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Home My WebLink About10-5692 Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq,, Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 248785 FILED OFFICE ?p Y l ..?;)_2 P1i 1:13 COUNTY CUIV PENNSYLVANA ATTORNEY FOR PLAINTIFF US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR STRUCTURED ASSET SECURITIES COURT OF COMMON PLEAS CORPORATION TRUST 2006-WF2 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 Plaintiff V. HERBERT A. BROWN A/K/A H. ALROY BROWN 257 WHISKEY SPRINGS ROAD DILLSBURG, PA 17019-9012 CIVIL DIVISION TERM NO. 10 - SWQ Gvi l lem CUMBERLAND COUNTY Defendant File #: 248785 We hereby certify the within to be a true and correct copy of the original file "t record 001.00 p(BHTT / ??g989(ol e,# a? 14 7654 ., NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, 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 ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File 4: 248785 1. Plaintiff is US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR STRUCTURED ASSET SECURITIES CORPORATION TRUST 2006-WF2 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 2. The name(s) and last known address(es) of the Defendant(s) are: HERBERT A. BROWN A/K/A H. ALROY BROWN 257 WHISKEY SPRINGS ROAD DILLSBURG, PA 17019-9012 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 04/21/2006 HERBERT A. BROWN and BRENDA C. PAUL-BROWN made, executed and delivered a mortgage upon the premises hereinafter described to WELLS FARGO BANK, NA which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1949, Page 3282. By Assignment of Mortgage recorded 03/09/2009 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Instrument No. 200906611. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 02/01/2010 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 248785 do 6. The following amounts are due on the mortgage: Principal Balance $172,101.14 Interest $8,130.58 01/01/2010 through 08/18/2010 (Per Diem $35.36) Attorney's Fees $650.00 Late Charges through 08/18/2010 $125.02 Property Inspections/Property Preservations $15.00 Costs of Suit and Title Search $550.00 Escrow Deficit $1,050-go TOTAL $182,622.54 7 8. 9 Plaintiff is nat seeking a judgment of personal liability (or an in nersz onam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. Plaintiff hereby releases BRENDA C. PAUL-BROWN from liability for the debt secured by the mortgage. File #: 248785 410 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $182,622.54, together with interest from 08/18/2010 at the rate of $35.36 per diem to the date of judgment, and other costs, fees, and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN & SCHMIEG, LLP By: c , - a 9,-, ? Lawrence T. Phe an, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 U,Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Attorneys for Plaintiff File #: 248785 r LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in the Township of South Middleton, County of Cumberland, and Commonwealth of Pennsylvania, being more particularly bounded and described as follows, to wit: BEGINNING at a steel pin set due North a distance of 5.22 feet from the southernmost dedicated right- of-way line of Whiskey Spring Road (T-518) said pin also being located for reference purposes only due South a distance of 19.78 feet from a point in the centerline of Whiskey Spring Road; thence extending South 86 degrees 7 minutes 10 seconds East for a distance of 150.34 feet to a steel pin at Lot No. 2 on the hereinafter mentioned plan of subdivision; thence extending along Lot No. 2 the following two course3s and distances; due South, through a steel pin set 7.19 feet from the origin of this call, for a total distance of 292.08 feet to a steel pin; thence continuing along Lot No. 2 due West for a distance of 150.00 feet to a steel pin at Lot No. 3 on the hereinafter mentioned plan of subdivision; thence continuing along Lot No. 3 due North through a steel pin set on the southernmost right-of-way line Whiskey Spring Road a distance of 5.22 feet from the terminus of this call, for a total distance of 302.26 feet to a steel pin, said pin marking the place of BEGINNING. CONTAINING 1.023 acres to the property line at the road, and 43,364 square feet to the dedicated right- of-way line of Whiskey Spring :Road, and being designated as Lot No. 4 on the final plan of minor subdivision of Fitzgerald Acres prepared for Harmon-Graves Company by Rodney Lee Decker & Associates, dated June 16, 1987, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 55, Page 89. PROPERTY ADDRESS: 257 WHISKEY SPRINGS ROAD, DILLSBURG, PA 17019-9012 PARCEL # 40-14-0140-062 File #: 248785 w The undersigned attorney hereby states that I am the attorney for the Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of my knowledge, information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsifications to authorities. DATE: Attorney for Plaintif File #: 248785 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff a~i: 4 ti i ~ ,ti;' '~/,~~. - - '"`~i'~RY Jody S Smith Chief Deputy Richard W Stewart Solicitor PE`~tvSY~V^,-1NIA US Bank National Association vs. Herbert A. Brown Case Number 2010-5692 SHERIFF'S RETURN OF SERVICE 09/10/2010 05:40 PM -Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on September 10, 2010 at 1740 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Herbert A. Brown a/k/a Alroy Brown, by making known unto himself personally, at 257 Whiskey Springs Road, Dillsburg, Cumberland County, Pennsylvania 17019 its content;. and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $43.30 September 13, 2010 ,,T- DENNI RY, DEPU SO ANSWERS, °C~~' RON R ANDERSON, SHERIFF r~ F ~~ s~ l li~t~. i ~a ski ~r~n r„'. ~~ f'~~*'}~~~~V ~., ,may-i ~4 '`1a± t4 iii 1~'f~/t[U toJi~ ~ Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 ..-Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR STRUCTURED ASSET SECURITIES CORPORATION TRUST 2006-WF2 Plaintiff vs. HERBERT A. BROWN A/K/A H. ALROY BROWN Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO. 10-5692-CIVIL TERM CUMBERLAND COUNTY PRAECIPE TO SUBSTITUTE VERIFICATION TO CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE PHS #: 248785 TO THE PROTHONOTARY: Kindly substitute the attached verification for the verification originally filed with the complaint in the instant matter. Phelan Hallinan &Schmieg, LLP Attorney for Plaintiff ~~ By: ^ Lawrence T. P elan, Esq., Id. No. 32227 ^ Francis S. Hallinan, Esq., Id. No. 62695 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Pe ~ ulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua 1. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 Date: 9-17-10 PHS #: 248785 t VERIFICATION Vice President Loan Documentation China Brown ,hereby states that he/she is of, WELLS FARGO HOME MORTGAGE, INC., servicing agent for Plaintiff in this matter, that he/she is authorized to take this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. r Name: China Brown DATE: 9/7/10 File #: 248785 Name: BROWN Title: Vice President Loan Documentation Servicer: WELLS FARGO HOME MORTGAGE, INC. Phelan Hallinan &Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., ld. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Phi1~~.!r~lphia, PA 19103 215-JE~3-7000 US B ~~NK NATIONAL ASSOCIATION, AS TRUSTEE FOR STRUCTURED ASSET SECURITIES CORPORATION TRUST 2006-WF2 Plaintiff vs. HERBERT A. BROWN A/K/A H. ALROY BROWN Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO. 10-5692-CIVIL TERM CUMBERLAND COUNTY CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of Plaintiffs Praecipe to attach Verification of Complaint was sent via first class mail to the following on the date listed below: PHS #: 248785 HERBERT A. BROWN A/K/A H. ALROY BROWN 257 WHISKEY SPRINGS ROAD DILLSBURG, PA 17019-9012 Phelan Hallinan & Attorney for Plainti By: ~awrence T. Phelan, Esq., Id. No. 322?~7 ^ Francis S. Hallinan, Esq., Id. No. 62~C95 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. J ~ Esq., Id. No. 86657 ^ P r J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 Date: 9-17-10 PHS #: 248785 Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Attorney for Plaintiff Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 /Taime McGuinness, Esq., Id. No. 90134 ~-' ~ -°~ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ~~ _ ~' "~ ~ Joshua I. Goldman, Esq., Id. No. 205047 z ~ ~ '~'i~.- .. Courtenay R. Dunn, Esq., Id. No. 206779 ~ ~ -- `~ ~ ~ Andrew C. Bramblett, Esq., Id. No. 208375 ~`-~'-' ' °~; 1617 JFK Boulevard, Suite 1400 ~ c~- One Penn Center Plaza ~~ ~' ~ r~ Philadelphia, PA 19103 ~ ..... ~ ~ 215-563-7000 ~ `~' `' --c, US BANK NATIONAL ASSOCIATION, CUMBERLAND COUNTY AS TRUSTEE FOR STRUCTURED ASSET SECURITIES CORPORATION COURT OF COMMON PLEAS TRUST 2006-WF2 CIVIL DIVISION vs. No.10-5692-CIVIL TERM HERBERT A. BROWN A/K/A H. ALROY BROWN PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against HERBERT A. BROWN A/K/A H. ALROY BROWN, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff s damages as follows: ~I~.oc Po a~ Clt l u17(ot~(r R~ a49a~h ~o}~e ~A~.a-~. 248785 As set forth in Complaint $182,622.54 Interest - 08/19/2010 to 10/15/2010 $2,050.88 TOTAL $184,673.42 I hereby certify that (1) the Defendant's last known address is 257 WHISKEY SPRINGS ROAD, DILLSBURG, PA 17019-9012, and (2) that notice has been given in accordance with Rule 237.1, copy attached. ~I~f/ _I /'~ ^ Lawrence T. Phelan, Esq., Id. No. 32227 ^ Francis S. Hallinan, Esq., Id. No. 62695 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 Attorney for Plaintiff T)AMA('TF.R ARF. HF.RF.RY AC~F.C4F.T) A~ TNT)TC'ATFD DATE: /o ! o PHS # 248785 PROTHONOTARY 248785 Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Attorney for Plaintiff Philadelphia, PA 19103 215-563-7000 US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR STRUCTURED ASSET SECURITIES CORPORATION TRUST 2006-WF2 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION vs. HERBERT A. BROWN A/K/A H. ALROY BROWN No. 10-5692-CIVIL TERM VERIFICATION OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or it Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. 248785 (b) that defendant HERBERT A. BROWN A/K/A H. ALROY BROWN is over 18 years of age and resides at 257 WHISKEY SPRINGS ROAD, DILLSBURG, PA 17019- 9012. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: lO ~ ~ ~/~0 ~ ~~ ^ Lawrence T. Phelan, Esq., Id. No. 32227 ^ Francis S. Hallinan, Esq., Id. No. 62695 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq:, Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 Attorney for Plaintiff 248785 (Rule of Civil Procedure No. 236) -Revised US BANK NATIONAL ASSOCIATION, CUMBERLAND COUNTY AS TRUSTEE FOR STRUCTURED ASSET SECURITIES CORPORATION COURT OF COMMON PLEAS TRUST 2006-WF2 vs. HERBERT A. BROWN A/K/A H. ALROY BROWN CIVIL DIVISION No.10-5692-CIVIL TERM Notice is given that a Judgment in the above captioned matter has been entered against you on /o By: If you have any questions concerning this matter please contact: ^ Lawrence T. Phelan, Esq., Id. No. 32227 ^ Francis S. Hallinan, Esq., Id. No. 62695 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 drew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 Attorney or Party Filing 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza. Philadelphia, PA 19103 215-563-7000 * * THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANYINFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLYRECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BEAN ATTEMPT TO COLLECT A DEBT, BUT ONLYENFORCEMENT OFA LIENAGAINST PROPERTY. ** 248785 US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR STRUCTURED ASSET SECURITIES CORPORATION TRUST 2006-WF2 Plaintiff v. HERBERT A. BROWN, A/K/A H. ALROY BROWN Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-5692-CIVIL TERM CUMBERLAND COUNTY TO: HERBERT A. BROWN, A/K/A H. ALROY BROWN 257 WHISKEY SPRINGS ROAD DILLSBURG, PA 17019-9012 DATE OF NOTICE: October 4, 2010 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE PERSONALLY OR BY ATTORNEY AND FII.E IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN 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 IlVIPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. PHS # 248785 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. Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION 1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle, FA 17013 2 LIBERTY AVENUE (717) 240-6195 CARLISLE, PA 17013 (717) 249-3166 By: Lawrence T. elan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallinan &Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 248785 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR COURT OF COMMON PLEAS STRUCTURED ASSET SECURITIES CORPORATION TRUST 2006-WF2 Plaintiff CIVIL DIVISION v HERBERT A. BROWN A/K/A H. ALROY BROWN Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 10/16/2010 to Date of Sale ($30.36 per iem) TOTAL NO.: 10-5692-CIVIL TERM CUMBERLAND COUNTY $184,673.42 $20,978.76 $ 05 652.18 : P an Hallman & Schmieg, LLP ' hn Michael Kolesnik, Es q., Id. No.308877 Attorney for Plaintiff Note: Please attach description of property. PHS # 248785 aM\ a g. so ?a a 43.30 OW ??.0o i? I LI . Vo ?' iso. CL I U. s-0 c,t ?k? 11 ? 18 y S V -(r cat Fo? ?SS'Ljeo/ w? o? W? a? C 0w ?H O? O? o? U W ?U O O N H W z 0 W 0.4 a ?o ?U O? 0-0 OU d? ?w O? EAR z : H Cd x a a° °a d O^ a? a? W Q 0 WU W ? w ? O c H 0 w O? w on W o ?g a 3 O O v ? x dON rn > on ? ? rn y ? o W Cl) ?a x N Q w oo °O 00 0 M az ab b .?a w c vD w Cd c"0 U ? A 0 w d LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in the Township of South Middleton, County of Cumberland, and Commonwealth of Pennsylvania, being more particularly bounded and described as follows, to wit: BEGINNING at a steel pin set due North a distance of 5.22 feet from the southernmost dedicated right-of- way line of Whiskey Spring Road (T-518) said pin also being located for reference purposes only due South a distance of 19.78 feet from a point in the centerline of Whiskey Spring Road; thence extending South 86 degrees 7 minutes 10 seconds East for a distance of 150.34 feet to a steel pin at Lot No. 2 on the hereinafter mentioned plan of subdivision; thence extending along Lot No. 2 the following two course3s and distances; due South, through a steel pin set 7.19 feet from the origin of this call, for a total distance of 292.08 feet to a steel pin; thence continuing along Lot No. 2 due West for a distance of 150.00 feet to a steel pin at Lot No. 3 on the hereinafter mentioned plan of subdivision; thence continuing along Lot No. 3 due North through a steel pin set on the southernmost right-of-way line Whiskey Spring Road a distance of 5.22 feet from the terminus of this call, for a total distance of 302.26 feet to a steel pin, said pin marking the place of BEGINNING. CONTAINING 1.023 acres to the property line at the road, and 43,364 square feet to the dedicated right-of- way line of Whiskey Spring Road, and being designated as Lot No. 4 on the final plan of minor subdivision of Fitzgerald Acres prepared for Harmon-Graves Company by Rodney Lee Decker & Associates, dated June 16, 1987, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 55, Page 89. TITLE TO SAID PREMISES VESTED IN Herbert A. Brown, by Deed from H. Alroy Brown, dated 04/20/2006, recorded 05/05/2006 in Book 274, Page 1998. PREMISES BEING: 257 WHISKEY SPRINGS ROAD, DELLSBURG, PA 17019-9012 PARCEL NO. 40-14-0140-062 PHELAN HALLINAN & SCHMIEG, LLP John Michael Kolesnik, Esq., Id. No.308877 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorneys for Plaintiff ..1" : t'El.h_ 20'2 PR -6' A V, 9: 49 "t!?113E Rl. AND COUH I-,, `Ft#1(-yl IA US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR COURT OF COMMON PLEAS STRUCTURED ASSET SECURITIES CORPORATION TRUST 2006-WF2 CIVIL DIVISION Plaintiff NO.: 10-5692-CIVIL TERM V. HERBERT A. BROWN A/K/A H. ALROY BROWN CUMBERLAND COUNTY Defendant(s) CERTIFICATION The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: ( ) the mortgage is an FHA Mortgage ( ) the premises is non-owner occupied ( ) the premises is vacant (X) Act 91 procedures have been fulfilled ( ) Act 91 is Not Applicable pursuant to Pa Bulletin, Doc No 11-1197, 41 Pa.B. 3943 This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. By: Ph on Haninan & Schmieg, LLP Michael Kolesnik, Esq., Id. No.308877 'AM A ttorney for Plaintiff US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR STRUCTURED ASSET SECURITIES CORPORATION TRUST 2006-WF2 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION NO.: 10-5692-CIVIL TERM V. HERBERT A. BROWN A/K/A H. ALROY BROWN Defendant(s) CUMBERLAND COUNTY PHS # 248785 AFFIDAVIT PURSUANT TO RULE 3129.1 US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR STRUCTURED ASSET SECURITIES CORPORATION TRUST 2006-WF2, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 257 WHISKEY SPRINGS ROAD, DILLSBURG, PA 17019-9012. Name and address of Owner(s) or reputed Owner(s): Name 2. HERBERT A. BROWN A/K/A H. ALROY BROWN Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE T C'7 -? = = :Z- C:3 CD C 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) Keystone Financial Bank Keystone Financial Bank, C/O WILLIAM A. DUNCAN, ESQUIRE M & T Bank M&TBank, C/O WILLIAM A. DUNCAN, ESQUIRE Cleveland Brothers Equipment Company, Inc. Address (if address cannot be reasonably ascertained, please so indicate) 257 WHISKEY SPRINGS ROAD DILLSBURG, PA 17019-9012 Address (if address cannot be reasonably ascertained, please so indicate) 4 NORTH HIGHWAY 15 DILLSBURG, PA 17019 1 IRVINE ROW CARLISLE, PA 17013 4 NORTH US HIGHWAY 15 DILLSBURG, PA 17019 1 IRVINE ROW CARLISLE, PA 17013 2300 PAXTON STREET HARRISBURG, PA 17111 Cleveland Brothers Equipment Company, Inc., 100 MARKET STREET, SUITE 200 C/O NATALIE GRILL EINSIG, ESQUIRE HARRISBURG, PA 17108 Falling Spring Technologies P.O. BOX 410 NEWBURG, PA 17240 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANVOCCUPANT BRENDA C. PAUL-BROWN 257 WHISKEY SPRINGS ROAD DILLSBURG, PA 17019-9012 257 WHISKEY SPRINGS DILLSBURG, PA 17019 Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department of Justice U.S. Attorney for the Middle District of PA Federal Building 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 228 Walnut Street, Suite 220 PO Box 11754 Harrisburg, PA 17108-1754 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.A. § 4904 relating to unsworn falsification to authorities. _,, Date: -3 By: ",f)6 Hallinan & Schmieg, LLP Michael Kolesnik, Esq., Id. No.308877 Attorney for Plaintiff US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR COURT OF COMMON PLEAS STRUCTURED ASSET SECURITIES CORPORATION TRUST 2006-WF2 ' CIVIL DIVISION Plaintiff NO.: 10-5692-CIVIL TERM VS. CUMBERLAND COUNTY HERBERT A. BROWN A/K/A H. ALROY BROWN Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: HERBERT A. BROWN A/K/A H. ALROY BROWN r' 257 WHISKEY SPRINGS ROAD ?- DILLSBURG, PA 17019-9012 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORIA10ONk. D WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE fR NOUPkY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT; UT DNL ENFORCEMENT OF A LIEN AGAINST PROPERTY." - Your house (real estate) at 257 WHISKEY SPRINGS ROAD, DILLSBURG, PA 17019-9012 is scheduled to be sold at the Sheriff s Sale on 09/05/2012 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $184,673.42 obtained by US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR STRUCTURED ASSET SECURITIES CORPORATION TRUST 2006-WF2 (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 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 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. 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 filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in the Township of South Middleton, County of Cumberland, and Commonwealth of Pennsylvania, being more particularly bounded and described as follows, to wit: BEGINNING at a steel pin set due North a distance of 5.22 feet from the southernmost dedicated right-of- way line of Whiskey Spring Road (T-518) said pin also being located for reference purposes only due South a distance of 19.78 feet from a point in the centerline of Whiskey Spring Road; thence extending South 86 degrees 7 minutes 10 seconds East for a distance of 150.34 feet to a steel pin at Lot No. 2 on the hereinafter mentioned plan of subdivision; thence extending along Lot No. 2 the following two course3s and distances; due South, through a steel pin set 7.19 feet from the origin of this call, for a total distance of 292.08 feet to a steel pin; thence continuing along Lot No. 2 due West for a distance of 150.00 feet to a steel pin at Lot No. 3 on the hereinafter mentioned plan of subdivision; thence continuing along Lot No. 3 due North through a steel pin set on the southernmost right-of-way line Whiskey Spring Road a distance of 5.22 feet from the terminus of this call, for a total distance of 302.26 feet to a steel pin, said pin marking the place of BEGINNING. CONTAINING 1.023 acres to the property line at the road, and 43,364 square feet to the dedicated right-of- way line of Whiskey Spring Road, and being designated as Lot No. 4 on the final plan of minor subdivision of Fitzgerald Acres prepared for Harmon-Graves Company by Rodney Lee Decker & Associates, dated June 16, 1987, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 55, Page 89. TITLE TO SAID PREMISES VESTED IN Herbert A. Brown, by Deed from H. Alroy Brown, dated 04/20/2006, recorded 05/05/2006 in Book 274, Page 1998. PREMISES BEING: 257 WHISKEY SPRINGS ROAD, DILLSBURG, PA 17019-9012 PARCEL NO. 40-14-0140-062 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 10-5692-CIVIL TERM US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR STRUCTURED ASSET SECURITIES CORPORATION TRUST 2006-WF2 vs. HERBERT A. BROWN A/K/A H. ALROY BROWN owner(s) of property situate in the TOWNSHIP OF SOUTH MIDDLETOWN, Cumberland County, Pennsylvania, being (Municipality) 257 WHISKEY SPRINGS ROAD, DILLSBURG, PA 17019-9012 Parcel No. 40-14-0140-062 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $184,673.42 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 10-5692 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR STRUCTURED ASSET SECURITIES CORPORATION TRUST 2006-WF2 Plaintiff (s) From HERBERT A. BROWN A/K/A H. ALROY BROWN (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $184,673.42 L.L.: $.50 Interest from 10/16/2010 to date of sale - ($30.36 PER DIEM) - $20,978.76 Atty's Comm: % Atty Paid: $180.30 Plaintiff Paid: Date: APRIL 2, 2012 (Sea!) REQUESTING PARTY: Due Prothy: $2.25 Other Costs: r Davi Buell, Prothonotary , By: Name: JOHN MICHAEL KOLESNIK, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Deputy Supreme Court ID No. 308877 AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR STRUCTURED ASSET SECURITIES CORPORATION TRUST PHS # 248785 2006-WF2 DEFENDANT SERVICE TEAM/ Nh HERBERT A. BROWN A/K/A H. ALROY BROWN COURT NO.: 10-5692-CIVIL TERM SERVE HERBERT A. BROWN A/K/A H. ALROY BROWN AT: 257 WHISKEY SPRINGS ROAD DILLSBURG, PA 17019-9012 SERVED TYPE OF ACTION XX Notice of Sheriffs Sale SALE DATE: September 5, 2012 Served and made known to HERBERT A. BROWN A/K/A H. ALROY BROWN, Defendant on ,20 Q, at (o , o'clock P. M., at 957 K,A 1st?SpQtrtt6? V ,DiLLS&Ri.,4in the manner described below: t/ Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is - Adult in charge of Defendant's residence who refused to give name or relationship. - Manager/Clerk of place of lodging in which Defendant(s) reside(s). - Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other: / q. Description: Age Height 5 ((_ Weight 9'36 Race w Sex A' Other ,-??? 1EtT. ?l j fY e a,,x R the Ou day of 49(1- a competent adult, hereby verify that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: 41 1 6h "L NAME: PRINTED NAME: -,ild Moll TITLE: Process Server NOT SERVED On the __ day of , 20_, at o'clock _. M., Defendant NOT FOUND because: Vacant Does Not Exist _ Moved - Does Not Reside (Not Vacant) No Answer on at at Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Jay B. Jones, Esq., Id. No. 86657 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Courtenay R. Dunn, Esq., Id. No. 206779 Allison F. Wells, Esq., Id. No. 309519 Melissa J. Cantwell, Esq., Id. No. 308912 Mario J. Hanyon, Esq., Id. No. 203993 Andrew J. Marley, Esq., Id. No. 312314 ., ~~r~.~ll-fir ~~~~: ,;c- ~~~~ ~F;fl7~lONOTA. PHELAN HALLINAN & SCHMIEG, LLPq~ ~ Z AUG 13 A~ It?~~"~ey for Plaintiff John Michael Kolesnik, Esq., Id. No.30887~J 1617 JFK Boulevard, Suite 1400 ~UM~ERLAND COUNTY One Penn Center Plaza PENNSYLVANIA Philadelphia, PA 19103 215-563-7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA US BANK NATIONAL ASSOCIATION, AS CUMBERLAND COUNTY TRUSTEE FOR STRUCTURED ASSET SECURITIES CORPORATION TRUST 2006-WF2 COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. HERBERT A. BROWN A/K/A H. ALROY BROWN Defendant(s) No.: 10-5692-CIVIL TERM AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY 1 SS: As required by Pa. R.C.P. 3129.1(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each the persons or parties named, at that address, set forth on the Affidavit and as amended applicable. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Retu~ Receipt stamped by the U.S. Postal Service is attached h~xeto Exhibit "A". Jo ichael Kolesnik, Esquire ~~~ rney for Plaintiff Date: IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may n~ be sold in the absence of a representative of the plaintiff at the Sheriff s Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not prese at the sale. PHS # 248785 ._._...N~ ~ W _.__ N ~~+ C ~p 00 ~1 O~ __.~. t!r A W N ~ ~ N " z ~. _ H ~ ~~ _~ art ~o ~ ~_ ~ ~ ~ 1f K' '~' ~' K' * ' K' K' X' ~' ~' * K' K' M' X' „' ~' '~' * ~' ~ K' * X' ~ ~` 1f X' K' ~ ~'. ~ ~' * X' ~F ~' ~ Q "1 A o E ~ Cs7 ~ ~~.1 ~ yy N A -~~ ~. 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