IMPORTANT:Save this receipt and present it when making an inquiry. m a o
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Merchandise Registered Mail: certificate of mailing or for
Ill Woodcrest Road,Suite 200 COD Int'l Recorded Del. F]With Postal Insurance additional copies of this bill.
Cherry Hill,NJ 08003 FICertified Express Mail EJ Without postal Insurance Aostrnarkand Date of Receipt
Line Article Name of Addressee Street and Post Office Address Postage Handling Act.Value insured Due Sender R.R. S.D. S.H. Rst.Del.Fee
, ,
Number age Charge (If Regis.) Value If COD Fee Fee Fee Remarks
-T-
0-3814 Steve Willard Clark dba C.W.Clark
1392 Lowther Road
Camp Hill,PA 17011
Kristi K.Clark
1392 Lowther Road
66—iORYI—3 Camp Hill,PA 17011 UJ
0 1
C)
V '14t i C'J
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C14 0
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to 0 0R,
7 401se
8
9
10
12
13
14
15
Total number of Pieces Total Number of Pieces Post] r,Per(Name oJ'Receiving Employee) The full declaration of value is required on all—domestic and international registered mail.The maximum indemnity payable for the
Listed by Sender Received Office reconstruction of nonnegotiable documents under Express Mail document reconstruction insurance is$50,000 per piece subject to a limit of
$500,000 per occurrence.The maximum indemnity payable on Express mail merchandise is$500.The maximum indemnity payable is
$25,000 for registered mail,sent with optional postal insurance.See Domestic Mail Manual R900,5913,and S921 for limitations of
2 coverage on insured and COD mail.See international Mail Manual for limitations ofcoverage on international mail.Special handling
char es a I ord to third and forth class arcels.
Ora
PS Fonn 3877,February 1994 Post]
M Must be Completed by Typewriter,Ink or Bali Point Pen
Steve W. Clark—MJU#08120062-2 (Cumberland County) and Kristi K. Clark-MJU#08120062-2 (Cumberland County)
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S n,
Chef Deprutyh � « L''113 A 23 Of 10
Richard W Stewart � 'r CUMBI RLAN7 Cotjh,vTy
Solicitor orPIcs4rNE SRERIFF PEM4SYL�/AMA
Deutsche Bank National Trust Company Case Number
vs.
Steve W Clark(et al.) 2010-3814
SHERIFF'S RETURN OF SERVICE
01/03/2013 07:35 PM -Deputy William Cline, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the
above titled action, upon the property located at 1392 Lowther Road, Camp Hill, PA 17011, Cumberland
County.
02/06/2013 Ronny R. Anderson, being duly sworn according to law, states he made diligent search and inquiry for the
within named Defendant to wit: Steve W. Clark, but was unable to locate the Defendant in his bailiwick.
The Sheriff therefore returns the within requested Real Estate Writ, Notice of Sale, Legal Description as
"Not Served" at 1392 Lowther Road, Camp Hill, PA 17011, per neighbor the couple is not longer together
and rarely seen at this address, 8 service attempts were made,
but defendant could not be located prior to expiration date.
02/06/2013 Ronny R. Anderson, being duly sworn according to law, states he made diligent search and inquiry for the
within named Defendant to wit: Kristi K. Clark, but was unable to locate the Defendant in his bailiwick.
The Sheriff therefore returns the within requested Real Estate Writ, Notice of Sale, Legal Description as
"Not Served"at 1392 Lowther Road, Camp Hill, PA 17011, per neighbor the couple is not longer together
and rarely seen at this address, 8 service attempts were made,
but defendant could not be located prior to expiration date.
02/27/2013 As directed by Mark Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 5/1/2013
04/05/2013 As directed by Mark Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 6/5/2013
04/08/2013 06:06 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Kristi K.
Clark, pursuant to Order of Court by'Posting"the premises located at 1392 Lowther Road, Lower Allen
Township, Camp Hill, PA 17011, Cumberland County with a true and correct copy according to law.
04/08/2013 06:06 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Steve W
Clark, pursuant to Order of Court by"Posting"the premises located at 1392 Lowther Road, Lower Allen
Township, Camp Hill, PA 17011, Cumberland County with a true and correct copy according to law.
06/05/2013 Ronny R.Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had
been given according to law, he exposed the within described premises at public venue or outcry at the
Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA on June 5, 2013 at 10:00 a.m. He
sold the same for the sum of$1.00 to Attorney Mark Udren, on behalf of Deutsche Bank National Trust
Company, as Trustee for Soundview Home Loan Trust 2006-EQ1 Asset Backed Certificates, Series
2006-EQ1, being the buyer in this execution, paid to the Sheriff the sum of
SHERIFF COST: $1,220.75 SO ANSWERS,
Jul 02 2013 �p(- �/•
July RONIV R ANDERSON, SHERIFF
f ' a�3 �`
(c)CountySuite Sheriff,Telecsoft,Inc.
JF UDREN LAS, OFFICES, P.C. ATTORNEY FOR PLAINTIFF
V OODCRE,ST CQCRPORATE CENTER
111 WOODCREST ROAD., SUITE 200
CHERRY HILL, NJ 08003-3620
856=66.9-5400
pleadings @udren.com
Deutsche Bank National Trust : COURT OF COMMON PLEAS
Company as Trustee for the : CIVIL DIVISION
Registered Holder of Soundview, € Cumberland County
Home Loan Trust 2006-EQ1
Asset-Backed Certificates, ; MORTGAGE FORECLOSURE
Series 2006-EQ1
Plaintiff
V.
Steve W. Clark : NO. 10-3814
Kristi K. Clark
Defendant (s)
AFFIDAVIT PURSUANT TO RULE 3129 . 1
AND RULE 76
Deutsche Bank National Trust Company as Trustee for the
Registered Holder of Soundview Home Loan Trust 2006-EQ1 Asset-
Backed Certificates, Series 2006-EQ1, Plaintiff in the above
action, by its undersigned attorney, upon information and belief,
Udren Law Offices, P. C. , sets forth, as of the date the Praecipe
for the Writ of Execution was filed, the following information
concerning the real property located at : 1392 Lowther Road, Camp
Hill, PA 17011
1 . Name and address of Owner (s) or reputed Owner (s) :
Name Address
Steve W. Clark 1392 Lowther Road
Camp Hill, PA 17011
Kristi K. Clark 1392 Lowther Road
Camp Hill, PA 17011
2 . Name and address of Defendant (s) in the judgment :
Name Address
SAME AS #1 ABOVE
3 . Name and address of every judgment creditor whose judgment is
. a record lien on the real property to be sold:
Name Address
Capital One Bank Address to Follow
4 . Name and address of the last recorded holder of every mortgage
of record: `
_Name Address
Deutsche Bank National Trust 12650 Ingenuity Drive
Company as Trustee for the Orlando,. FL 32826
Registered Holder of
Soundview Home Loan Trust
2006-EQ1 Asset-Backed
Certificates, Series 2006-EQ1
Pennsylvania Housing Finance Address to Follow
Agency
MERS as Nominee for Address to Follow
EquiFirst Corporation
5 . Name and address of every other person who has any record lien
on the property:
Name Address
None
6 . Name and address of every other person who has any record
interest in the property and whose interest may be affected by
the sale:
. Name Address
Real Estate Tax Dept. 1 Courthouse Square
Carlisle, PA- 17013
Domestic Relations Section 13 North Hanover Street
Carlisle, PA 17013
Commonwealth of PA, Bureau of Compliance, PO Box 281230
Department of Revenue Harrisburg, PA 17128-1230
7 . Name and address of every other person of whom the plaintiff
has knowledge who has any interest in the property which may be
affected by -the ,sale:
Name Address
Tenants/Occupants 1392 Lowther Road,
Camp Hill, PA 17011
I verify that the statements made in this affidavit are true and
correct to the best of my information and belief . I understand
that false statements herein are made subject to the penalties of
18 Pa.C. S . sec . 4904 relating to unsworn falsification to
authorities .
DATED: September 28 ,2012
UDREN LAW OFFICES,OFFICES, P. C.
BY:
Attorneys for Plaintiff
Katherine E. Knowlton, Esq
PA ID 311713
UDREN LAVA OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings @udren.com
Deutsche Bank National Trust : COURT OF COMMON PLEAS
Company as Trustee for the ' CIVIL DIVISION
Registered Holder of Soundview : Cumberland, County
Home Loan Trust 2006-EQ1
Asset-Backed Certificates, : MORTGAGE FORECLOSURE
Series 2006-EQ1
Plaintiff
V.
Steve W. Clark : NO. 10-3814
Kristi K. Clark
Defendant (s)
NOTICE OF SHERIFF' S SALE OF REAL PROPERTY
TO: Steve W. Clark
1392 Lowther Road
Camp Hill, PA 17011
Your house (real estate) at 1392 Lowther Road, Camp Hill, PA
17011 is scheduled to be sold at the Sheriff ' s Sale on March 6,
2013, at 10 : 00am in the Commissioners Hearing Room, 2nd Floor,
Courthouse, Carlisle, PA , to enforce the court judgment of
$129, 547 . 58, obtained by Plaintiff above (the mortgagee) against
you. If the sale is postponed, the property will be relisted for
the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF' S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment,
late charges, costs and reasonable attorney's fees. To find out how
much you must pay, you may call: (856) 669-5400.
2. You may be able to stop the sale by filing a petition asking the Court
to strike or open the judgment, if the judgment was improperly entered.
You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact
one, the more chance you will have of stopping the sale. (See notice on
page two on how to obtain an attorney. )
YOU MAY STILL BE' ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF' S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold
to the highest bidder. You may find out the price bid by calling 856-669-
5400.
2. You may be able to petition the Court to set aside the sale if the
bid price was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the
full amount due in the sale. To find out if this has happened, you may call
856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff, you
will remain the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount
due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that
time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for
your house. A schedule of distribution of the money bid for your house will
be filed by the Sheriff within 30 days after the sale. This schedule will
state who will be receiving that money. The money will be paid out in
accordance with this schedule unless exceptions (reasons why the proposed
distribution is wrong) are filed with the Sheriff within ten (10) days after
Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting
your home back, if you act immediately after the sale.
YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17031
717-249-3166
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17031
717-249-3166
Y'M
M� UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOOD.CREST CORPORATE CENTER
212 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings @udren.com
Deutsche Bank National Trust :: COURT OF COMMON PLEAS
Company as Trustee for the : CIVIL DIVISION
Registered Holder of Soundview =. Cumberland County
Home Loan Trust 2006-EQ1
Asset-Backed Certificates, : MORTGAGE FORECLOSURE
Series 2006-EQ1
Plaintiff
V.
Steve W. Clark : NO. 10-3814
Kristi K. Clark
Defendant (s)
NOTICE OF SHERIFF' S SALE OF REAL PROPERTY
TO: Kristi K. Clark
1392 Lowther Road
Camp Hill, PA 17011
Your house (real estate) at 1392 Lowther Road, Camp Hill, PA
17011 is scheduled to be sold at the Sheriff ' s Sale on March 6,
2013, at 10 : 00am in the Commissioners Hearing Room, ' 2nd Floor,
Courthouse, Carlisle, PA , to enforce the court judgment of
$129, 547 . 58, obtained by Plaintiff above (the mortgagee) against
you. If the sale is postp=ed, the property will be relisted for
the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF' S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be canceled if you pay to the mortgagee the back payment,
late charges, costs and reasonable attorney's fees. To find out how
much you must pay, you may call: (856) -669-5400.
2 . You may be able to stop the sale by filing a petition asking the Court
to strike or open the judgment, if the judgment was improperly entered.
! You may also ask the Court to postpone the sale for good cause.
3. You may also be able to. stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact
one, the more chance you will have of stopping the sale. (See notice on
page two on how to obtain an attorney. )
YOU MAY STILL BE'-ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold
to the highest bidder. You may find out the price bid by calling 856-669-
5400.
2,. You may be able to petition the Court to set aside the sale if the
bid price was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the
full amount due in the sale. To find out if this has happened, you may call
856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff, you
will remain the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount
due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that
time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid-for
your house. A schedule of distribution of the money bid for your house. will
be filed by the Sheriff within 30 days after the sale. This schedule will
state who will be receiving that money. The money will be paid out in
accordance with this schedule unless exceptions (reasons why the proposed
distribution is wrong) are filed with the Sheriff within ten (10) days after
Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting
your home back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17031
717-249-3166
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle—PA 17031
717-249-3166
ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES, SITUATE,
LYING AND BEING IN THE TOWNSHIP OF LOWER ALLEN IN THE COUNTY OF
CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY
DESCRIBED AS FOLLOWS :
BEGINNING AT A POINT ON THE NORTHERN LINE OF LOWTHER ROAD, ON
THE DIVIDING LINE BETWEEN LOT NOS . 24 AND 35, BLOCK "L", ON THE
HEREINAFTER MENTIONED PLAN OF LOTS; THENCE IN A NORTHERLY
DIRECTION ALONG SAID DIVIDING LINE ONE HUNDRED TWENTY (120) FEET
TO LOT NO. 9, BLOCK "L", ON SAID PLAN; THENCE IN AN EASTERLY
DIRECTION ALONG THE SOUTHERLY LINE OF SAID LOT NO. 9, FIFTY-FIVE
(55) FEET TO LOT. NO. 36, BLOCK L, ON SAID PLAN; THENCE IN A
SOUTHERLY DIRECTION ALONG THE WESTERN LINE OF SAID LOT NO . 36,
ONE HUNDRED TWENTY (120) FET TO LOWTHER ROAD FIFTY-FIVE TO THE
POINT OR PLACE OF BEGINNING.
BEING LOT NO. 35, BLOCK "L" ON THE PLAN OF GREATER HIGHLAND PARK,
LOWER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA,
RECORDED IN THE CUMBERLAND COUNTY RECORDER OF DEEDS OFFICE, IN
PLAN BOOK 4 , PAGE 89 .
HAVING THEREON ERECTED A ONE STORY FRAME DWELLING HOUSE
BEING KNOWN AS : 1392 Lowther Road, Camp Hill, PA 17011
PROPERTY ID NO. : 13-23-0545-231
TITLE TO SAID PREMISES IS VESTED IN STEVE W. CLARK AND KRISTI K.
CLARK; AS TENANTS BY THE ENTIRETY BY DEED. FROM JOHN D.
BRAKEFIELD, JR.-AND NICOLE L. BRAKEFIELD DATED 6/30/2006 RECORDED
7/10/2006 IN DEED BOOK 275 PAGE 2759 .
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 10-3814 Civil
COUNTY OF*CUMBERLAND) CIVIL ACTION—LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY,
as Trustee for the Registered Holder of SOUNDVIEW HOME LOAN TRUST 2006-EQ1 ASSET-
BACKED CERTIFICATES,SERIES 2006-EQ1, Plaintiff(s)
From STEVE W. CLARK and KRISTI K. CLARK
(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
GARNISHEES)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: $129,547.58 L.L.:
Interest from 7/25/10 to 3/6/13 Ongoing per diem of$21.69 to actual date of sale including if sale is
held at a later date -- $20,735.64
Atty's Comm: % Due Prothy: $2.25
Atty Paid: $290.38 Other Costs:
Plaintiff Paid:
Date: 10/2/12
David D. Buell,Prothonotary
(Seal). W"o,"r,
Deputy
REQUESTING PARTY:
Name: KATHERINE E.KNOWLTON,ESQUIRE TRUE COPY FRC3J�ii.RECORD
Address: UDREN LAW OFFICES PC in TesiimonyIwliere_+f,.1 Pieta unto set my hand
' and the sea eaf sa15 C.otiri.at,C Misle,Pa.
WOODCREST CORPORATE CENTER This ,?0
Prothonotary
111 WOODCREST ROAD,SUITE 2002
CHERRY HILL,NJ 08003-3620
Attorney for: PLAINTIFF
Telephone: 856-669-5400
Supreme Court ID No. 311713
On October 19, 2012 the Sheriff levied upon the
defendant's interest in the real property situated in
Lower Allen Township, Cumberland County, PA,
Known and numbered as, 1392 Lowther Road,
Camp Hill, more fully described on Exhibit
"A" filed with this writ and by this reference incorporated
herein.
Date: October 19, 2012
By:
ClItc
Real Estate Coordinator
pfd
i.
CUMBERLAND LAW JOURNAL
Writ No. 2010-3814 Civil
Deutsche Bank National
Trust Company
vs.
Steve W. Clark,
Kristi K. Clark
Atty.: Mark J.Udren
ALL THAT CERTAIN tract or par-
cel of land and premises, situate,
lying and being in the Township of
Lower Allen in the County of Cum-
berland and Commonwealth of Penn-
sylvania,more particularly described
as follows:
BEGINNING at a point on the
northern line of Lowther Road, on
the dividing line between Lot Nos.24
and 35,Block"L",on the hereinafter
mentioned Plan of Lots; thence in a
northerly direction along said divid-
ing line one hundred twenty(120)feet
to Lot No.9, Block"L", on said plan;
thence in an easterly direction along
the southerly line of said Lot No.9,
fifty-five(55)feet to Lot No.36,Block
L,on said plan;thence in a southerly
direction along the western line of
said Lot No.36,one hundred twenty
(120) fet to Lowther Road fifty-five
to the point or place of BEGINNING.
BEING Lot No. 35, Block "L" on
the plan of Greater Highland Park,
Lower Allen Township, Cumberland
County, Pennsylvania, recorded in
the Cumberland County Recorder of
Deeds Office,in Plan Book 4,Page 89.
HAVING THEREON ERECTED a
one story frame dwelling house being
known as: 1392 Lowther Road,Camp
Hill,PA 17011.
PROPERTY ID NO.: 13-23-0545-
231.
TITLE TO SAID PREMISES is
vested in Steve W. Clark and Kristi
K. Clark, as tenants by the entirety
by Deed from John D. Brakefield,
Jr. and Nicole L. Brakefield dated
6/30/2006 recorded 7/10/2006 in
Deed Book 275 Page 2759.
33
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 25, February 1, and February 8, 2013
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.
�isa Marie Coy�e, Editor
SWORN TO AND SUBSCRIBED before me this
da of Februar 2013
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH,CUMBERLAND COUNTY
My Commission Expires Apr 28,2014
The Patriot-News,Co.
2020 Technology Pkwy the atr10tWXfW5
Suite 300`
Mechanicsburg, PA 17050 Now you know
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE PA 17013
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin) ss
Marianne Miller, being duly sworn according to law, deposes and says:
That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 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.
2010.3814 Civil p
De sche Bank National rust r This ad ran on the date(s)shown below:
Company 4•'
VS 01/22/13
Steve W Clark
Krlstl K.Clark 01/29/13
Atty: Mark J Udren C 02/05/13
ALL THAT CERTAIN TRACT OR
PARCEL OF LAND AND PREMISES,
SITUATE,LYING AND BEING IN THE . . . . . . . . . �. . . .
TOWNSHIP OF LOWER ALLEN IN
THE COUNTY OF CUMBERLAND
AND COMMONWEALTH
OF PENNSYLVANIA, MORE RE Sworn to and sub cribed before me this day February, 2013 A.D.
PARTICULARLY DESCRIBED AS
FOLLOWS:
BEGINNING AT A POINT ON THE
NORTHERN LINE OF LOWTHER Notary P li
ROAD, ON THE DIVIDING
LINE BETWEEN LOT NOS. 24
AND 35, BLOCK "C', ON THE
HEREINAFTER MENTIONED PLAN : COMMONWEAL NNSYLVANIA
OF LOTS;THENCE IN A NORTHERLY Notarla15ea1
DIRECT ID ION ALONG SA DIVIDING
LINE ONE HUNDR99—CITY Holly Lynn Warfel,Notary Public
(170) FEET TO LOT NO.9, BLOCK Washington TWp.,Dauphin County
"U',-ON SAIII,PLAN;THENCE IN AN i' Commission Expires Dec.12,2016
EASTERLY DIRECTION ALONG THE ( MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES
SOUTHERLY LINE OF SAID LOT NO.9,
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
1, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff s Deed in which Soundview Home Loan Trust 2006-EQ I is the grantee the same having
been sold to said grantee on the 5th day of June A.D.,2013,under and by virtue of a writ Execution
issued on the 2nd day of October, A.D.,2012, out of the Court of Common Pleas of said County as of
Civil Term, 2010 Number 3814, at the suit of Soundview Home Loan Trust 2006-EQl T against Steve
W&Kristi K Clark is duly recorded as Instrument Number 201324172.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this d3—d day of
& A.D.
/V ecorder of Deeds
' —