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Home My WebLink About10-5358RICHARD F. STERN, ESQUIRE (03315) STEVEN K. EISENBERG, ESQUIRE (75736) .KEVIN P. D1sKIN, ESQUIRE (86727) STERN AND EISENBERG, LLP THE PAVILION 261 OLD YORK ROAD, SUITE 410 JENKINToWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) obo AM llo PM 11; 53 ?v J! IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY DEUTSCHE BANK NATIONAL TRUST COMPANY, AS Trustee for the registered holders of MORGAN STANLEY ABS CAPITAL I INC. TRUST 2007-HE5 MORTGAGE PASS-THROUGH CERTIFICATES,SERIES 2007-HE5, by its attorney in fact, Ocwen Loan Servicing, LLC 1661 Worthington Road, Suite 100 West Palm Beach, FL 33409 v. Joseph J. Lego and Christina L. Lego 3 Edgewood Drive Mechanicsburg, PA 17055 Defendant(s) Civil Action Number: 10- /? 5358 ?;vil iems COMPLAINT IN MORTGAGE FORECLOSURE CIVIL ACTION - MORTGAGE FORECLOSURE NOTICE This is an attempt to collect a debt and any information obtained will be used for that purpose. You have been sued in Court. If you wish to defend the claims set forth in the following pages, you must take action within twenty (20) days after this Civil Action and notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defense 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 Civil Action or for any other claim or relief requested by the plaintiff. You may lose money or property of othe is important to you. 5 44 ^90143 P,* apt X858 J: \Supriya\Complainu\Cumberland\Ocwen.Lego.08.10. doc YOU SHOULD TAKE THIS PAPER TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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 32 South Bedford Street Carlisle, PA 17013 800-990-9108 717-249-3166 J:\Supriya\Complaints\Cumberland\Ocwen.Lego.08.10.doc NOTICE PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ., YOU MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF YOU DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE YOU WITH WRITTEN VERIFICATION OF THE DEBT, AS WELL AS THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM THE CURRENT CREDITOR. OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. IF YOU DO NOT DISPUTE THE DEBT, IT IS NOT AN ADMISSION OF LIABILITY BY YOU. IF YOU NOTIFY US IN WRITING WITHIN THE THIRTY (30) DAY PERIOD, WE WILL CEASE COLLECTION OF THIS DEBT, OR ANY DISPUTED PORTION OF IT, UNTIL WE HAVE OBTAINED THE REQUIRED INFORMATION AND MAILED IT TO YOU. ONCE WE HAVE MAILED YOU THE REQUIRED INFORMATION, WE WILL CONTINUE THE COLLECTION OF THIS DEBT. THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR. THIS ACTION IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. J:\Supriya\Complaints\Cumberland\Ocwen.Lego.08.10.doc RICHARD F. STERN, ESQUIRE (03315) STEVEN K. EISENBERG, ESQUIRE (75736) KEVIN P. DIsKiN, ESQUIRE (86727) STERN AND EISENBERG, LLP THE PAVILION 261 OLD YORK ROAD, SUITE 410 JENKINTowN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FAcsnvtiLE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY DEUTSCHE BANK NATIONAL TRUST COMPANY, AS Trustee for the registered holders of MORGAN STANLEY ABS CAPITAL I INC. TRUST 2007-HE5 MORTGAGE PASS-THROUGH CERTIFICATES,SERIES 2007-HE5, by its attorney in fact, Ocwen Loan Servicing, LLC 1661 Worthington Road, Suite 100 West Palm Beach, FL 33409 v. Joseph J. Lego and Christina L. Lego 3 Edgewood Drive Mechanicsburg, PA 17055 Defendant(s) Civil Action Number: COMPLAINT IN MORTGAGE FORECLOSURE COMPLAINT CIVIL ACTION - MORTGAGE FORECLOSURE 1. Plaintiff is DEUTSCHE BANK NATIONAL TRUST COMPANY, AS Trustee for the registered holders of MORGAN STANLEY ABS CAPITAL I INC. TRUST 2007-HE5 MORTGAGE PASS-THROUGH CERTIFICATES,SERIES 2007-HE5, by its attorney in fact, Ocwen Loan Servicing, LLC (hereinafter referred to as "DEUTSCHE BANK NATIONAL TRUST COMPANY") with offices located at 1661 Worthington Road, Suite 100, West Palm Beach, FL 33409. 2. Defendant(s) are Joseph J. Lego and Christina L. Lego, adult individuals with a last- known address of 3 Edgewood Drive, Mechanicsburg, PA 17055. 3. Under date of 12/12/2006, defendants executed and delivered to MERS, INC., AS NOMINEE FOR DECISION ONE MORTGAGE COMPANY, LLC a mortgage upon the J:\Supriya\Complaints\Cumberland\Ocwen.Lego.08.10.doc property 3 Edgewood Drive, Mechanicsburg, PA (the "Property") to secure the payment of the sum of $120,000.00. The said mortgage is recorded in the Office for the Recording of Deeds in and for Cumberland County on 12/20/2006 at Book 1976 at Page 4640 and is incorporated herein by reference as though set forth at length herein. A copy of the legal description of the Property is attached hereto and made a part hereof as Exhibit "A". 4. The said mortgage was assigned to DEUTSCHE BANK NATIONAL TRUST COMPANY, the within Plaintiff, by Assignment which has been duly recorded or is in the process of being recorded. 5. Ocwen Loan Servicing LLC, successor to Ocwen Federal Bank FSB is the attorney in fact authorized to act for Plaintiff. 6. Said Defendant(s) are the real owners of Property 3 Edgewood Drive, Mechanicsburg, PA 17055. 7. In accordance with Act 91 of 1983, as amended, a combined notice providing the information required by §403 of Act No. 6 of 1974, and Act 91, aforesaid, was sent to the defendants and no response was made in the appropriate period of time. A true and correct copy of the aforesaid notice is attached hereto and made a part hereof as Exhibit "B" 8. The said loan is in default as a result of the failure to pay the monthly installments of $1,054.55 due on March 1, 2010 and on the same day of each month thereafter. 9. The following is due on the loan: PRINCIPAL BALANCE ....................................................... $115,042.40 INTEREST accrued thru 08/11/2010 of ............................... $4,232.00 Interest after 08/11/2010 shall accrue at the per diem rate of $22.19.) LATE CHARGES accrued thru 08/11/2010 of ..................... $659.27 Late charges after 08/11/2010 shall accrue at the monthly rate of $39.57.) ESCROW ADVANCES ........................................................ $698.75 FEES BILLED ....................................................................... $1,409.07 COSTS ................................................................................... 300.00 ATTORNEY'S FEE .............................................................. $6,000.00 LESS SUSPENSE (If any) ..................................................... ($883.37) TOTAL .................................................................................. $127,458.12 The attorney fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the J:\Supriya\Complaints\Cumberland\Ocwen.Lego.08.10. doc mortgage is reinstated prior to Sale, reasonable attorney fees will be charged based on work actually performed. WHEREFORE, Plaintiff, DEUTSCHE BANK NATIONAL TRUST COMPANY requests this Court to enter judgment for foreclosure of the mortgaged property for the sum of $115,042.40 plus interest thereon of $4,232.00 plus $22.19 per day from 08/11/2010 until judgment is paid in full, late charges of $659.27, plus late charges of $39.57 per month from 08/11/2010 until judgment is paid in full, escrow advances of $698.75, fees billed of $1,409.07, costs of $300.00, attorney's fees of $6,000.00 and all other amounts set forth above, less any suspense as set forth above, together with record costs and any other amounts to which Plaintiff is entitled to recover. STERN AND EISENBERG LLP BY: Date: August 11, 2010 RYHARD F. STERN, ESQUIRE TEVEN K. EISENBERG, ESQUIRE KEVIN P. DISKIN, ESQUIRE Attorney for Plaintiff J:\Supriya\Complaints\Cumberland\Ocwen. Lego.08.10. doc VERIFICATION JOHNNA MILLER is Authorized signer of OCWEN LOAN SERVICING LLC and is authorized to sign this Verification on behalf of same, and states that she verifies the foregoing Civil Action-Mortgage Foreclosure against the within defendant and avers the statements of fact therein contained are made subject to the penalties of 18 PA C.S. Section 4904 relating to the unswom falsification to authorities, and that same are true upon the signer's personal knowledge or information and belief. Da t e:g /&r O -JOHn-in-aMiller, Authorized Signer 557098424044 Lego ALL THAT CERTAIN lot of land situate in Mechanicsburg, Cumberland County, Pennsylvania, more described as follows, to wit: BEGINNING at a point on the Southwesterly line of Edgewood Drive, which point is at the line of dividing Lots 4 and 3, Block K on the hereinafter mentioned Plan of Lots; thence South 77 degrees 27 minutes West 177.41 feet to a point at lands now or formerly of Samual Engle; thence North 03 degrees 20 minutes East 86.49 feet to the dividing line of Lots Nos. 4 and 5 on the aforesaid Plan; thence North along same 83 degrees 57 minutes 20 seconds East 155.90 feet to a point on the Southwesterly line of Edgewood Drive; thence by an arc curving to the left, having a radius of 180 feet an arc distance of 20.44 feet to a point; thence South 12 degrees 33 minutes East 45.13 feet to the point and place of BEGINNING. UNDER AND SUBJECT to a 25 feet building set-back line. HAVING THEREON ERECTED a dwelling numbered 3 Edgewood Drive. BEING Lot No. 4, Block K as laid out on the Final Plan of Block K and part of Blocks H, B and D of Wynnewood Park and recorded in the Cumberland County Recorder's Office in Plan Book 26, page 66. BEING part of the same premises which W.D.C., Inc. a Pennsylvania Corporation by Deed dated February 13, 1976 and recorded in the aforesaid Recorder's Office in Deed Book L, Volume 26, Page 557, granted and conveyed unto Philip S. Lego and Yoon J. Lego, his wife. The said Philp S. Lego and Yoon J. Lego a/k/a Nancy A. Lego died on June 28, 2006 I Certify this to be recorded In Cumberland County PA L Recorder of Deeds (AAMOS-ooso2RMAAM0640602n 2) O1976PG46 Ocwen Loan Servicing, LLC P.O. Box 24737 `OI O C W E N West Palm Beach' Florida 33416-4737 (Do not send correspondence or payments to the above address.) W W W.OC WEN.COM June 19, 2010 VIA First Class Mail VIA Certified Mail (return receipt requested) Certified Number: 71069017515134356305 Reference Code: 1003 Christinia L. Lego 3 Edgewood Dr Mechanicsburg, PA 17055 Loan Number: 70984240 Property Address: 3 Edgewood Dr, Mechanicsburg, PA 17055-0000 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 t° Ocwen Loan Servicing, LLC '•. P.O. Box 24737 OCWEN West Palm Beach' Florida 33416-4737 (Do not send correspondence or payments to the above address) WWW.OCWEN.COM June 19, 2010 APPENDIX A ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortg age on your home is in default= an d the lende r intends to forec lose Specific information about the nature of the defau lt is p rovide d in the att ached pages . The HOMEOWNER'S MOR TGAGE A SSIST ANCE PROGRA M (HEMAP ) may be a ble to help to sav e your home This Notice explains how the p rogram wo rks. To see if HEMAP can help you must MEET WITH A CONS UMER CR EDIT COU NSELING AGEN CY WITHIN THIRTY (30) DAYS OF TH E DATE OF T HIS N OTICE. T ake this N otice with you when you m eet with the Counseling AgencL - The name. address and phone number o f Cons umer Credit Cou nseling Age ncies servin g your County ar e listed at the end of this Notice. If you have any questi ons. y ou may call the Pe nnsylvania Housing Fi nance Agency toll free at (800) 342-2397 (Persons with i mpaired he aring can ca ll 712) 780 -18691. This Notice contains importan t legal inf ormat ion. If you have a ny question s, represen tatives at the Cons umer Credit Counseling Agency may be ab le to help explai n it. Y ou may als o want to c ontact an a ttorney in your ar ea The local bar association may be able to help you fi nd a l awyer. 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 LENDERISERVICER: Christinia L. Lego 3 Edgewood Dr Mechanicsburg, PA 17055-0000 70984240 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 t---' West Palm Beach, Florida 33416-4737 DGWEN (Do not send correspondence or payments to the above address.) WW W.OC WEN.COM HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH C AVE 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. TEMPO RARY STAY OF FORECL OSURE. -Under the Act. you are entitled to a tem norarvjttay of foreclosure on your mo rtgage for thirty_(30days fr om the date of this Notice. During that time you mu st arrange and attend a "face- to-face" meeting with one of the con sumer credit counseling agencies listed at the end o f this Notice THIS MEETING MUST O CCUR WITHIN THE NE XT 00) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE. ASSISTA NCE YOU MUST BRIN G YOUR MORTGAGE P TO DATE. THE PART OF THIS NOTICE CALL ED "HOW TO CURE. YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO D ATE. CONSUMER EDIT COUNSELING AGENCIES - 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 telephone numbers of designated consumer credit counseling agencies for the oun in which the propeM is located are set forth at the end of h'. 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.) 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). DAM1.16 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 O[ P.O. Box 24737 O O W E N West Palm Beach, Florida 33416-4737 (Do not send correspondence or payments to the above address.) W WW.OCWEN.COM HOW TO CURE YOUR MORTGAGE. DEFAULT (Bring it up to daft), NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property located at: 3 Edgewood Dr, Mechanicsburg, PA 17055-0000 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 4 payments in the amount of $ 1,054.55 from March 01. 2010 through June 19. 2010 DETAIL SUMMARY : Principal and Interest ................................. Interest Arrearage ..................................... Escrow .................................................. Late Charges ........................................... Insufficient Funds Charges ........................... Fees / Expenses ........................................ Suspense Balance (CREDIT) ........................ Interest Reserve Balance (CREDIT) ................ TOTAL DUE .......................................... $ 3,165.44 $ 0.00 $ 1,046.51 $ 619.70 $ 0.00 $ 723.57 $ 883.37 $ 0.00 $ 4,671.85 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 $4,671.85, 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's heck Certified 'heck or Money Order made payable and sent to: OCWEN P.O. BOX 6440 CAROL STREAM, IL 60197-6440 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 u0n your mortgaged propgrtv. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY QQ) 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 THE 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 till have h right to cure the default and prevent the sale at any time unto one hour before he Sheriffs Cale You may do so by pa-^ng the total amount hen other r 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. DAM1.16 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 QCWEN West Palm Beach, Florida 33416-4737 (Do not send correspondence or payments to the above address.) WWW.OCWEN.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 servicer. HOW TO CONTACT THE SERVICER: Name of Servicer: OCWEN Address: 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 X 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. 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 (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 AGENCIES SERVING YOUR COUNTY 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 ;n P.O. Box 24737 W E N West Palm Beach, Florida 33416-4737 O C (Do not send correspondence or payments to the above address.) W W W.OC WEN.CnM June 19, 2010 VIA First Class Mail VIA Certified Mail (return receipt requested) Certified Number: 71069017515134356299 Reference Code: 1003 Joseph J. Lego 3 Edgewood Dr Mechanicsburg, PA 17055-0000 Loan Number: 70984240 Property Address: 3 Edgewood Dr, Mechanicsburg, PA 17055-0000 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 i € Ocwen Loan Servicing, LLC i i P.O. Box 24737 °-- ° O C W E E N West Palm Beach, Florida 33416-4737 (Do not send correspondence or payments to the above address.) W W W.OC WEN.COM APPENDIX A June 19, 2010 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE 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 ap gres. 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 THIRTY (30) DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the_ Counseling Agency, The name. address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at (800) 342-2397 (Persons with impaired hearing can call (717) 780-18691. This Notice contains important legal information. If you have any questions. representatives at the Consumer Credit Counseling Agency may be able to he explain it. You may also want to contact an attorney in your area The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, 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: Joseph J. Lego 3 Edgewood Dr Mechanicsburg, PA 17055-0000 70984240 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 0 0 Ocwen Loan Servicing, LLC P.O. Box 24737 O C W W E N West Palm Beach, Florida 33416-4737 (Do not send correspondence or payments to the above address.) W W W .OC WEN.COM HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE 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. TEMPO RA RY STAY OF FORECLOS URE --Under the Act. you are entitled to a tem porary stay of foreclosure on your mor tga ge for thirty (Q) days from the date of this Notice. During that time you mu st arrange and attend a "face- to-face" mee ting with one of the consum er credit counseling agencies listed at the end o f this Notice THIS MEETING MUST O CC UR WITHIN THE NEXT (30) DAYS IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTA NC E. YOU MUST BRING YOUR MORTGAGE UP TO DATE, THE PART OF THIS NOTICE CALLED "H OW TO CURE YOUR MO RTGAGE DEFAULT", EXPLAINS HOW TO _ BRING YOUR MORTGAGE UP TO D AT E. CONSUMER CREDIT COUNSELING AGENCIES -- 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 telephone numbers of designated consumer credit counseling agencies for the- county in which the proper 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.) 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 i Ocwen Loan Servicing, LLC nn P.O. Box 24737 V O C W E N West Palm Beach, Florida 33416-4737 (Do not send correspondence or payments to the above address.) W WW.OCWEN.COM NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender on your property located at: 3 Edgewood Dr, Mechanicsburg, PA 17055-0000 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 4 payments in the amount of $ 1,054.55 from March 01. 2010 through June 19, 2010 DETAIL SUMMARY : Principal and Interest ................................. Interest Arrearage ..................................... Escrow .................................................. Late Charges ........................................... Insufficient Funds Charges ........................... Fees / Expenses ........................................ Suspense Balance (CREDIT) ........................ Interest Reserve Balance (CREDIT) ................ TOTAL DUE .......................................... $ 3,165.44 $ 0.00 $ 1,046.51 $ 619.70 $ 0.00 $ 723.57 $ 883.37 $ 0.00 $ 4,671.85 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 $4,671.85, 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's Check 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 THE, DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intend 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 lemon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period. you will not be required to pay attorney's fees. OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE. THE. DEFAULT PRIOR TO SHERIFF'S SALE _ If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale You may do so by pa?dng the total amount then. nast due_ nhis anv late nr nth- rha-v t{.eo A.,o . e.. ....{.1 .u .. _.? a--- - -- ---_ - -. - , .. - otner requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. 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) WW W.OCWEN.COM EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately 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 servicer. HOW TO CONTACT THE SERVICER: Name of Servicer: OCWEN Address: 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 Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may or X 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. 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 (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. 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 ACT 91 AGENCY LISTING PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES ACORN HOUSING CORPORATION COMM. ON ECONOMIC OPPORTUNITY FOR LUEERNE COUNTY 846 North Broad Street 163 Amber Lane Philadelphia, Pa., 19130 Willies-Barre, Pa., 18702 (215) 765-1221 (570) 826-0510 or 1-800-822-0359 Counties: Bucks, Chester, Delaware, Montgomery and Philadelphia Counties: Carbon, Luzeme, Schuylkill and Wyoming Action Honing, Inc 425 6° Avenue, Suite 950 Pittsburgh, Pa., 15219 (412)391-1956,(412)28I-2102 or(900)792-2801 Counties: Allegheny, Beaver, Butler, Fayette, Greene Washington and Westmoreland Adams County Interfaith Housing Authority AMERICAN RID CROSS - HANOVER CHAPTER 529 Carlisle Strzet Hanover, Pa-, 17331 (717) 637-3294 FAX (717) 637-3294 Contact Stephanie Calp Counties: Adams, Franklin and York BLAIR COUNTY ECONOMIC OPPORTUNITY COUNCIL 5433 Industrial Avenue Altoona, Pennsylvania, 16601 (814) 946-3651 FAX: (8 14) 946-5451 Contact Paul Rennie Counties: Blair only BOOKER T. WASHINGTON CENTER 1720 Holland Street Erie, Pennsylvania, 16503 (814) 453-5744 FAX (814) 453-5749 Contact Bob Hubta Counties: Crawford, Earl and Warren BUCKS COUNTY HOUSING GROUP, INC. 140 East Richardson Avenue Langhorne, Pa., 19047 (215) 750-4310 FAX (215) 750-4318 Contact: Pat Dyson Counties: Bucks only BUDGET COUNSELING CENTER 247 North Fifth Street Reading, Pa., 19601 (215) 375-7866 FAX: (215) 376-0575 - Main Office Contact: Deborah Strunk Counties: Berks, Chester, Montgomery and Schuylkill CENTRO PEDRO CLAVER 3565 North 7th Street Philadelphia, Pa., 19130 (215) 227-7111 FAX: (215) 227-7117 Contact: Roberto Santiago Counties: Philadelphia, Bucks, Chester, Delaware and Montgomery COMMUNITY ACTION SOUTHWEST 22 West High Street Waynesburg, Pa., 15370 (412) 852-2893 FAX: (412) 627-7713 Contact Doug Wagner Counties: Allegbeay, Fayette, Greene, Washington and Westmoreland CONSUMER CREDIT COUNSELING SERVICE OF DELAWARE VALLEY 1515 Market Street, Suite 1325 Philadelphia, Pa., 19102 (215) 563-5665 FAX (215) 8642666 Contact Tom O'Neill Counties: Bucks, Chester, Delaware, Montgomery and Philadelphia CONSUMER CREDIT COUNSELING SERVICE OF LEHIGH VALLEY 3671 Crescent Court East Whitehall, Pa., 19107 (215) 921-4011 or 1-800-220-2733 (717 & 814 Area codes only) FAX (215) 821-0137 Contact AI Kotcb Counties: Berks, Bucks, Carbon, Lancaster, Lehigh and Northhampton CONSUMER CREDIT COUNSELING SERVICE OF WESTERN PENNSYLVANIA, INC. A) 309 Smithfield Street, Suite 2000 Pittsburgh, Pa., 15222 (412)471-7584 Contact: Jack Onorad B) 1 North Gate Square #2 Garden Center Drive Greensburg, Pa., 15601 (412) 838-1290 C) 500-02 3rd Avenue, P.O. Box 278 Duncanville, Pa-, 16635 (814) 696-3546 D) l st Federal Plaza, Suite 406 North Mill Street Newcastle, Pa., 16101 (412) 652-8074 E) 524 Franklin Avenue Franklin Center Aliquippa, Pa., 15001 (412) 652-8074 txf a. ACT 91 AGENCY LISTING CONTRgMD CONSUMER CREDIT COUNSELING OF WESTERN PENNSYLVANIA, INC. (CONT.) F) 2000 Linglestown Road Harrisburg, Pa., 17102 (717) 541-1757 Counties: Adams, Cumberland, Dauphin, Perry and York G) YMCA Building 339 North Washington Street Butler, Pa., 16001 Counties: Allegheny, Armstrong, Beaver, Bedford, Blair, Butler, Cambria, Cameron, Centre, Clarion, Clearfield, Fayette, Franklin, Fulton, Greene, Huntingdon, Indiana, Jefferson, Juniata, Lawrence, Mercer, Mifflin, Snyder, Somerset, Union, Venango, Washington and Westroortland. H) 912 South George Street York, Pa., 17403 (717) 846-4176 Counties: York, Adams, Franklin and Lancaster CONSUMER CREDIT COUNSELING SERVICE OF NORTHEASTERN PENNSYLVANIA A) Human Services Building 541 Wyoming Avenue, Box 168 Scranton, Pa., 18501 (717) 342-1072 or (800) 922-9537 FAX (717) 342-8040 B) 31 West Market Street Wilkes-Barre, Pa., 18702 (717) 821-0837 or (800) 922-9537 FAX (717) 821-1785 Contact Mike Elick Counties: Bradford, Carbon, Columbia, Lackawanna, Luzeme, Lycoming, Monroe, Montour, Northumberland, Pike, Sullivan, Susquehanna, Tioga, Wayne and Wyoming ECONOMIC OPPORTUNITY CABINET OF SCHUYLKILL COUNTY 118 Norwegian Street Pottsville, Pa., 17901 (717) 622-1995 FAX (717) 622-0429 Contact Marybeth Dohman Counties: Berks, Carbon, Lebanon, Lehigh, Luzerne, Northumberland and Schuylkill FAYETTE COUNTY COMMUNITY ACTION AGENCY, INC. 137 North Beeson Avenue Uniontown, Pa-, 15401 (412) 437-6050 ext. 38 or (800) 427-INFO FAX: (412) 437-4418 Contact: Jennifer Canada FINANCIAL SERVICES UNLIMITED 117 West 3rd Street Waynesboro, Pa., 17268 (717) 762-3285 Contact: Natalie Newcomer Counties: Adams, Cumberland, Franklin, Fulton and Perry GREATER ERIE COMMUNITY ACTION COMMITTEE 18 West 9th Street Erie, Pa-, 16501 (814) 459-4581 FAX: (814) 456-0161 Contact: Robert Lamary Counties: Crawford, Erie, Venango and Warren INDIANA COUNTY COMMUNITY ACTION PROGRAM 827 Water Street, Box 187 Indiana, Pa L, 15701 (412) 465-2657 FAX (412) 465-5118 Contact Randy Foster Counties: Armstrong Cambria, Clearfield, Indiana, Jefferson and Westmoreland HOME MORTGAGE PROTECTION GROUP A) 19 West 3rd Street Chester, Pa., 19013 (215) 247-4712 B) 8634 Provident Street Philadelphia, Pa-, 19150 (215) 447-9568 FAX (215) 872-856 Contact A-H. Muhammed Counties: Berks, Chester, Delaware, Lancaster, Montgomery and Philadelphia HOUSING COUNCIL OF YORK 116 North George Street York, Pa., 17401 (717) 854-1541 FAX (717) 854-7934 Contact Diana Walker County. York only HOUSING ASSOCIATION OF DELAWARE VALLEY A) 1314 Chestnut Street, Suite 900 Philadelphia, Pa., 19107 (215) 545-6010 FAX (215) 790-9132 B) 658 North Watts Street Philadelphia, Pa., 19123 (215) 978-0224 FAX (215) 765-7614 Contact Khalil Walker County. Philadelphia only HOUSING OPPORTUNITIES, INC. 133 Seventh Street, P.O. Box 9 MckeespoM Pa., 15134 (412) 6641590 FAX (412) 664-0873 Contact Allen Sethman Counties: Allegheny, Beaver, Butler, Washington and Westmoreland JOHN F. KENNEDY CENTER, INC. 2021 East 20th Street Erie, Pa, 16510 (814) 898-0400 FAX: (814) 899-1243 Contact: Mary Gavin Counties: Crawford, Elk, Erie, Jefferson, Mckean and Venango KEYSTONE ECONOMIC DEVELOPMENT CORP. 1954 Mary Grace Lane Johnstown, Pa., 15901 (814) 539-1688 FAX: (814) 539-1688 Contact David Kennedy Counties: Bedford, Blair, Cambria, Clearfield, Indiana, Somerset and Westmoreland txf r, ACT 91 AGENCY LISTING CONTINUED LA CASA DEL PUEBLO 815 W. Baltimore Turnpike Kennet Square, Pa., 19348 (215) 444-3731 FAX (215) 4443178 Contact Dawn Vega Counties: Chester, Delaware, Montgomery, Lancaster and Berks LYCOMWG-CLINTON COUNTIES COMMISSION FOR COMMUNITY ACTION 2138 Lincoln Street, PO Box 1328 Williamsport, Pa., 17703 (717) 326-0587 FAX: (717) 322-2197 Contact Dan Mark Counties: Clinton and Lycoming MEDIA FELLOWSHIP HOUSE 302 South Jackson Street Media, Pa., 19063 (215) 565-0846 Contact: Joyce Kane Counties: Chester, Delaware, Montgomery and Philadelphia MONTGOMERY COUNTY OPPORTUNITY BOARD 530 Church Street, 2nd Floor Norristown, Pa., 19401 (215) 277-6363 FAX (215) 277-2123 Contact: Charles Mason County. Montgomery only MON-VALLEY UNEMPLOYED COMMITTEE 116 Fifth Avenue Mckeesport, Pa., 15132 (412) 678-1409 Contact Ray Ganczk Counties: Allegheny, Beaver, Butler, Fayette, Green Washington and Westmoreland NORTHERN TIER COMMUNITY ACTION CORP. 135 West 4th Street Emporium, Pa., 15834 (814) 486-1161 FAX: (814) 486-3370 Contact: Fred Fish Counties: Cameron, Elk, Mckean and Potter PHILADELPHIA COUNCIL FOR COMMUNITY ADVANCEMENT 100 North 17th Street, Suite 600 Philadelphia, Pa., 19103 (215) 567-7803 FAX: (215) 963-9941 Contact: Henry Cruz Counties: Chester, Delaware, Montgomery and Philadelphia SHENANGO VALLEY URBAN LEAGUE, INC. Housing Counseling Services 39 Chestnut Street Sharon, Pa., 16146 (412) 981-5310 Contact: James Long Counties: Crawford, Lawrence and Mercer TABLELAND SERVICES, INC. 131 North Center Avenue Somerset, Pa., 15501 (814)445-9628 FAX (814) 443-3690 Contact Mary Ann Strong Counties: Bedford, Cambria, Fayette, Somerset and Westmoreland TABOR COMMUNITY SERVICES, INC. 439 East King Street Lancaster, Pa., 17602 (717) 397-5182 or (800) 788-5062 (Homeowners only) FAX (717) 3994117 Contact Navin Horst Counties: Chester, Lebanon and Lancaster THE TREEIAB CENTER OF NORTHEASTERN PENN. A) 7 Lake Avenue, Box 366 Montrose, Pa., 18801 (800) 982-4045 FAX (717) 278-1889 B) 185 Elmira Street, P.O. Box 218 Troy, Pa, 16947 (717) 297-2101 Contact Carole Munn Counties: Bradford, Sullivan, Susquehanna, Tioga, Wayne and Wyoming URBAN LEAGUE OF METROPOLITAN HARRISBURG 25 North Front Street Harrisburg, Pa., 17101 (717) 234-5925 FAX (717) 232-4985 Contact Kelly Sloane URBAN LEAGUE OF PHILADELPHIA Urban Education Foundation 4601 Market Street, 2nd Floor/South Wing Philadelphia, Pa., 19139 (215) 476.4040 FAX (215) 476-4667 Contact Herb Brunson County: Philadelphia only URBAN LEAGUE OF PITTSBURGH, INC. One Smithfield Street Pittsburgh, Pa., 15222-2222 (412) 261-1130 FAX: (412) 261-5207 Contact Lee Fuqua County: Allegheny only WARREN-FORREST COUNTIES ECONOMIC OPPORTUNITY COUNCIL 1209 Pennsylvania Avenue West, P.O. Box 547 Warren, Pa., 16365 (814) 726-2400 FAX: (814) 723-0510 Contact Doris Swan Counties: Forrest and Warren YWCA OF CARLISLE 301 G Street Carlisle, Pa., 17013 (717) 243-3818 FAX. (717) 243-3948 Contact Pamela Line Counties: Cumberland, Franklin and Perry txf RICHARD F. STERN, ESQUIRE STEVEN K. EISENBERG, ESQUIRE t/KEVIN P. DI3ICIN, ESQUIRE STERN AND EISENBERG LLP THE PAVILION 261 OLD YORK ROAD, SUITE 410 JENIC]NTOWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAIN'T'IFF) ~-~„~- r..,, ,.. ,1 ~•~r. (~^^ ~+a i.! a a,J'1 v ~ 1a4J ~l~ 1,1 t~ ~ ..~ .. ...`i ~ I `- ~~, gym' ~t f, ~ ~~ e1,j 1 C _..,~._ .~ 's IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY DEUTSCHE BANK NATIONAL TRUST COMPANY, AS Trustee for the registered holders of MORGAN STANLEY ABS CAPITAL I INC. TRUST 2007-HES MORTGAGE PASS-THROUGH CERTIFICATES,SERIES 2007-HES, by its attorney in fact, Ocwen Loan Servicing, LLC v. Joseph J. Lego and Christina L. Lego Defendant(s) Civil Action Number: 2010-5358 MORTGAGE FORECLOSURE PRAECIPE FOR ENTRY OF JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Enter judgment in favor of Plaintiff and against Defendant(s), Joseph J. Lego and Christina L. Lego, for failure of said Defendant(s) to file a responsive pleading to the Complaint within twenty (20) days of service thereof. PRINCIPAL BALANCE ..........................................::..........$115,042.40 INTEREST accrued thru 08/11/2010 of ...............................$4,232.00 Interest after 08/11/2010 shall accrue at the per diem rate of $22.19.) LATE CHARGES accrued thru 08/11/2010 of .....................$659.27 Late charges after 08/11/2010 shall accrue at the monthly ~~~,oo PD gym! rate of $39.57.) C#a0Ay0 ~,'~ aft iii J:\Supriya\Sales\Cumberland\Ocwen.Lego.09.10.doc ~~,~ ~~ ESCROW ADVANCES ........:...............................................$698.75 FEES BILLED .......................................................................$1,409.07 LEGAL COSTS .....................................................................300.00 ATTORNEY'S FEE ..............................................................$6,000.00 LESS SUSPENSE (If any) .....................................................($883.37) Sub-Total Through Date of Complaint ............................$127,458.12 ACCRUED INTEREST after 08/11/2010 shall accrue at the per diem rate of $22.19 to September 28, 2010 ....................................$1,065.12 ACCRUED LATE CHARGES Late charges after 08/11/2010 accruing at the monthly rate of $39.57 through September 28, 2010 ......................................$79.14 TOTAL DUE THROUGH DATE OF REQUEST FOR JUDGMENT .................................................................$128,602.38 STERN AND EISENBERG LLP BY: Date: September 28, 2010 HARD F. TERN, ESQUIRE STEVEN K. EISENBERG, ESQUIRE KEVIN P. DISKIN, ESQUIRE Attorney for Plaintiff J:\Supriya\Sales\Cumberland\Ocwen. Lego.09.10. doc RICHARD F. STERN, ESQUIRE STEVEN K. EISENBERG, ESQUIRE KEVIN P. DISKIN, ESQUIRE STERN AND EISENBERG LLP THE PAVILION 261 OLD YORK ROAD, SUITE 410 JENKINTOWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSIMII,E: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY DEUTSCHE BANK NATIONAL TRUST COMPANY, AS Trustee for the registered holders of MORGAN STANLEY ABS CAPITAL I INC. TRUST 2007-HES MORTGAGE PASS-THROUGH CERTIFICATES,SERIES 2007-HES, by its attorney in fact, Ocwen Loan Servicing, LLC v. Joseph J. Lego and Christina L. Lego Civil Action: 2010-5358 MORTGAGE FORECLOSURE AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF MONTGOMERY I, the undersigned, being duly sworn according to law, deposes and says, to the best of his knowledge, information and belief, Defendants' 1. Last-known address is 3 Edgewood Drive, Mechanicsburg, PA 17055 2. Is over the age of twenty-one. 3. Is not now nor has been within the last six (6) months in the Armed Services of the United States as defined in the Soldiers' Civil Relief Act of 1940, as amended. COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL HELEN CAPASSO, Notary Public Jenkintown f3oro., Montgomery County My Commission Expires October 21, 2012 Sworn to and subscrib be ore me this Day of -- c~' 2010. ~J Notary Public ST BERG LLP BY• ~ + EN K. EISENBERG RICHARD F. STERN KEVIN P. DISKIN Attorney for Plaintiff J:\Supriya\Sales\Cumberland\Ocwen.Lego.09.10. doc RICHARD F. STERN, ESQUIRE STEVEN K. EISENBERG, ESQUIItE KEVIN P. DISKIN, ESQUIRE STERN AND EISENBERG LLP THE PAVILION 261 OLD YORK ROAD, SurrE 410 JENKINTOWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY DEUTSCHE BANK NATIONAL TRUST COMPANY, AS Trustee for the registered holders of MORGAN STANLEY ABS CAPITAL I 1NC. TRUST 2007-HES MORTGAGE PASS-THROUGH CERTIFICATES,SERIES 2007-HES, by its attorney in fact, Ocwen Loan Servicing, LLC v. Joseph J. Lego and Christina L. Lego Defendant(s) Civil Action: 2010-5358 MORTGAGE FORECLOSURE CERTIFICATION UNDER RULE 237.1 I, the undersigned attorney on the writ and attorney for Plaintiff, hereby certify that a ten- day notice of intention to enter judgment by default was sent to Defendants in accordance with Pa. R.C.P. No. 237.1., a true and correct copy of which is attached hereto. STERN AND EISENBERG LLP TE ~. EISENBERG RICHARD F. STERN KEVIN P. DISKIN Attorney for Plaintiff J:\Supriya\Sales\Cumberl andl0cwen. Lego.09.10. doc • STERN AND ELSENBERG LLP THE PAVILION 261 OLD YORK ROAD, SUITE 410 JENKINTOWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND COUNTY DEUTSCHE BANK NATIONAL TRUST COMPANY, AS Trustee for the registered holders of MORGAN STANLEY ABS CAPITAL I INC. TRUST 2007-HES MORTGAGE PASS-THROUGH CERTIFICATES,SERIES 2007-HES, by its attorney in fact, Ocwen Loan Servicing, LLC (Plaintiff) v. Joseph J. Lego and Christina L. Lego Docket #: 2010-5358 TEN DAY NOTICE NOTICE PURSUANT TO Pa.R.C.P. 237.1 TO: Joseph L. Lego 3 Edgewood Drive Mechanicsburg, PA 17055 Date of Notice: Tuesday, September 7, 2010 Christina L. Lego 3 Edgewood Drive Mechanicsburg, PA 17055 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE 1N WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10} DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IIvIPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE IF YOU DO NOT HAVE A LAWYE 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 32 South Bedford Street Cazlisle, PA 17013 800-990-9108 717-249-3166 STERN & EISENBERG, LLP By: ---------- Kevin P. Diskin, Esquire Attorney for Plaintiff J:\Aagela\Ten Day\Ocwen.Lego.9.l0.doc RICHARD F. STERN, ESQUIRE STEVEN K. EISENBERG, ESQUIRE KEVIN P. DISKIN, ESQUIRE STERN AND EISENBERG LLP THE PAVILION 261 OLD YORK ROAD, SurrE 410 JENKINTOWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAIN'T'IFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY DEUTSCHE BANK NATIONAL TRUST COMPANY, AS Trustee for the registered holders of MORGAN STANLEY ABS CAPITAL I INC. TRUST 2007-HES MORTGAGE PASS-THROUGH CERTIFICATES,SERIES 2007-HES, by its attorney in fact, Ocwen Loan Servicing, LLC v. Joseph J. Lego and Christina L. Lego Defendant(s) Civil Action: 2010-5358 MORTGAGE FORECLOSURE CERTIFICATE UNDER ACT 91 OF 1983 It is hereby certified that the Sheriffs Sale scheduled in the above-captioned matter is not protected under the Homeowner's Emergency Assistance And Mortgage Foreclosure Act, P.L. 1688, No. 621 because notice, as required, was sent to Defendants and no timely response was made. STERN AND EISENBERG LLP B _ STEVEN K. EISENBERG RICHARD F. STERN KEVIN P. DISKIN Attorney for Plaintiff J:\SupriyalSales\Cumberland\Ocwen.I.ego.09.10. doc RICHARD F. STERN, ESQUIRE STEVEN K. EISENBERG, ESQUIRE KEVIN P. DI$KIN, ESQUIItE STERN AND EISENBERG LLP THE PAVILION 261 OLD YORK ROAD, SurrE 410 JENKINTOWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY DEUTSCHE BANK NATIONAL TRUST COMPANY, AS Trustee for the registered holders of MORGAN STANLEY ABS CAPITAL I INC. TRUST 2007-HES MORTGAGE PASS-THROUGH CERTIFICATES,SERIES 2007-HES, by its attorney in fact, Ocwen Loan Servicing, LLC v. Joseph J. Lego and Christina L. Lego Attorney for Plaintiff CERTIFICATION OF ADDRESS It is hereby certified that the last known addresses of the parties are as follows: DEUTSCHE BANK NATIONAL TRUST COMPANY 1661 Worthington Road, Suite 100 West Palm Beach, FL 33409 (Plaintiff) Joseph J. Lego and Christina L. Lego 3 Edgewood Drive Mechanicsburg, PA 17055 (Defendant(s)) Civil Action: 2010-5358 MORTGAGE FORECLOSURE STERN AND EISENBERG LLP -~ STEVEN K. EISENBERG RICHARD F. STERN KEVIN P. DISKIN J:\Supriya\Sales\Cumberland\Ocwen.Lego.09.10. doc iN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C[VIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: ( )Confessed Judgment DEUTSCHE BANK NATIONAL TRUST COMPANY, AS Trustee for the registered holders of MORGAN STANLEY ABS CAPITAL I INC. TRUST 2007-HES MORTGAGE PASS-THROUGH CERTIFICATES,SERIES 2007-HES, by its attorney in fact, Ocwen Loan Servicing, LLC v. Joseph J. Lego and Christina L. Lego TO THE PROTHONOTARY OF THE SAID COURT: ~xx) Other File No. 2010-5358 Amount Due $128, 602.38 Interest from 9/29/2010 at the per diem rate of $22.19 until judgment is paid in full. Atty's Comm COStS The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland ~~ ~ ~.. bounty, for debt, interest and costs, upon the following described property of the defendant(s) _ E ; --~ ..~ 3 Edeewood Drive MPrhanj,ogburs, gA 17055 _ °~ 3 <:t :- .~.~ , , "1::.~i_~.~ -, -_ a3 ~, p .~._ ... .. -. PRAECIPE FOR ATTACHMENT EXECUTION ~~ _._ j~ ...~ c.r; ,::.a Issue writ of attachment to the Sheriff of County, for debt, inter st and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). defendant(s) described in the attached exhibit. ~te 9/28/2010 Signature: Print Name: K in P. Diskin Es uire # ~'`'~'~ Pq Am/ 261 Old York Road ~'bO CBS Address: Tt,P Paul ~ ion, Suite-110 4d. o o ~~ PA 19046 ,, Jenkintown, I'~.oo a.so ~~ . ` ~'~ ~ _ Pp A,rt,V Attorney for: Plaintiff Telephone: (215)572-8111 ~;~ ~~e~ Supreme Court ID No.: 86727 ~# ao940 ~E Wrti~, ~~~ (over) (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the ALL THAT CERTAIN lot of land situate in Mechanicsburg Boro, Cumberland County, Pennsylvania, more described as follows, to wit: BEGINNING at a point on the Southwesterly Line of Edgewood Drive, which point is at the line of dividing Lots 4 and 3, Block K on the hereinafter mentioned Plan of lots; thence South 77 degrees 27 minutes West 177.41 feet to point at lands now or formerly of Samuel Engle; thence North 03 degrees 20 minutes East 86.49 feet to the dividing line of Lots nos. 4 and 5 on the aforesaid Plan; thence North along same 83 degrees 57 minutes 20 seconds East 155.90 feet to a point on the Southwesterly line of Edgewood Drive; thence by an arc curving to the left, having a radius of 180 feet an arc distance of 20.44 feet to a point; thence South 12 degrees 33 minutes East 45.13 feet to the point and place of BEGINNING. UNDER AND SUBJECT to a 25 feet building set-back line. HAVING THEREON ERECTED a dwelling numbered 3 Edgewood Drive. BEING Lot No. 4, Block K as laid out on the Final Plan of Block K and part of Blocks H, B and D of Wynnewood Park and recorded in the Cumberland County Recorder's Office in Plan Book 26, Page 66. BEING the same premises which Joseph J. Lego and David A. Lego, Co-Administrators for the Estate of Philip S. Lego and the Estate of Nancy A. Lego, deceased, by deed dated December 12, 2006 and recorded on December 20, 2006, in Book 278 at page 299, of the Cumberland County, PA records, granted and conveyed unto, Joseph J. Lego and Christina L. Lego, husband and wife. RICHARD F. STERN, ESQUIItE STEVEN K. EISENBERG, ESQUIItE KEVIN P. DISKIN, ESQUIRE STERN AND EISENBERG LLP THE PAVILION 261 OLD YORK ROAD, SUITE 410 JENKIN'1'OWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSIMI[.E: (215) 572-5025 (COUNSEL FOR PLAINTIFF) ~' ~ ~ ~ F .f 4 a` ..~ t~a~U~l l~ t 1~ ,~i~{~ ', IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY DEUTSCHE BANK NATIONAL TRUST COMPANY, AS Trustee for the registered holders of MORGAN STANLEY ABS CAPITAL I INC. TRUST 2007-HES MORTGAGE PASS-THROUGH CERTIFICATES,SERIES 2007-HES, by its attorney in fact, Ocwen Loan Servicing, LLC v. Joseph J. Lego and Christina L. Lego Defendant(s) Civil Action: 2010-5358 MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 I, the undersigned attorney for Plaintiff in the above caption, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 3 Edgewood Drive, Mechanicsburg, PA. 1. Name and address of Owner(s) or Reputed Owner(s): Joseph J. Lego and Christina L. Lego 3 Edgewood Drive Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Joseph J. Lego and Christina L. Lego 3 Edgewood Drive Mechanicsburg, PA 17055 J:\Supriya\Sales\Cumberland\Ocwen. Lego.09.10. doc 5. Name and address of every other person who has any record lien on the property: N/A 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: PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128 West Shore TV Cable Co. C/o Prentice Hall Corporation System Inc. 100 Pine Street Harrisburg, PA 17108 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: Domestic Relations Cumberland County 13 North Hanover Street Carlisle, PA 17013 Occupant 3 Edgewood Drive Mechanicsburg, PA 17055 Tax Claim Bureau Cumberland County Courthouse One Courthouse Street Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: September 28, 2010 BY: Sworn to and subsc ' ed fore me this a of , 2010. Notary Public STERN AND EISENBERG LLP F~ E~3'K. EISENBERG RICHARD F. STERN KEVIN P. DISKIN Attorney for Plaintiff COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL HELEN CAPASSO, Notary Pu`~lic Jenkintown Boro., Montgomery County My Commission Expires October 21, 2012 J:\Supriya\Sales\Cumberland\Ocwen.L.ego.09. l0.doc RICHARD F. STERN, ESQUIRE STEVEN K. EISENBERG, ESQUIRE KEVIN P. DISKIN, ESQUIRE STERN AND ETSENBERG LLP THE PAVILION 261 OLD YORK ROAD, SUITE 410 JENKINTOWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY DEUTSCHE BANK NATIONAL TRUST COMPANY, AS Trustee for the registered holders of MORGAN STANLEY ABS CAPITAL I INC. TRUST 2007-HES MORTGAGE PASS-THROUGH CERTIFICATES,SERIES 2007-HES, by its attorney in fact, Ocwen Loan Servicing, LLC v. Joseph J. Lego and Christina L. Lego Civil Action: 2010-5358 MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Joseph J. Lego and Christina L. Lego 3 Edgewood Drive Mechanicsburg, PA 17055 Your real estate at 3 Edgewood Drive, Mechanicsburg, PA is scheduled to be sold at Sheriffs Sale on Wednesday, March 2, 2011 at 10:00 A.M., at Sheriffs Office, Cumberland County Courthouse, Carlisle, PA 17013 (location of sale) to enforce the court judgment of $128,602.38 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to Stern and Eisenberg, LLP the back payments, late chazges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call Stern and Eisenberg LLP, telephone (215) 572-8111. 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.) J:4Supriya\Sales\Cumberlandl0cwen.Lego.09.10. doc 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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Stern and Eisenberg LLP, telephone (215) 572-8111. 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 Stern and Eisenberg LLP, telephone (215) 572-8111. 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 a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a shaze 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 on a date specified by the Sheriff no later than 30 days after the sale date. 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) aze filed with the Sheriff within ten (10) days after the date of filing of said schedule. You should check with the Sheriffs Office by calling (717) 240-6390 to determine the actual date of filing of said schedule. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Cazlisle, PA 17013 800-990-9108 717-249-3166 J:lsupriya\Sales\Cumberland\Ocwen.I.ego.09. l0.doc RICHARD F. STERN, ESQUIltE STEVEN K. EISENBERG, ESQUIRE KEVIN P. DLSKIN, ESQUIRE STERN AND EISENBERG LLP THE PAVILION 261 OLD YORK ROAD, SUITE 410 JENKINTOWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSrn-m.E: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY DEUTSCHE BANK NATIONAL TRUST COMPANY, AS Trustee for the registered holders of MORGAN STANLEY ABS CAPITAL I INC. TRUST 2007-HES MORTGAGE PASS-THROUGH CERTIFICATES,SERIES 2007-HES, by its attorney in fact, Ocwen Loan Servicing, LLC v. Joseph J. Lego and Christina L. Lego Civil Action: 2010-5358 MORTGAGE FORECLOSURE RE: PREMISES: 3 Edgewood Drive, Mechanicsburg, PA Dear Sir or Madam: Please be advised that I represent the above creditor that has a judgment against the above Defendant. As a result of a default, the above referenced premises, also described on the attached sheet, will be sold by the Sheriff of Cumberland County on Wednesday, March 2, 2011 at 10:00 A.M. at Sheriffs Office, Cumberland County Courthouse, Carlisle, PA 17013 (subject to change without further notice). The sale is being conducted pursuant to the judgment in the amount of $128,602.38 together with interest, costs (and such other allowed amounts) thereon entered in the above matter in favor of Plaintiff against the above-named Defendant(s) who is/are also the real owner of said premises. I have discovered that you may have a lien and/or interest in the premises to be sold. This notice is given so that you can protect your interest, if any, in the lien you have on the premises. If you have any questions regarding the type of lien or the effect of the Sheriff s Sale upon your lien, we urge you to CONTACT YOUR ATTORNEY, as we are not permitted to give you legal advice. A Schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after the sale date and the distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days thereafter. September 28, 2010 STERN AND EISENBERG LLP BY: VEN K. EISENBERG CHARD F. STERN KEVIN P. DISKIN Attorney for Plaintiff J:\Supriya\Sales\Cumberlandl0cwen.Lego.09.10. doc ALL THAT CERTAIN lot of land situate in Mechanicsburg Boro, Cumberland County, Pennsylvania, more described as follows, to wit: BEGINNING at a point on the Southwesterly Line of Edgewood Drive, which point is at the line of dividing Lots 4 and 3, Block K on the hereinafter mentioned Plan of lots; thence South 77 degrees 27 minutes West 177.41 feet to point at lands now or formerly of Samuel Engle; thence North 03 degrees 20 minutes East 86.49 feet to the dividing line of Lots nos. 4 and 5 on the aforesaid Plan; thence North along same 83 degrees 57 minutes 20 seconds East 155.90 feet to a point on the Southwesterly line of Edgewood Drive; thence by an arc curving to the left, having a radius of 180 feet an arc distance of 20.44 feet to a point; thence South 12 degrees 33 minutes East 45.13 feet to the point and place of BEGINNING. UNDER AND SUBJECT to a 25 feet building set-back line. HAVING THEREON ERECTED a dwelling numbered 3 Edgewood Drive. BEING Lot No. 4, Block K as laid out on the Final Plan of Block K and part of Blocks H, B and D of Wynnewood Park and recorded in the Cumberland County Recorder's Office in Plan Book 26, Page 66. BEING the same premises which Joseph J. Lego and David A. Lego, Co-Administrators for the Estate of Philip S. Lego and the Estate of Nancy A. Lego, deceased, by deed dated December 12, 2006 and recorded on December 20, 2006, in Book 278 at page 299, of the Cumberland County, PA records, granted and conveyed unto, Joseph J. Lego and Christina L. Lego, husband and wife. ~" ~ ~'^ n ~ .... ~ i`t RICHARD F. STERN, ESQUIItE ~- ~ , .-; { ~ ! STEVEN K. EISENBERG, ESQUIItE ` ~ ` ` i j ~ u ~t~, C i I'~ + KEVIN P. DI$KIN, ESQUIRE n ~, , f, „., ~. ,. STERN AND EISENBERG LLP , ~"' ' u `~` ' ' _ ~~ ~, _~_ ; I : i j THE PAVILION n " ~ 261 OLD YORK ROAD, SUITE 410 ~ '~~, f~' 1 ', ;~ } ~t ~ ; . ri , JENKINTOWN, PENNSYLVANIA 19046 , ~ , ~ 9 ' .~ ~ ~ ~- ~ <~ ~ ~ }' t'-~ TELEPHONE: (21S) 572-8111 FACSIMILE: (21S) S72-S02S (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY DEUTSCHE BANK NATIONAL TRUST COMPANY, AS Trustee for the registered holders of MORGAN STANLEY ABS CAPITAL I INC. TRUST 2007-HES MORTGAGE PASS-THROUGH CERTIFICATES,SERIES 2007-HES, by its attorney in fact, Ocwen Loan Servicing, LLC v. Joseph J. Lego and Christina L. Lego Civil Action: 2010-5358 MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Joseph J. Lego and Christina L. Lego 3 Edgewood Drive Mechanicsburg, PA 17055 Your real estate at 3 Edgewood Drive, Mechanicsburg, PA is scheduled to be sold at Sheriffs Sale on Wednesday, March 2, 2011 at 10:00 A.M., at Sheriffs Office, Cumberland County Courthouse, Carlisle, PA 17013 (location of sale) to enforce the court judgment of $128,602.38 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to Stern and Eisenberg, LLP the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call Stern and Eisenberg LLP, telephone (21 S) 572-8111. 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.) J:\Supriya\Sales\Cumberland\Ocwen. Lego.09.10. doc 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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Stern and Eisenberg LLP, telephone (215) 572-811 1. 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 Stem and Eisenberg LLP, telephone (215) 572-8111. 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 a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 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 on a date specified by the Sheriff no later than 30 days after the sale date. 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 the date of filing of said schedule. You should check with the Sheriffs Office by calling (717) 240-6390 to determine the actual date of filing of said schedule. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 800-990-9108 717-249-3166 J:\Supriya\Sales\Cumbedand\Ocwen.Lego.09. l0.doc ALL THAT CERTAIN lot of land situate in Mechanicsburg Boro, Cumberland County, Pennsylvania, more described as follows, to wit: BEGINNING at a point on the Southwesterly Line of Edgewood Drive, which point is at the line of dividing Lots 4 and 3, Block K on the hereinafter mentioned Plan of lots; thence South 77 degrees 27 minutes West 177.41 feet to point at lands now or formerly of Samuel Engle; thence North 03 degrees 20 minutes East 86.49 feet to the dividing line of Lots nos. 4 and 5 on the aforesaid Plan; thence North along same 83 degrees 57 minutes 20 seconds East 155.90 feet to a point on the Southwesterly line of Edgewood Drive; thence by an arc curving to the left, having a radius of 180 feet an arc distance of 20.44 feet to a point; thence South 12 degrees 33 minutes East 45.13 feet to the point and place of BEGINNING. UNDER AND SUBJECT to a 25 feet building set-back line. HAVING THEREON ERECTED a dwelling numbered 3 Edgewood Drive. BEING Lot No. 4, Block K as laid out on the Final Plan of Block K and part of Blocks H, B and D of Wynnewood Park and recorded in the Cumberland County Recorder's Office in Plan Book 26, Page 66. BEING the same premises which Joseph J. Lego and David A. Lego, Co-Administrators for the Estate of Philip S. Lego and the Estate of Nancy A. Lego, deceased, by deed dated December 12, 2006 and recorded on December 20, 2006, in Book 278 at page 299, of the Cumberland County, PA records, granted and conveyed unto, Joseph J. Lego and Christina L. Lego, husband and wife. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-5358 Civil 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 holders of MORGAN STANLEY ABS CAPITAL I INC TRUST 2007- HES MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-HES, by its attorney in fact, Ocwen Loan Servicing, LLC, Plaintiff (s) From JOSEPH J. LEGO and CHRISTINA L. LEGO (1) You are directed to lery upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $128,602.38 L.L.$.50 Interest from 9/29/10 at the per diem rate of $22.19 until judgment is paid in full Atty's Comm Atty Paid $185.50 Plaintiff Paid Date: 10/5/10 (Seal) '~ REQUESTING PARTY: Due Prothy $2.00 Other Costs ic~l ~. ~~e11 David D uell, Prothon ~ By: Deputy Name: KEVIN` P.:DISKIN, ESQUIRE Address: STERN AND EISENBERG, LLP THE PAVILION 261 OLD YORK ROAD, SUITE 410 JENKINTOWN, PA 19046 Attorney for: PLAINTIFF Telephone : 215-572-8111 Supreme Court ID No. 86727 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW KEVIN P. DISKIN, ESQUIRE STERN AND EISENBERG LLP The Pavilion 261 Old York Road, Suite 410 Jenkintown, PA 19046 (215) 572-8111 I.D. #86727 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS Trustee for the registered holders of MORGAN STANLEY ABS CAPITAL I INC. TRUST 2007-HE5 MORTGAGE PASS-THROUGH CERTIFICATES,SERIES 2007-HE5, by its attorney in fact, Ocwen Loan Servicing, LLC V. Joseph J. Lego and Christina L. Lego c? C o Q Ul CO Q - O E7 -n "> c - z n ::-C) ' C)m - : D =-+ Ln ;:0 Civil Action Number: 2010-5358 MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I, KEVIN P. DISKIN, ESQ., attorney for the within Plaintiff, hereby certify that notice of the Sheriff's Sale was mailed to the Defendants by certified mail, return receipt requested on December 30, 2010. I further certify that notice of the Sheriff's Sale was mailed to each lienholder by regular, first-class, postage prepaid mail on December 30, 2010, as evidenced by copy of certificates of mailing attached. STERN AND EISENBERG LLP BY: VIN P. 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F C v dz C/I w T o? N M 7 V'1 lQ [? 00 O\ v F_ ? f7 U 5 U PITNEY BOWES $ 002.10° 782 DEC 30 2010 ROM ZIP CODE 19046 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW KEVIN P. DISKIN, ESQUIRE STERN AND EISENBERG 410 The Pavilion, 261 Old York Road Jenkintown, PA 19046 (215) 572-8111 I.D. #86727 Deutsche Bank National Trust Company, As Trustee, By its attorney in fact, Ocwen Loan Servicing, LLC VS. JOSEPH J. LEGO AND CHRISTINA L. LEGO r-J C) = rn M rnr- Z ca --a . Ln m ::0 Cn G? -- z3 t.t. . ? NO. 2010-5358 CIVIL TERM MOTION FOR SPECIAL ORDER DIRECTING SERVICE BY POSTING AND CERTIFIED MAIL PURSUANT TO PA. R.C.P. 430(a) TO DEFENDANT CHRISTINA L. LEGO 1. Plaintiff is Deutsche Bank National Trust Company, as Trustee, et. al. the holder of a Note executed by defendants, securing a mortgage on real estate located at 3 Edgewood Drive, Mechanicsburg, PA 17055. 2. On or about August 16, 2010, Plaintiff filed a Civil Action-Mortgage Foreclosure against defendants as a result of defendants' failure to pay the required monthly mortgage payments. 3. Service of Plaintiff's Civil Action was effected at the mortgaged property by the Sheriff of Cumberland County on August 17, 2010. 4. In due course, Plaintiff entered judgment and listed defendants' real estate located at 3 Edgewood Drive, Mechanicsburg, PA 17055, for sale by the Sheriff of Cumberland County for March 2, 2011. 5. Unfortunately, the Sheriff could not effect service of Plaintiff s Notice of Sale on the defendant Christina L. Lego. 6. The whereabouts of defendant, Christina L. Lego whose last-known address according Plaintiffs records is 3 Edgewood Drive, Mechanicsburg, PA are unknown, and accordingly, all attempts to serve said defendant pursuant to the usual process prescribed by Pa. R.C.P. 400-405 have been futile. 7. Pursuant to Pa. R.C.P. 430(a), an investigation has been made to determine the whereabouts of the defendants and the reasons why service cannot be made. Attached hereto and made part hereof as Exhibit "A" is an Affidavit stating the nature and extent of that investigation. 8. Pursuant to Pa. R.C.P. 430(a) and Pa. R.C.P. 410(c)(2) and (3), this Court may enter a special Order directing that service be made by posting a copy of its original process, and all further notices requiring personal service, including Notice of Sheriff' s Sale, if any, in the above-captioned matter, on the most public part of the property or by certified mail to the defendant's last-known address. WHEREFORE, Plaintiff, Deutsche Bank National Trust Company, moves this Honorable Court to enter a special Order directing that service be made by posting a copy of Plaintiff' s Notice of Sale on premises 3 Edgewood Drive, Mechanicsburg, PA 17044 and by sending a copy of the same to defendant Christina L. Lego at her last-known address of 3 Edgewood Drive, Mechanicsburg, PA 17044, by certified mail, return receipt requested and regular mail. Respectfully submitted, STERN AND EISENBERG B PVIN P. DISKIN, Attorney for Plaintiff J:\ANGELA\POSTING\CUMBERLAND\OCWEN.LEGO.2.1 LDOC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW KEVIN P. DISKIN, ESQUIRE STERN AND EISENBERG 410 The Pavilion, 261 Old York Road Jenkintown, PA 19046 (215) 572-8111 I.D. #86727 Deutsche Bank National Trust Company, As Trustee, By its attorney in fact, Ocwen Loan Servicing, LLC VS. : NO. 2010-5358 CIVIL TERM JOSEPH J. LEGO AND CHRISTINA L. LEGO AFFIDAVIT OF INVESTIGATION I, KEVIN P. DISKIN, being duly sworn according to law, depose and say that I am counsel for Plaintiff, Deutsche Bank National Trust Company in the foregoing action and that the following efforts were made by my office to serve the defendants with Plaintiff s Notice of Sale and to determine the present whereabouts of said defendant Christina L. Lego: 1. Service of Plaintiff's original process was effected at the mortgaged property address by the Sheriff of Cumberland County on August 17, 2010. See Exhibit "B" which is attached hereto and made a part hereof. 2. Plaintiff then attempted service its Notice of Sale in the same manner. Unfortunately, service could not be made because, as noted on the Sheriff's Return of Service, which is attached hereto and made a part hereof as Exhibit "C", the defendant, Christina L. Lego has moved and left no forwarding address. 3. Plaintiff sent an inquiry to the Department of Motor Vehicles in order to obtain information concerning the defendant and defendant Christina L. Lego is registered at 3 Edgewood Drive, Mechanicsburg, PA 17055. See Exhibit "D" which is attached hereto and made a part hereof. 4. Moreover, Cumberland County Sheriff's Office did an inquiry to the Post Office and according to the records it maintains, the defendant did not leave a forwarding address with the Post Office. See collective Exhibit "E" which is attached hereto and made a part hereof. 5. Plaintiff also sent an inquiry to the Department of Voter Registration in Cumberland County and according to the records it maintains, the defendant, Christina L. Lego is registered at the mortgaged property address, 3 Edgewood Drive, Mechanicsburg, PA 17055. See collective Exhibit "F" which is attached hereto and made a part hereof. 6. In addition to the standard searches conducted above, Plaintiff's Counsel has also conducted an accurint search in order to determine additional information as to the whereabouts of the Defendant and Defendant Christina L. Lego is registered at 3 Edgewood Drive, Mechanicsburg, PA 17055. See Exhibits "G" which is attached hereto and made a part hereof. The information provided has enabled Counsel to conduct additional investigation including those contemplated pursuant to Pa.RCP 430. Notwithstanding, those additional inquiries and calls have lead to no information that would indicate that the Defendant Christina L. Lego is at any other address. Based on the additional investigation, Counsel believes that Defendant is simply evading service. This information is true and correct to the best of my knowledge, information and belief. 'COMMONWEALTH OF PENNSYLVANIA sow AnPW Mme,, t4oWy PubUo Corr r, Sworn to and sub$?ribed before me this /0 day of Phraa , 011. STERN AND EISENBERG BY: KEVIN P. DISKIN, Attorney for Plaintiff J:\ANGELA\POSTING\CUMBERLAND\OCWEN.LEGO.2.1 LDOC SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Deutsche Bank National Trust Company vs. Joseph Jin Lego (et al.) SHERIFF'S RETURN OF SERVICE Case Number 2010-5358 08/17/2010 08:48 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 17, 2010 at 2048 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Joseph Jin Lego, by making known unto himself personally, at 3 Edgewood Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of the same. t NOAH CLINE, DEPUTY 08/17/2010 08:48 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 17, . 2010 at 2048 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Christina L. Lego, by making known unto Joseph Jin Lego, Husband of defendant at 3 Edgewood Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of the same.. NOAH CLINE, DEPUTY SHERIFF COST: $53.00 August 18, 2010 at Cumblt4 OFr C E Or TI-c RIFF SO ANSWERS, RON R ANDERSON, SHERIFF SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Deutsche Bank National Trust Company vs. Joseph Jin Lego (et al.) SHERIFF'S RETURN OF SERVICE Case Number 2010-5358 01/03/2011 07:07 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Joseph Jin Lego at 3 Edgewood Drive, Mechanicsburg Borough, Mechanicsburg, PA 17055, Cumberland County. 01/04/2011 Deputy Robert Bitner, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 3 Edgewood Drive, Mechanicsburg, PA Cumberland County. 01/31/2011 07:15 PM - Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Christina L. Lego, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 3 Edgewood Drive, Mechanicsburg, PA 17055, defendant no longer resiides at this address, per ex-husband, husband provided alternate address of 200 North Frederick Street, Apt 4, Mechanicsburg, (Christina's Sisters Residence) however defendant is not residing there, did not leave a forwarding with the post office. SHERIFF COST: $908.94 February 02, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF PAGE 1 PENNSY3 NIA DEPARTMENT OF TRANSPO lTION BUREAU OF DRIVER LICENSING BASIC DRIVER INFORMATION AUG 24 2010 DRIVER: CHRISTINIA L LEGO DRIVER LICENSE NO : 24567745 3 EDGEWOOD DR DATE OF BIRTH : JUL 26 1974 MECHANICSBURG, PA 17055 SEX : FEMALE RECORD TYPE REG LIC/LP/ID DRIVER LICENSE (DL) LICENSE CLASS : C LICENSE ISSUE DATE: MAY 27 2010 LICENSE EXPIRES : JUL 27 2014 ORIG ISSUE DATE : AUG 04 1994 MED RESTRICTIONS : NONE LEARNER PERMITS LICENSE STATUS COMMERCIAL DRIVER LICENSE (CDL) CDL LICENSE CLASS . CDL LICENSE ISSUED : CDL LICENSE EXPIRES: CDL ENDORSEMENTS : NONE CDL RESTRICTIONS : NONE CDL LEARNER PERMITS: CDL LICENSE STATUS : SB ENDORSEMENT PROBATIONARY LICENSE (PL) PL LICENSE CLASS PL LICENSE ORIG ISS: PL LICENSE ISSUED . PL LICENSE EXPIRES : PL LICENSE STATUS . OCCUPATIONAL LIMITED LICENSE (OLL) OLL LICENSE CLASS . OLL LICENSE ISSUED : OLL LICENSE EXPIRES: OLL LICENSE STATUS : *** END OF RECORD *** SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff up?l'A14 a[ 4tlerlb?r?Tfr? Jody S Smith Chief Deputy s f - Richard W Stewart Solicitor n-`.rE Cr r-E "`RAF` Deutsche Bank National Trust Company Case Number vs. Joseph Jin Lego (et al.) 2010-5358 SHERIFF'S RETURN OF SERVICE 01/03/2011 07:07 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Joseph Jin Lego at 3 Edgewood Drive, Mechanicsburg Borough, Mechanicsburg, PA 17055, Cumberland County. 01/04/2011 Deputy Robert Bitner, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 3 Edgewood Drive, Mechanicsburg, PA Cumberland County. 01/31/2011 07:15 PM Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Christina L. Lego, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 3 Edgewood Drive, Mechanicsburg, PA 17055, defendant no longer resiides at this address, per ex-husband, husband provided alternate address of 200 North Frederick Street, Apt 4, Mechanicsburg, (Christina's Sisters Residence) however defendant is not residing there, did not leave a forwarding with the post office. SHERIFF COST: $908.94 February 02, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF F;LEGO. CHRIST NIA L Security: Not Restricted LastClianged 3/2512008 3:44:41 P t _ r ?"ral Vote"' General I >` nistrirhz Votes Corresnondence 't Petitions Q Chanoes? Documents Id Other ? --1 Annlir-ation I ID Number Application Source: Registered: Status-Reason: D01067330 2 DOTIA10/0712002 ' ACTIVE4,REGISTERED Title: Last Name: First Name: Middle Name: Suffix: Maiden Name: v- I LEGO CHRISTINIA L F_7-]F_ House W 112 Street Name: Unit: Unit #: Cit : State: Z Code: ? 3 - EDGEWOOD DR MECHANICSBURG PA -1117055 ? I Address Line 2: Mail Addr Line 1:- Mail Cit . State: Mail Zi Mail Countr : Email Address: BirthDate: Social Sec: DriVef S Lic-: Phone: U: r Sex: Race Lan ua e_ Assistance: 07126/1974 >M-}47963 24567745 717-766-6392 F 1 wjI Part : Other Last ---1 REPUBLICAN Must Vote r- Poll Worker ?I In Person Precinct Split: r Poll Worker Interest '• ? • Insert . 12.05=1 ? MECHANICS9UR ? Clear ?' '° -' F ' 1 :. 4 Y 7 yy;1 a' ?1 q "h pds Sf '+?5t.t Y ?. +Y/.S 3a- l .'s:. •.x > j 4ij'- ,: R`? _. ? ?y Lfr SY Mf ` T 4 OK Cancel r, 71 ?, I Record:.' 1 10 of . t Page 1 of 1 CHRISTINIA L LEGO Gender - Female 3 EDGEWOOD DR MECHANICSBURG, PA 17055-2784 SSN - 184-54-xxxx Age - 36 DOB - 07/26/1974 Dates - Feb 76 - Jan 11 Phone - 717-458-5266 - EST https:Hsecure.accurint.com/app/bps/main 2/9/2011 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW KEVIN P. DISKIN, ESQUIRE STERN AND EISENBERG 410 The Pavilion, 261 Old York Road C; Jenkintown, PA 19046 r, (215) 572-8111 -n I.D. #86727 '? = Deutsche Bank National Trust Company, v C-) As Trustee, By its attorney in fact, c) = -- CD Ocwen Loan Servicing, LLC VS. : NO. 2010-5358 JOSEPH J. LEGO AND CHRISTINA L. LEGO CERTIFICATE OF SERVICE I, KEVIN P. DISKIN, attorney for the within Plaintiff, hereby certify that a true and correct copy of Plaintiff s Motion for Alternative Service was mailed to the following by first class, postage prepaid mail on ID)11 Christina L. Lego 3 Edgewood Drive Mechanicsburg, PA 17055 STERN AND EISENBERG BY: N P. DISKIN, nev for Plaintiff DATE: -1::A J:\ANGELA\POSTING\CUMBERLAND\OCWEN.LEGO.2.1 LDOC IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION - LAW KEVIN P. DISKIN, ESQ. STERN & EISENBERG, LLC The Pavilion 261 Old York Road, Suite 410 Jenkintown, PA 19046 (215) 572-8111 I.D. #86727 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS Trustee for the registered holders of MORGAN STANLEY ABS CAPITAL I INC. TRUST 2007-HE5 MORTGAGE PASS-THROUGH CERTIFICATES,SERIES 2007-HE5, by its attorney in fact, Ocwen Loan Servicing, LLC V. Joseph J. Lego and Christina L. Lego Defendant(s) zW -? rn -v :3 > - ._ ?C) ` 7- rv `ter D Civil Action Number: 2010-5358 MORTGAGE FORECLOSURE PRAECIPE TO VACATE JUDGMENT WITHOUT PREJUDICE TO THE PROTHONOTARY: Subsequent to the entry of judgment, Plaintiff, DEUTSCHE BANK NATIONAL TRUST COMPANY, as trustee, directs the Prothonotary to vacate the judgment without prejudice to the continuing validity of the note and mortgage and without prejudice to Plaintiff's right to institute a separate proceeding on the note or mortgage against the Defendant as a result of any default. STERN AND EISENBERG 5/4/2011 ?;FSVTN P. DISIaN Attorney for Plaintiff Pd. #?.oa " 60 N(?sal 74 to ?9ay IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION - LAW r _ M KEVIN P. DISKIN, ESQ. zn te ? STERN & EISENBERG, LLC r - `-n The Pavilion 261 Old York Road, Suite 410 Jenkintown, PA 19046 -" { (215) 572-8111 I.D. #86727 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS Trustee for the registered holders of MORGAN STANLEY ABS CAPITAL I INC. TRUST 2007-HE5 MORTGAGE PASS-THROUGH CERTIFICATES,SERIES 2007-HE5, by its attorney in fact, Ocwen Loan Servicing, LLC V. Joseph J. Lego and Christina L. Lego Defendant(s) Civil Action Number: 2010-5358 MORTGAGE FORECLOSURE ORDER TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE To the Prothonotary: Kindly mark the above captioned matter as settled, discontinued and ended, without prejudice, upon payment of your costs only. STERN AND EISENBERG BY: ,KEVIN P. DISKIN Attorney for Plaintiff 5/4/2011