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Home My WebLink About10-4185GOLD13ECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 WWW.GOLDBECKLAW.COM IN THE COURT WELLS FARGO BANK MINNESOTA, N.A., AS INDENTURE TRUSTEE FOR MSCC HELOC TRUST 2007-1 SB/M NORWEST BANK MINNESOTA, NA, AS INDENTURE TRUSTEE FOR NOVUS HOME EQUITY LOAN TRUST 1999-MS I 4708 Mercantile Drive North Fort Worth, TX 76137 Plaintiff VS. The Unknown Heirs of Paulette D. Beck, Deceased GARY D. NULL DENISE M. NULL Mortgagors and Record Owners JENNIFER NELSON, Solely in Her Capacity as Heir of Paulette D. Beck, Deceased RICHARD BECK, Solely in His Capacity as Heir of Paulette D. Beck, Deceased ROY SEIXAS, Solely in His Capacity as Heir of Paulette D. Beck, Deceased 420 Bosler Avenue Lemoyne, PA 17043 Defendants OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE RLED-0f FE OF THE P 0THC NOTAAY 2010 JUN 23 PM 1:23 0JM8-[:FtA",JJ C0?JJJl, Term _ No. 10 - 4185 (2i tVt 1 Term CIVIL ACTION: MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 S LEGAL SERVICES INC 4Qa DO PQ K"I 8 Irvine Row C It 534q 7(0 Carlisle, PA 17013 & ayy )( 4 717-243-9400 0 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisions de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://WWW.Dhfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://www.philadelDhiafed.org/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention&goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 93329FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is WELLS FARGO BANK MINNESOTA, N.A., AS INDENTURE TRUSTEE FOR MSCC HELOC TRUST 2007-1 SB/M NORWEST BANK MINNESOTA, NA, AS INDENTURE TRUSTEE FOR NOVUS HOME EQUITY LOAN TRUST 1999-MS 1, 4708 Mercantile Drive North, Fort Worth, TX 76137. 2. The names and addresses of the Defendants are The Unknown Heirs of Paulette D. Beck, Deceased, 420 Bolser Avenue, Lemoyne, PA 17043, GARY D. NULL, 420 Bosler Avenue, Lemoyne, PA 17043, DENISE M. NULL, 420 Bosler Avenue, Lemoyne, PA 17043, who are the mortgagors and record owners of the mortgaged premises hereinafter described. JENNIFER NELSON, Solely in Her Capacity as Heir of Paulette D. Beck, Deceased, 1917 Kent Drive, Camp Hill, PA 17011, RICHARD BECK, Solely in His Capacity as Heir of Paulette D. Beck, Deceased, 420 Bosler Ave, Lemoyne, PA 17043 and ROY SEIXAS, Solely in His Capacity as Heir of Paulette D. Beck, Deceased, 507 16th Ave, New Cumberland, PA 17070. PUALETTE D. BECK died on October 22, 2008 Intestate and is survived' by her heirs-at-laws ROY SEIXAS, JENNIFER NELSON and RICHARD BECK. 3. On November 20, 1998 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to NOVUS FINANCIAL CORPORATION, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1502, Page 829. The mortgage has been assigned to: WELLS FARGO BANK MINNESOTA, N.A., AS INDENTURE TRUSTEE FOR MSCC HELOC TRUST 2007-1 SB/M NORWEST BANK MINNESOTA, NA, AS INDENTURE TRUSTEE FOR NOVUS HOME EQUITY LOAN TRUST 1999-MS 1 by assignment of Mortgage April 21, 1999 and recorded on September 27, 1999 as Book 625, Page 1001. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for June 28, 2009 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ....................................................................................$22,573.14 Interest from 05/28/2009 through 06/04/2010 at 6.2400% ..........................$586.57 Per Diem interest rate at $3.86 Reasonable Attorney's Fee .................................................................$2,000.00 Costs of suit and Title Search (Estimated) ...................................................$900.00 Fees ..............................................................................................................$682.00 $26,741.71 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendants have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terns judgment in mortgage foreclosure in the sum of $26,741.71, together with interest at the rate of $3.86, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. By: GOLDBECK MCCAFFERTY & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 ATTORNEYS FOR PLAINTIFF VERIFICATION John Cottrell as the representative of the servicing agent for the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: lQ WELLS ARGO BANK MINNESOTA, SUCCESSOR BY MERGER TO WELLS FARGO BANK MINNESOTA N.A., AS INDENTURE TRUSTEE FOR MSCC HELOC TRUST 2007-1, BY MORGAN STANLEY CREDIT CORPORATION, AS ITS ATTORNEY IN FACT John Cottrell Assistant Vice President #93329FC - The Unknown Heirs of Paulette D. Beck, Deceased, GARY D. NULL, DENISE M. NULL, JENNIFER NELSON, Solely in Her Capacity as Heir of Paulette D. Beck, Deceased, RICHARD BECK, Solely in His Capacity as Heir of Paulette D. Beck, Deceased and ROY SEIXAS, Solely in His Capacity as Heir of Paulette D. Beck, Deceased 420 Bosler Avenue Lemoyne, PA 17043 r,.,h i 6 i t A All W%at certain lot or piece of ground situated in Mortgage Premise. 420 HOSLBR AV LBMOYIU,PA 17043. CUMBERLAND (Borough or Township, if stated), Commonwealth of Pennsylvania. Being more particularly described in said mortgage. NOVAS OI[' I??' E.)chibit (B ACT 91 NOTICE DATE OF NOTICE: 05/14/2010 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. This is an official notice that the mortgage on your home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home This Notice explains how the program works To see if HEMAP can help you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name address and phone number of Consumer Credit Counseling A.Rencies serving your _County are listed at the end of this Notice If you have any questions you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired heann can call 717 780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado Homeowners Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. Prepared by: GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 Fax (215) 627-7734 Date: 05/14/2010 Homeowners Name: The Unknown Heirs of Paulette D. Beck, Deceased, GARY D. NULL, DENISE M. NULL, JENNIFER NELSON, Solely in Her Capacity as Heir of Paulette D. Beck, Deceased, RICHARD BECK, Solely in His Capacity as Heir of Paulette D. Beck, Deceased and ROY SEIXAS, Solely in His Capacity as Heir of Paulette D. Beck, Deceased Property Address: 420 Bosler Avenue, Lemoyne, PA 17043 Loan Account No.: 6000003235 Original Lender: SAXON MORTGAGE SERVICES INC. Current Lender/Servicer: SAXON MORTGAGE SERVICES INC. HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (33) DAYS IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be filed or postmarked within thirty (30) days of your fact-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTRCTEU`BY THE FILING OF A,PETITION INBANKRUPTCY, 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 Egji r? Mo W Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 420 Bosler Avenue, Lemoyne, PA 17043 IS SERIOUSLY IN DEFAULT because: A. THE MORTGAGE HAS MATURED, BUT HAS NOT BEEN PAID IN FULL. The following amounts are now past due: (a) Principal Balance $22,573.14 (b) Interest $104.20 (c) Corporate Advance $127.44 (d) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $22,804.78 HOW TO.CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $22,804.78, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check certified check or money order made payable and sent to: SAXON MORTGAGE SERVICES INC. 4708 Mercantile Drive North Fort Worth, TX 76137 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon -your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender brings legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have 4 the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale You may do so by paying the total amount then past due plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing b the lender and b performing any re uirements under the mortgage Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately four (4) to six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: SAXON MORTGAGE SERVICES INC. Address: 4708 Mercantile Drive North Fort Worth, TX 76137 Phone Number: 888-325-3502 Contact Person: Loss Mitigation Department EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Contact: Loss Mitigation Department Phone Number: 888-325-3502 HEMAP Consumer Credit Counseling Agencies Report last updated: 4/30/2010 3:43:52 PM Greater Erie Community Action Committee 18 West 9TH Street Erie, PA 16501 814.459.4581 Shenango Valley Urban League, Inc. 601 Indiana Avenue Farrell, PA 16121 724.981.5310 St. Martin Center 1701 Parade Street Erie, PA 16503 814.452.6113 CUMBERLAND County CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 888.511.2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 DELAWARE County Advocates for Financial Independence 1503 Wadsworth Ave Philadelphia, PA 19150 267-323-2696 American Credit Counseling Institute 526-528 Dekalb Street Norristown, PA 19401 610.971.2210 888.212.6741 American Credit Counseling Institute 175 Strafford Avenue Suite 1 Wayne, PA 19087 610.971.2210 888.212.6741 American Financial Counseling Services Inc. 1080 N. Delaware Avenue Suite 200 Philadelphia, PA 19125 267.228.7903 800.490.3039 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PA Interfaith Community Programs Inc 40 E High Street Gettysburg, PA 17325 717.334.1518 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 DAUPHIN County CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 888.511.2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 American Financial Counseling Services Inc. 405 West Germantown Pike Norristown, PA 19403 267.228.7903 800.490.3039 American Financial Counseling Services Inc. 175 Strafford Avenue Suite One Wayne, PA 19087 267.228.7903 800.490.3039 American Red Cross of Chester 1729 Edgemont Avenue Chester, PA 19013 610.874.1484 APM 600 W Diamond Street Philadelphia, PA 19122 215.235.6070 (267) 953-4615 Carroll Park Community Council, Inc. 5218 Master Street Philadelphia, PA 19131 215.877.1157 CCCS of Delaware Valley 4400 North Reese Street Philadelphia, PA 19140 215.563.5665 Page 8 of 21 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart $Oi1CltOr Wells Fargo Bank vs. Richard Beck (et al.) ~~~wttit~ ~t lrirartGrr/r~~G ~: ~~~__, , T Fri ~ ~ GF.t~~ r= ~ .-r. ~~~ r~ r ~t ' ~' ~ J(1L -7 AID 8= ~+~ C ~ r. ".Y Case Number 2010-4185 SHERIFF'S RETURN OF SERVICE 06/29/2010 08:37 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to la tates that on June 29, 2010 at 2030 hours, he served a true copy of the within Complaint in Mortgag F ' eclosure, upon the within named defendant, to wit: Jennifer Nelson, by making known unto h rself rso ally, at 1713 Cedar Cliff Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its cont s n at th same time handinc to her personally the said true and correct copy of the same. S WN HARRISON, DEPUTY 06/29/2010 07:38 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on June 29, 2010 at 1920 hours, he served a true copy of the within Complaint in Mortga oreclosure, upon the within named defendant, to wit: Gary Null, by making known unto himself perso ally, at 420 Bosler Avenue, Lemoyne, Cumberland County, Pennsylvania 17043 its content and t the same time handing tc him personally the said true and correct copy of the same. ~ ~ i SHgp'aN HARRISON, DEPUTY 06/29/2010 07:38 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, tes that on June 29, 2010 at 1920 hours, he served a true copy of the within Complaint in Mortgage or closure, upon the within named defendant, to wit: Denise M. Null, by making known unto herself per ona y, at 420 Bosler Avenue, Lemoyne, Cumberland County, Pennsylvania 17043 its conterind at he s e time handing tc her personally the said true and correct copy of the same. ~ ~'"~ DEPUTY 06/29/2010 08:10 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on June 29, 2010 at 2000 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Roy Seixas, by making known unto Enid Torres, ad charge at 507 16th Street, New Cumberland, Cumberland County, Pennsylvania 170rnonte is d at the same time handing to her personally the said true and correct copy of the sa e. ~ SHp(iNN HARRISON, DEPUTY 06/30/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Richard Beck, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Richard Beck. Gary Null, defendants uncle advised Deputies Richard Beck is currently residing in Juneau, Alaska. ;ci Ceun?,Suite J'henff. Tei,~o=_off. Ir;. 07/01/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: The Unknown Heirs of Paulette D. Beck, Deceased, bui was unable to locate them in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant The Unknown Heirs of Paulette D. Beck. Gary Null advised Deputies there are no additonal heirs. SHERIFF COST: $161.20 July 06, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF {cj Coun?ySuitP Shenff. Telc~osoft. Inr. -' ,~", , .. WELLS FARGO BANK INDENTURE TRUSTEE TRUST 2007-1 S/B/M N( MINNESOTA, NA, AS D FOR NOVi1S HOME EQ 1999-MS 1 The Unknown Heirs of Pai GARY D. NULL DENISE M. NULL JENNIFER NELSON, Sol of Paulette D. Beck, Dece~ RICHARD BECK, Solely Paulette D. Beck, Decease ROY SEIXAS, Solely in I Paulette D. Beck, Decease Motion for Substituted faith efforts to ascertain Deceased and RICHARD unsuccessful, it is hereby ORDERED and directed to Serve the Paulette D. Beck, Unknown Heirs of Paulette D. Beck, 420 Boller Avenue, and regular mail to the ORDERED and Defendants, The Capacity as Heir of JUL 1 6 2010 NNESOTA, N.A., AS )R MSCC HELOC .WEST BANK -ENTURE TRUSTEE TY LOAN TRUST D. Beck, Deceased in Her Capacity as Heir His Capacity as Heir of Capacity as Heir of C? o ' ~ c ._ ~, y ~, -~- -~~ -ry _Tl _ ;.~ _ ~, ~ :r-, c: c~ ^_ } ~;. ~ tea. ORDER this l ~ day o 010, upon consideration of the Plaintiffs ice under Pa.R.C.P. 43 (a) and it appearing to the Court that Plaintiffs good present whereabouts of Defendants, The Unknown Heirs of Paulette D. Beck, Solely in His Capacity as Heir of Paulette D. Beck, Deceased have been that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is in Mortgage Foreclosure upon Defendant, The Unknown Heirs of by (i) publication as provided in Pa.R.C.P. 430(bx2), and upon Defendants, The D. Beck, Deceased and RICHARD BECK, Solely in His Capacity as Heir of by (ii) posting a copy of the Complaint upon the subject property, located at ne, PA, 17043 (the "Property"), and (iii) sending a copy of same by certified and, it is further that Plaintiff shall serve the Notice of Sheriff's sale upon Heirs of Paulette D. Beck, Deceased and RICHARD BECK, Solely in His D. Beck, Deceased by (i) posting a copy of the Complaint upon the Property, 3 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY Term No. 10-4185- CIVIL TERM and (ii) sending a copy oi# same by certified and regular mail to the Property; and, it is further ~ _ - ` ORDERED and Unknown Heirs of Paulette D. Beck, that all other legal papers shall be served upon Defendants, The D. Beck, Deceased and RICHARD BECK, Solely in His Capacity as Heir of by sending a copy of same by rg~mail to~he Property J. y/-~~~d ~~ GOLDBECK McCAFFERTY & McKEEVER ~IL~r, _ ~,.~ ,_~ ,~. ~'~~~ T~ tr L --A ~~J e:_ , ~.,. BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 20 C 0 J~.~L 23 F~~1 2> 34 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET C~.'h~;~4.~ ~~ ,,. ,.,`~,~ ~ ~, PHILADELPHIA, PA 19106-1532 F-'~;, '~;`;'~'~,,'-~.~~.;1 (215)627-1322 ATTORNEY FOR PLAIIVTIFF WELLS FARGO BANK MINNESOTA, N.A., AS INDENTURE TRUSTEE FOR MSCC HELOC TRUST 2007-1 S/B/M NORWEST BANK MINNESOTA, NA, AS INDENTURE TRUSTEE FOR NOVUS HOME EQUITY LOAN TRUST 1999-MS 1 4708 Mercantile Drive North Fort Worth, TX 76137 Plaintiff IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term. No. 10-4185- CIVII. TERM vs. The Unknown Heirs of Paulette D. Beck, Deceased GARY D. NULL DENISE M. NULL JENNIFER NELSON, Solely in Her Capacity as Heir of Paulette D. Beck, Deceased RICHARD BECK, Solely in His Capacity as Heir of Paulette D. Beck, Deceased ROY SEIXAS, Solely in His Capacity as Heir of Paulette D. Beck, Deceased 420 Bosler Avenue Lemoyne, PA 17043 Defendant(s) PRAECIPE TO REINSTATE COMPLA~IT Kindly reinstate the Complaint in the above captioned matter. GOLDBECK, McCAFFERTY & McKEEVER ~/N2bu. ~/~~w"` By Michael T. McKeever, Esq. Attorney for Plaintiff alp. oo Pu ~Tt`I ~~ ~1(~0 ~,# a4s~3) ~ . ...,~ a GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215)627-1322 ATTORNEY FOR PLAINTIFF WELLS FARGO BANK MINNESOTA, N.A., AS INDENTURE TRUSTEE FOR MSCC HELOC TRUST IN THE COURT OF COMMON 2007-1 SB/M NORWEST BANK MINNESOTA, NA, PLEAS AS INDENTURE TRUSTEE FOR NOVUS HOME OF Cumberland COUNTY EQUITY LOAN TRUST 1999-MS 1 4708 Mercantile Drive North CIVIL ACTION -LAW Fort Worth, TX 76137 ACTION OF MORTGAGE vs. FORECLOSURE The Unknown Heirs of Paulette D. Beck, Deceased, Term GARY D. NULL, DENISE M. NULL, JENNIFER No. 10-4185- CIVII. TERM NELSON, Solely in Her Capacity as Heir of Paulette D. Beck, Deceased, RICHARD BECK, Solely in His Capacity as Heir of Paulette D. Beck, Deceased and ~ Q ~ ROY SEIXAS, Solely in His Capacity as Heir of ~=~ ~ ~'' Paulette D. Beck, Deceased ~ "~' ' ~'°' -~~ c_.: 7 Mortgagor(s) _ ",' a- 420 Bosler Avenue -Z-~=~ Lemoyne, PA 17043 -~ ~ ~ ~ r,,., Defendant(s) -_ ~ ~ '~ - -. C.' ~. a ~.~ CERTIFICATE OF SERVICE MICHAEL T. MCKEEVER ESQUIRE hereby certifies that on ~ ~ 3 0 % D he did serve upon Defendant(s) The Unknown Heirs of Paulette D. Beck, Deceased, RICHARD BECK, Solely in His Capacity as Heir of Paulette D. Beck, Deceased a true and correct copy of the above- captioned Complaint by certified and regular mail in accordance with the Court Order dated July 19, 2010. The undersigned understands that the statements herein and subject to the penalties provided by 18 P.S. Section 4904 Respectfully submitted, GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ESQUIRE SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson "~" ~~ .W Sheriff r ~~~~ . ~ , ~0~~ttr oC L ttl~brr~#~ ' Jody S Smith _~ x .,n,,~ , y -+ ( ~ Chief Deputy ~ ~ y{Y [ ~ ; - ~. . ~ .. r` ,~ t ~o~o A~ub y ~rn ~ ~• a ~ Richard W Stewart "~ '° t ;~ SOilC/t0( pFFiCE ~T'~+E S`•.'-:RIFF G:.:;~. , i ~ - .. , Wells Fargo Bank Case Number vs. 2010-4185 Richard Beck (et al.) SHERIFF'S RETURN OF SERVICE 07/29/2010 06:23 PM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on July 29, 2010 at 1823 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Richard Beck, pursuant to order of court by posting the premises located at 420 Bosler Avenue, Lemoyne, Cumberland County, Pennsylvania 17043 with a true and correct copy according to law. AMANDA COBAUGH, DEPUTY 07/29/2010 06:23 PM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on July 29, 2010 at 1823 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Unknown Heirs of Paulette D. Beck, deceased, pursuant to order of court by posting the premises located at 420 Bosler Avenue, Lemoyne, Cumberland County, Pennsylvania 17043 with a true and correct copy according to law. MANDA COBAUG ,DEPUTY SHERIFF COST: $70.40 August 03, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF {c) CountySuite Sheriff. Teleosoft, Inc. O 10 AUG 24 RM 2= 45 ..o a ?' 3 J4 O ? 0 u v a '13 ? 0 (t cd u GJ U 41 U C cn U x ;. r. ?,?u 3 ?a .? O z f bb T? w O O00 3 a 0 0 3 Qj r_4 oa m a a Q) Z, .fl v o v ?y v?-i "? W r + ?Ul) GJ 4J 4J U W a V) 0 v O a? 0 a? ra, U ? v m cu) c D O ? -cd oa?v? v ?i. e ii 'd fCS a+ w ? iw M M 0 v v V CA 0 NY dW TJ TN ?-? mI- Cmo LQ:, a: IOZO ZO 3w0} U O0x o2-c a>>'? ZW Q m 0 , 3 a d o 'N d O y y Q4 ¢ (nog WLL.Oy?U JnTCN U? F- U) -woo° E ¢ =Q pZ? ZaW ww 02 2 JUC_a OO -(n NQWY. Q LL ?F-O Tt0 ?.N 00 Qa Z Oo 3:0 O W Q O W O Z W¢ --'9'E M E m C.t m.i U 7 W ¢=O¢2 pJIQ- xw-25> mam ° m ? JW Wa 0S ?¢ a5,J .... me y o `o U W 052_ I m m WOO w~ocT CAw wm > 0.9 W m 20p?? 3m0 Z?maa1 om9E9 2WO QJ ., ICU U >,yR 0oQ tnZA«T?a> a smoL O~3OW L _ 0 z fn J O C _ F z (`9 JL O?JUUm Wtn? 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F m¢Z of y o 0 3_oO0 cUw c? ai OmFZx? o?OZ TO2'> J ccw__•Q roa C OF-? mW0?U m cnwy,oc3LL LL 3:2 V N 7C?O?LU? papa (nQOzcaw?Yw-2 mom J0"LU 6 0(nn0ooo wZ_-,U00d.5 3. z2z r m F- } 01= ?N? O(rJ =-U TN:-, O N TwW F-2Z ??OCQF-? (wW ?o3o?wLL¢01¢LL Jvc- E 0,,: ,0 O I< oa ??adoNOQQO?Z O F ¢ cvc Jr NF- ZO •O C? Ty Tw O?LL Q O ooc'-JalY (7QQ Jm3 tlmoE?ui2 -Zw c c y«.L, J Z9O?LLa>'- ca 3 o?00ZF-p °E?}Z) OZZQ?W o n: m o?0¢-UECU moT3Uc0?=Z) Op L'.-2 N'tE LLF-OLL W }mom«ap¢3}?¢ LL ad c_ U Rf mN LLy'c ?Yc U O ¢ ? al -rD `m C 0 Y ro 0 oU o, F-YO? m W Lnn : tam. V O .? e 20ri) PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. 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 August 13, 2010 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Lisa Marie Clyne, Editor SWORN TO AND SUBSCRIBED before me this 13 day of August, 2010 Notary NOTMW BEAT 0E80RAH A COttMli *"PAC E 80ROU6N, CUMBERLW COWN Mf? CoMMWM EWWS Apr 28.2811 CUMBERLAND LAW JOURNAL NOTICE OF ACTION IN MORTGAGE FORECLOSURE In the Court of Common Pleas, Cumberland County Civil Action-Law No. 10-4185-CIVIL TERM WELLS FARGO BANK MINNESOTA, N.A., AS INDENTURE TRUSTEE FOR MSCC HELOC TRUST 2007-1 s/b/m NORWEST BANK MINNESOTA, NA, AS INDENTURE TRUSTEE FOR NOVUS HOME EQUITY LOAN TRUST 1999-MS1, Plaintiff vs. The Unknown Heirs of Paulette D. Beck, Deceased, GARY D. NULL, DENISE M. NULL, JENNIFER NELSON, Solely in Her Capacity as Heir of Paulette D. Beck, Deceased, RICHARD BECK, Solely in His Capacity as Heir of Paulette D. Beck, Deceased & ROY SEIXAS, Solely in His Capacity as Heir of Paulette D. Beck, Deceased, Mortgagors and Real Owners, Defendants TO: The Unknown Heirs of Pau- lette D. Beck, Deceased, MORT- GAGOR AND REAL OWNER, DEFENDANT(S), whose last known address is 420 Bolser Av- enue, Lemoyne, PA 17043. THIS FIRM IS A DEBT COLLEC- TOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OB- TAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECT- ING THE DEBT. You are hereby notified that Plain- tiff, WELLS FARGO BANK MINNESO- TA, N.A., AS INDENTURE TRUSTEE FOR MSCC HELOC TRUST 2007-1 s/b/m NORWEST BANK MINNE- SOTA, NA, AS INDENTURE TRUSTEE FOR NOVUS HOME EQUITY LOAN TRUST 1999-MS1, has filed a Mort- gage Foreclosure Complaint endorsed with a notice to defend against you in the Court of Common Pleas of Cum- berland County, Pennsylvania, dock- eted to No. 10-4185-CIVIL TERM, wherein Plaintiff seeks to foreclose on the mortgage secured on your property located, 420 Bosler Avenue, Lemoyne, PA 17043, whereupon your property will be sold by the Sheriff of Cumberland County. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written ap- pearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint 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 PA- PER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A RE- DUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford St. Carlisle. PA 17013 CUMBERLAND LAW JOURNAL (717) 249-3166 LEGAL SERVICES INC. 401 E. Louther St. Ste. 103 Carlisle, PA 17013 (717) 243-9400 MICHAEL T. McKEEVER, ESQUIRE GOLDBECK McCAFFERTY & McKEEVER, P.C. Attorneys for Plaintiff Mellon Independence Center 701 Market St. Suite 5000 Philadelphia, PA 19106-1532 (215) 627-1322 Aug. 13 N. KML LAW GROUP,P.C. Suite 5000-BNY Mellon Independence Center 701 Market Street ATTORNEY FOR PLAINTIFF Philadelphia,PA 19106-1532 215-627-1322 WELLS FARGO BANK MINNESOTA,N.A.,AS INDENTURE TRUSTEE FOR MSCC HELOC TRUST 2007-1 S/B/M NORWEST BANK MINNESOTA,NA,AS INDENTURE TRUSTEE FOR In the Court of Common Pleas of NOVUS HOME EQUITY LOAN TRUST 1999-MS1 Cumberland County Plaintiff Civil Action-Law vs. Action of Mortgage Foreclosure The Unknown Heirs of Paulette D.Beck,Deceased,GARY D. NULL,DENISE M.NULL,JENNIFER NELSON,Solely in Her No. 10-4185-CIVIL TERM) f,,,, C Capacity as Heir of Paulette D.Beck,Deceased,RICHARD BECK, `_.4 • Solely in His Capacity as Heir of Paulette D.Beck,Deceased and r co a --wj.„ ROY SEIXAS,Solely in His Capacity as Heir of Paulette D.Beck, =m c-) r n - Deceased m 3 ---a t-;:.; (Mortgagors)and (Record Owners) of)b ` 420 Bosler Avenue ice—M --4c) Lemoyne,PA 17043 D G� =-. 'n' Defendant(s) p 5 c=-tlLJ '7.- 3 `1 4-. . SUGGESTION OF BANKRUPTCY -{ a ' TO THE CLERK OF THE COURT: Please take note that Defendant The Unknown Heirs of Paulette D. Beck, Deceased, GARY D. NULL, DENISE M. NULL, JENNIFER NELSON, Solely in Her Capacity as Heir of Paulette D. Beck,Deceased, RICHARD BECK, Solely in His Capacity as Heir of Paulette D.Beck,Deceased and ROY SEIXAS,Solely in His Capacity as Heir of Paulette D.Beck,Deceased filed a Chapter 13 Bankruptcy on August 30,2010 in the United States Bankruptcy Court for the Middle District of Pennsylvania at Case Number 10-07085. Accordingly, the above captioned matter should be deferred until the conclusion of the bankruptcy proceedings. By: KML LAW ROUP,P.C. Michael McKeever Pa.ID 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 'ill P.Jenkins Pa.ID 306588 Salvatore Filippello Pa.ID 313897 Alyk Oflazian Pa.ID 312912 Attorneys for Plaintiff o KML LAW GROUP,P.C. Suite 5000-BNY Mellon Independence Center 701 Market Street ATTORNEY FOR PLAINTIFF Philadelphia,PA 19106-1532 215-627-1322 WELLS FARGO BANK MINNESOTA,N.A.,AS INDENTURE TRUSTEE FOR MSCC HELOC TRUST 2007-1 S/B/M NORWEST BANK MINNESOTA,NA,AS INDENTURE TRUSTEE FOR In the Court of Common Pleas of NOVUS HOME EQUITY LOAN TRUST 1999-MS1 Cumberland County Plaintiff Civil Action-Law vs. Action of Mortgage Foreclosure The Unknown Heirs of Paulette D.Beck,Deceased,GARY D. NULL,DENISE M.NULL,JENNIFER NELSON,Solely in Her No. 10-4185-CIVIL TERM Capacity as Heir of Paulette D.Beck,Deceased,RICHARD BECK, Solely in His Capacity as Heir of Paulette D.Beck,Deceased and ROY SEIXAS,Solely in His Capacity as Heir of Paulette D.Beck, Deceased (Mortgagors)and (Record Owners) 420 Bosler Avenue Lemoyne,PA 17043 Defendant(s) CERTIFICATE OF SERVICE ItLisa Kane,hereby certifies that on +/ > (3 I did send a true and correct copies of the within Suggestion of Bankruptcy by first class mail,postage pre-paid upon the following: The Unknown Heirs of Paulette D.Beck,Deceased 420 Bolser Avenue Lemoyne,PA 17043 GARY D.NULL 420 Bosler Avenue Lemoyne,PA 17043 DENISE M.NULL 420 Bosler Avenue Lemoyne,PA 17043 JENNIFER NELSON,Solely in Her Capacity as Heir of Paulette D.Beck,Deceased 1713 Cedar Cliff Drive Camp Hill,PA 17011 RICHARD BECK,Solely in His Capacity as Heir of Paulette D.Beck,Deceased 420 Bosler Ave Lemoyne,PA 17043 ROY SEIXAS,Solely in His Capacity as Heir of Paulette D.Beck,Deceased 507 16th Ave New Cumberland,PA 17070 KML LAW G UP,P. BY: LA.44-- Employee of KML LAW GROUP,P.C. IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY WELLS FARGO BANK MINNESOTA,N.A.,AS Term INDENTURE TRUSTEE FOR MSCC HELOC TRUST 2007-1 S/B/M NORWEST BANK MINNESOTA,NA, No. 10-4185-CIVIL TERM AS INDENTURE TRUSTEE FOR NOVUS HOME EQUITY LOAN TRUST 1999-MS1 4708 Mercantile Drive North Fort Worth, TX 76137 c VS. The Unknown Heirs of Paulette D.Beck,Deceased, rn �t : GARY D.NULL, DENISE M.NULL,JENNIFER of"_ �a � c NELSON, Solely in Her Capacity as Heir of Paulette D. -< �. Beck,Deceased,RICHARD BECK, Solely in His <Q x Capacity as Heir of Paulette D. Beck,Deceased and ROY =cp .. . "=r� SEIXAS, Solely in His Capacity as Heir of Paulette D. p — ` Beck,Deceased Mortgagor(s) and Record Owner(s) 420 Bosler Avenue Lemoyne,PA 17043 STATEMENT OF INTENT TO PROCEED TO THE COURT: WELLS FARGO BANK MINNESOTA,N.A.,AS INDENTURE TRUSTEE FOR MSCC HELOC TRUST 2007-1 S/B/M NORWEST BANK MINNESOTA,NA,AS INDENTURE TRUSTEE FOR NOVUS HOME EQUITY LOAN TRUST 1999-MS1 intends to proceed with the above captioned matter. Defendants' Chapter 13 Bankruptcy filed on August 30, 2010 in the United States Bankruptcy Court for the Middle District of Pennsylvania and Case. 10-07085 is active, and this action should remain in deferred status. Plaintiff reserves the right to proceed upon the conclusion of the bankruptcy, if appropriate. Date q(,;, (1..2_4(9 By: ay- KML LAW GROUP,P.C. Michael McKeever Pa.ID 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Jill P.Jenkins Pa. ID 306588 Salvatore Filippello Pa.ID 313897 Alyk Oflazian Pa.ID 312912 Attorneys for Plaintiff V ff KML LAW GROUP,P.C. Suite 5000-BNY Mellon Independence Center 701 Market Street ATTORNEY FOR PLAINTIFF Philadelphia,PA 19106-1532 215-627-1322 WELLS FARGO BANK MINNESOTA,N.A.,AS INDENTURE TRUSTEE FOR MSCC HELOC IN THE COURT OF COMMON PLEAS TRUST 2007-1 S/B/M NORWEST BANK MINNESOTA,NA,AS INDENTURE TRUSTEE of Cumberland County FOR NOVUS HOME EQUITY LOAN TRUST 1999-MS 1 4708 Mercantile Drive North No. 10-4185-CIVIL TERM Fort Worth,TX 76137 vs. The Unknown Heirs of Paulette D. Beck,Deceased GARY D.NULL DENISE M.NULL JENNIFER NELSON, Solely in Her Capacity as Heir of Paulette D.Beck,Deceased RICHARD BECK, Solely in His Capacity as Heir of Paulette D. Beck,Deceased ROY SEIXAS, Solely in His Capacity as Heir of Paulette D. Beck,Deceased 420 Bosler Avenue Lemoyne,PA 17043 CERTIFICATE OF SERVICE Lisa Kane, an employee of KML Law Group, P.C., counsel for plaintiff, does hereby certify that on tj)301,3 , true and correct copies of the foregoing Statement of Intent to Proceed have been served by first class mail,postage prepaid, upon the following: The Unknown Heirs of Paulette D. Beck, Deceased 420 Bolser Avenue Lemoyne, PA 17043 GARY D.NULL 420 Bosler Avenue Lemoyne, PA 17043 DENISE M. NULL 420 Bosler Avenue Lemoyne, PA 17043 JENNIFER NELSON, Solely in Her Capacity as Heir of Paulette D. Beck, Deceased 1713 Cedar Cliff Drive Camp Hill, PA 17011 RICHARD BECK, Solely in His Capacity as Heir of Paulette D. Beck, Deceased 420 Bosler Ave Lemoyne, PA 17043 ROY SEIXAS, Solely in His Capacity as Heir of Paulette D. Beck, Deceased 507 16th Ave New Cumberland, PA 17070 JENNIFER NELSON, Solely in Her Capacity as Heir of Paulette D. Beck, Deceased 1917 Kent Drive Camp Hill, PA 17011 JENNIFER NELSON, Solely in Her Capacity as Heir of Paulette D. Beck, Deceased 420 Bosler Avenue Lemoyne, PA 17043 ROY SEIXAS, Solely in His Capacity as Heir of Paulette D. Beck, Deceased 420 Bosler Avenue Lemoyne, PA 17043 KML AW GROUP, P.C. By: 1/"."/L147A(__ Lisa Kane, Legal Assistant Employee of KML LAW GROUP, P.C.