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HomeMy WebLinkAbout10-7744RICIIARD F. STERN, ESQUIRE (03315) STEVEN K. EISENBERG, ESQUIRE (75736) KEVIN P. DI$KIN, ESQUIRE (86727) STERN AND EISENBERG, LLP TIC PAVILION 261 OLD YORK ROAD, SUITE 410 JENKINTOWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) Z~?~ ? ~?~C ~ 6 Pr`s ,~': ~-' IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Deutsche Bank National Trust Company, as trustee for the registered holders of Soundview Home Loan Trust 2006 EQ2 Asset-Backed Certificates, Series 2006-EQ2, by its attorney in fact, Ocwen Loan Servicing, LLC 1661 Worthington Road, Suite 100 West Palm Beach, FL 33409 v. Robert E. Kern and Heather A. Troup 210 Susquehanna Avenue Enola, PA 17025 Defendant(s) Civil Action Number: ~ ~ - ~ ~ `~~ COMPLAINT 1N MORTGAGE FORECLOSURE CIVIL ACTION -MORTGAGE FORECLOSURE This is an attempt to collect a debt and any information obtained will be used for that purpose. NOTICE 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 other rights important to you. 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 a~ ~ ol~ay~~~/ fP~p a~ J:\Supriya\Complaints\Cumberland\Ocwen~Kern.Troup.11.10.doc c~,7F'O"o°' 7 " R.>~.~sa 5Ya 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.Kern.Troup. l 1. l0.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.Kern.Troup. l l . l0.doc RICHARD F. STERN, ESQUIRE (03315) STEVEN K. EISENBERG, ESQUIRE (75736) KEVIN P. DISKIN, ESQUIRE (86727) STERN AND EISENBERG, LLP T71E 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 Soundview Home Loan Trust 2006 EQ2 Asset-Backed Certificates, Series 2006-EQ2, by its attorney in fact, Ocwen Loan Servicing, LLC 1661 Worthington Road, Suite 100 West Palm Beach, FL 33409 v. Robert E. Kern and Heather A. Troup 210 Susquehanna Avenue Enola, PA 17025 Defendant(s) Civil Action Number: ~ ~ ' ~ 7 y y G ~` ` ` COMPLAINT iN MORTGAGE FORECLOSURE COMPLAINT CIVIL ACTION -MORTGAGE FORECLOSURE 1. Plaintiff is Deutsche Bank National Trust Company, as trustee for the registered holders of Soundview Home Loan Trust 2006 EQ2 Asset-Backeci Certificates, Series 2006-EQ2, 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 Robert E. Kern and Heather A. Troup, adult individuals with alast- known address of 210 Susquehanna Avenue, Enola, PA 17025. 3. Under date of 10/06/2006, defendants executed and delivered to MERS, Inc., as nominee for Equifirst Corporation a mortgage upon the property 210 Susquehanna Avenue, Enola, PA (the "Property") to secure the payment of the sum of $68,000.00. The said mortgage is recorded in the Office for the Recording of Deeds in and for Cumberland County on 10/25/2006 at Book 1970 at Page 2612 and is incorporated herein by reference as though J:\Supriya\Complaints\Cumberland\Ocwen.Kern.Troup. l l . l 0.doc 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 210 Susquehanna Avenue, Enola, PA 17025. 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 $687.72 due on August 1, 2010 and on the same day of each month thereafter. 9. The following is due on the loan: PRINCIPAL BALANCE .......................................................$65,859.22 INTEREST accrued thru 11/23/2010 of .............................. .$2,331.88 Interest after 11 /23/2010 shall accrue at the per diem rate of $16.39.) LATE CHARGES accrued thru 11/23/2010 of .....................$109.12 Late charges after 11/23/2010 shall accrue at the monthly rate of $54.56.) ESCROW ADVANCES ........................................................ $586.67 FEES BILLED ....................................................................... $121.50 LEGAL COSTS ..................................................................... 300.00 ATTORNEY'S FEE ............................................................... $3,300.00 LESS TOTAL ........................................................................ $72,608.39 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 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 $65,859.22 plus interest thereon of $2,331.88 plus $16.39 per day from 11/23/2010 until judgment is paid in full, late charges J:\Supriya\Complaints\Cumberland\Ocwen.Kem.Troup. l l . l0.doc of $109.12, plus late charges of $54.56 per month from 11/23/2010 until judgment is paid in full, escrow advances of $586.67, fees billed of $121.50, costs of $300.00, attorney's fees of $3,300.00 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: CH J:\Supriya\Complaints\Cumberland\Ocwen.Kem.Troup. l 1. l0.doc Date: November 23, 2010 ., ESQUIRE S EN K. EISENBERG, ESQUIRE KEVIN P. DISKIN, ESQUIRE Attorney for Plaintiff VERIFICATION I, the undersigned, an authorized representative of Plaintiffs servicing agent, Ocwen Loan Servicing, LLC ("Ocwen"), am authorized to make this verification on behalf of Plaintiff and hereby certify that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. Except where otherwise stated and/or based upon public record, this verification is based upon a review of business records regularly created, kept and maintained in the course of Ocwen's mortgage servicing business conducted on Plaintiff s behalf. In making this verification, I understand that it is a crime under 18 PA C.S. Section 4904 to make a written statement to a public servant, or to invite a public servant's reliance upon a written statement or instrument, which I do n believe to be true or which I know to be false. ~ 0 3 210 Date: Title: Ocwen Loan Ser 'sing, LLC as attorney-in-fact for Plaintiff Notary Public State of Florida Rashad Blanchard My Commiaion EE027488 ~0- R~ Expiros 0 8/1 9120 1 4 ALL THAT CERTAIN tract or parcel of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the Easterly line of Susquehanna Avenue, which point is ninety-nine and six hundred ninety-nine one-thousandths (99.699) feet North of the Northeasterly corner of Susquehanna Avenue and Dauphin Street; thence along the Easterly line of Susquehanna Avenue North Eve (5) degrees nine (9) minutes thirty (30) seconds East twenty (20) feet to a point; thence further along the Easterly line of Susquehanna in an arc having a radius of seven hundred twenty-five (725) feet in a Northerly direction to the left thirty (30) feet to a point; thence through the center of a petition wall and beyond South eighty-seven (87) degrees twelve (12) minutes forty-five (45) seconds East one hundred fifty and seventy-five one-hundredths (150.75) feet to a point; thence South five (5) degrees nine (9) minutes thirty (30) seconds West fifty-six (56) feet to a point, the place of BEGINNING. BEING premises known as 210 Susquehanna Avenue, Enola, PA PARCEL NO. 09-14-0832-131 I Certify this to he r:'CC'. , In Cumberland Cac'.-.~y ~- :'- ;.. e. ~~.~.~.::. , ,. .~~•~~ . ):* , --~-~ ~_ :...................... Ocwen Loan Servicing, LLC P. O. Box 24737 `•• ~~- •' West Palm Beach Florida 3 O C W E N ' (Do not send correspondence September 30, 2010 3416-4737 or payments to the above address.) WW W.OC~~'EN.CO~t VIA First Class Mail VIA Certified Mail (return receipt requested) Certified Number: 71069017515136359625 Reference Code: 1007 Heather A. Troup 210 Susquehanna Avenue Enola, PA 17025 Loan Number: 40364770 Property Address: 210 Susquehanna Avenue , Enola, PA 17025-0000 PLEASE SEE THE ENCLOSED DOCUMENT ~~ DACT91.17 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; September 30, 2010 . 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.) WVVW.OCWEN.COM APPENDIX A ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on Xour home is in default, and the lender intends to foreclose Specific information about the nature of the default is provided in the attached a ec The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM LHEMAP may be able to help to save your home.. This Notice explains how the program works. To see if HEMAP can helpyouu must MEET WITH A CONSUMER REDIT COUNSELIN AGEN Y WITHIN THIRTY (30) DAYS OF THE DATE OF THI NOTI Take thi 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 (7~) 780-18691 This Notice contains important legal information If you have any questions, representatives at the Consumer redit Counseling Ag ncy may be able to he~p~xplain 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 PARR 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): Heather A. Troup PROPERTY ADDRESS: 210 Susquehanna Avenue Enola, PA 17025-0000 LOAN ACCT. NO.: 40364770 ORIGINAL LENDER: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CURRENT LENDER/SERVICER: OCWEN DACT91.17 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 ...................... Oewen Loan Servicing, LLC n P.O. Box 24737 V `--~------` West Palm Beach, Florida 33416-4737 O C W E N (Do not send correspondence or payments to the above address.) W~'~'V1%.OCWEN.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 RARY STAY OF FORECL OSURE --Under the Act, you are entirted to A tem porary stay of fore~~~c~~re nn your mo rtgage for thirty (30) days 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 gumgr crer~it cnnnceling~g .nriPC lia e!I ~+ the nnrl o f +hi~ Nn+ine TAiR MFT1 TiNC MUST O CCUR WITHIN THE NE XT (301 DAYS IF YOU DO NOT APP Y FnR FMFR("FNC'Y MnRT('ACF ASSISTA NCE. YOU MUST BRIN G YOUR MORTGAGE UP TO DAT TH . PART OF THI NOTI F CALLED "HOW TO CURE YOUR MORTGAGE DEFAUI T", EXPLAINS HOW TO __ BRING YOUR MORT A UP TO D ATE. CONSUMER CREDIT COUNSELING AGEN IE -- 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~•gen~iec fnr the_ coup in which the Fronerty is located are set forth at the end of thi Noticg. It is only necessary to schedule one face- to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE A~SiSTANCF. -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). DACT91.17 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. However, if the debt is in active bankruptcy or has been discharged Through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt Ocwen Loan Servicing, LLC P.O. Box 24737 '°-°°° - West Palm Beach, Florida 33416-4737 O C W E N (Do not send correspondence or payments to the above address.) WVy'~V.OCWEN.C<)~1 HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it UD to datel. NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender on your property located at: 210 Susquehanna Avenue , Enola, PA 17025-0000 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 2 payments in the amount of $ 687.72 from August Ol. 2010 through September 30, 2010 Principal and Interest ................................. Interest Arrearage ..................................... Escrow .................................................. Late Charges ........................................... Insufficient Funds Charges ........................... Fees /Expenses ........................................ Suspense Balance (CREDIT) ........................ Interest Reserve Balance (CREDIT) ................ TOTAL DUE .......................................... $ 1,091.16 $ 0.00 $ 284.28 $ 109.12 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 1,484.56 HOW TO CU F TH D .FAiJi.T __ you may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $1,484.56, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by Money ram, Cashier's C'herka Cprt~~Pd Check or Money Order made. Rayable and sent to: OCWEN P.O. BOX 6440 CAROL STREAM, IL 60197-6440 IF YOU DO NOT F. TH D FAiTi T -- 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 arralnrn+p +hn r..nr+g~gg a~I, This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged propertX. IF THE MORTGAGE IS FORECLO ED 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 ply attorney' f ec OTHER i..ND R FM .DI -The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THF. nF,FAiii T PRinR T H IFF' SAL - 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 anv time up to one hour before the Sheriffs ale You may do so by paying the total amount then. Il'.1 Rt ('tIIP_ Ff~uc anv 1~+a nr n+6nr n6n rnne t6 u.. .7.,0 ..o..........1.1.. .. aa...._.._.1_ e___ __~ ___~_ _____ , ... .. .. other requirements under the mort a e. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. DACT91.17 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 ................z Ocwen Loan Servicing, LLC P.O. Box 24737 ---------` West Palm Beach, Flonda 33416-4737 O C W E N (Do not send correspondence or payments to the above address.) W R'VI%,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 Sheriff s 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: 800-310-9229 Fax Number: 407-737-6300 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 t. 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 YOLJ BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW„ CONSUMER CREDIT COUNSE IN ACFN('iFC CFRViNf Y(liiR C'(1T'NTY DACT91.17 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt Ocwen Loan Servicing, LLC P.O. Box 24737 ~` West Palm Beach Florida 3 O C W E N ' (Do not send correspondence September 30, 2010 3416-4737 or payments to the above address.) W~~'N%.UCWEN.COM VIA First Class Mail VIA Certified Mail (return receipt requested) Certified Number: 71069017515136359618 Reference Code: 1007 Robert E. Kern 210 Susquehanna Avenue Enola, PA 17025-2424 Loan Number: 40364770 Property Address: 210 Susquehanna Avenue , Enola, PA 17025-0000 PLEASE SEE THE ENCLOSED DOCUMENT DACT91.17 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 3 (Do not send correspondence September 30, 2010 3416-4737 or payments to the above address.) W~'VV.OCV4'EN.COM APPENDIX A 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 S ecific information about the nature of the default is provided in the attache aee~ T~ HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAPI may be able to hel~to save your home . This Notice exulains how the grogram works. To see if HEMAP can helywou must MEET WITH A CONSUMER CREDIT COUNSELIN A ENCY WITHIN THIRTY (301 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 Aeencies servingyour 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 ca (717) 780-1869 This Notice contains important legal information. If you have any questions. representatives at the Consumer Credit Counseling Agency may be able to 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, PLIES 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. LISTED 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): Robert E. Kern PROPERTY ADDRESS: 210 Susquehanna Avenue Enola, PA 17025-0000 LOAN ACCT. NO.: 40364770 ORIGINAL LENDER: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CURRENT LENDER/SERVICER: OCWEN DACT91.17 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt Ocwen Loan Servicing, LLC ~. P.O. Box 24737 `------~---~` West Palm Beach, Flortda 33416-4737 O C W E N (Do not send correspondence or payments to the above address.) N'W 4V.OC1~'~'EN.COiyI 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 RARY STAY OF FORECL. OSURF. --Under the Act. you are entitled to a tem porary stay of fore~lncnre ~~ your mo rtgage for thirty (301 days 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 1'. ted at the end o f this Nntirn, TNi~ MF,F.TiN(: MUST O CCUR WITHIN THE NE XT (301 DAYS. IF YOU DO NOT APPi.Y FOR F.MF.RrF.NCY MnRTGAGF. ASSISTA NCE, YOU MUST BRIN G YOUR MORTGAGE UP TO DATE. THE P RT OF THI NOTI . CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO _ BRING YOUR MORT A F UP TO D ATE. 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 agenc~pc fir the_ coon in which the ILA' 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 MORT A A~~iSTANC'F, -Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your 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). DACT91.17 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 Q' -------°-° West Palm Beach, Florada 33416-4737 O C W E N (Do not send correspondence or payments to the above address.) WWII%.UC'WEN.COVI HOW TO CU E YOUR MORTGAGE DEFAULT ring it up to datel. NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender on your property located at: 210 Susquehanna Avenue , Enola, PA 17025-0000 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 2 payments in the amount of $ 687.72 from August Ol, 2010 through September 30, 2010 Principal and Interest ................................. Interest Arrearage ..................................... Escrow .................................................. Late Charges ........................................... Insufficient Funds Charges ........................... Fees /Expenses ........................................ Suspense Balance (CREDIT) ........................ Interest Reserve Balance (CREDIT) ................ TOTAL DUE .......................................... $ 1,091.16 $ 0.00 $ 284.28 $ 109.12 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 1,484.56 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 $1,484.56, 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 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 u on 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 SHE iFF'S A - 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 un to one hour before the Sheriff c Sale You may do co by plying the total amount then. ..no4 .I..n r.l.... n.... Ind.. .... ..41...« ..1... «...... 41..... .~ .... ..............1_I.. .. u.....___.1_ O-__ _~a _-_a_ ___"__a_~ ____a~ .~_ ~_____~__ other reQuirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. DACT91.17 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt Ocwen Loan Servicing, LLC P.O. Box 24737 `•- ° -~ --` West Palm Beach, Florida 33416-4737 OCWEN (Do not send correspondence or payments to the above address.) W W W.OCbVEN.COi1d F,ARi.IEST 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 Sheriff s 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: 800-310-9229 Fax Number: 407-737-6300 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 ~ 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 'CO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW,. ('ONSUMER CREDIT COUNSELING AGENCIES SERVING YO TR ('tli?NTy DACT91.17 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 LUZERNE COUNTY 846 Nortit Broad Street 163 Amber Lane Philadelphia, Pa., 19130 Wilkes Barre, Pa., 18702 (215) 765-1221 (570) 826-0510 or ] -800-822-0359 Counties: Bucks, Chester, Delawaro, Montgomery and Philadelphia Counties: Carbon, Luzeme, Schuylldll and Wyoming Action Housing, Inc 425 6t° Avenue, Suite 950 Pittsburgh, Pa., 15219 (412) 391-1956, (412) 281-2102 or (800) 792-2801 Counties: Allegheny, Beaver, Butler, Fayette, Greene Washington and Wtstmorcland COMMLINIIY ACTION SOUTHWEST ?2 Wes[ High Street Adams County Interfaith Housing Authority Waynesburg, Pa_, 15370 (412}852-2893 AMERICAN RED CROSS - HANOVER CHAPTER FAX: (412) 627-7713 529 Carlisle Street Contact Doug Wagner Hanover, Pa., 1733I Counties: Allegheny, Fayette, Greene, Washington (717) 637-3294 and Westmoreland FAX: (717) 637-3294 Contact: Stephanie Calp CONSUMER CREDIT COUNSELING SERVICE Counties: Adams, Franklin and York OF DELAWARE. VALLEY 1515 Market Street, Suite 1325 BLAIR COUNTY ECONOMIC OPPORTUNITY COUNCIL Philadelphia, Pa , 19102 5433 Industrial Avenue (215) 563-5665 Ahoona, Pennsylvania, 16601 FAX: (215) 864-2666 (814) 946-3651 Contact Tom O'Neill FAX: (814) 946-5451 Counties: Bucks, Chester, Delaware, Montgomery Contact: pawl Rennie and Philadelphia Counties: Blair only CONSUMER CREDIT COUNSELING SERVICE BOOKER T. WASHINGTON CENTER OF LEHIGH VALLEY 1720 Holland Street 3671 C7esc«tt Court East Erie, Pennsylvania, 16503 Whitehall, Pa., R 9107 (814) 453-5744 (215) 821-041 I or FAX: (814) 453-5749 1-800-220-2733 (717 & 814 Area codes only) Contact Bob Huhta FAX: (215) 821-0137 Counties: Crawford, Earl and Warren Contact: Al Kotrh Counties: Burks, Bucks, Carbon, Lancaster, BUCKS COUNTY HOUSING GROUP, INC. Lehigh and Northhampton 140 East Richazdson Avenue Langhorne, Pa., 19047 CONSUMER CREDIT COUNSELING SERVICE (215) 750310 OF WESTERN PENNSYLVANIA, INC. FAX: (215) 750-4318 A) 309 Smithfield Street, Suite 2000 Contact: Pat Dyson Pittsburgh, Pa., 15222 Counties: Bucks only (412) 471-7584 Contact: Jack: Onorad BUDGET COUNSELING CENTER B) 1 North Gate Square 247 North Fifth Sweet #2 Garden Ginter Drive Reading, Pa., 19601 Greensburg, :Pa., 15601 (215) 375-7866 (412) 838-1290 FAX: (215) 376-b575 -Main Office C) 500-02 3rd Avenue, P.O. Box 278 Contact: Deborah Strunk Duncansville, Pa., 16635 Counties: Berks, Chester, Montgomery and Schuylkill (814) 696-354,6 D) l st Federal Plaza, Suite 406 CENTRO PEDRO CLAVER North Mill Street 3565 North 7th Street New Castle, I'a., 16101 Philadelphia, Pa., )9130 (412) 652-8074 (215) 227-7111 E) 524 Franklin Avenue FAX: (215) 227-7117 Franklin Cem:er Contact: Roberto Santiago Aliquippa, Pa., 15001 Counties: Philadelphia, Bucks, Chester, Delaware and Montgomery (412) 652-8074 ACT 91 AGENCY LLST'ING CONTINUED CONSUMER CRIDII COUNSELING OF VdFSTERN PENNSYLVANI4, 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, Clearfeld, Fayette, Frankin, Fulton, Greene, Huntingdon, Indiana, Jefferson, Juniata, Lawrence, Mercer, Miffiin, Snyder, Somerset, Union, Venango, Washington and Westmoreland. H) 912 South George Street York, Pa, 17403 (717) 846176 Counties: York, Adams, Franklin and Lancaster CONSUMER CREDIT COUNSELING SERVICE OF NORTHEASTERN PENNSYLVANIA A) Human 5avices 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, LacL~awanna, Luzeme, Lycoming, Monroe, Montour, Northumberland, Pike, Sullivan, Susquehanna, Tioga, Wayne and Wyoming ECONOMIC OPPORTUNITY CABINET OF SCHUYLKTT.r. COUNTY 118 Norwegian Street Pottsville, Pa, 17901 (717)622-1995 FAX (717)622-0429 Contact: Marybeth Dohman Counties: Berta, Carbon, Lebanon, Lehigh, Luzeme, Northumberland and Schuylkill FAYETTE COUNTY COMMUNITY ACTION AGENCY, INC. 137 North Beeson Avenue Uniontown, Pa, 15401 (412) 437-b050 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 Eric, Pa., 16501 (814) 459j1581 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, 15701 (412)465-2657 FAX (412) 465-5 ii l 8 Contact: Randy Foster Counties: Armstrong, Cambria, Clearfield, Indiana, Jefferson and Westmoreland HOME MORTGAGE PROTECTION GROUP A)19 West 3rd Streit Chester, Pa, l 9013 (215) 2471712 B) 8634 Provident Street Philadelphia, Pa, 19150 (215)447-9568 FAX (215) 872-4856 Contact AA Mohammed Counties: Berta, Chester, Delaware, Lancaster, Montgomery and I?hiladciphia HOUSING COUNCIL OF YORK ] 16 North George Street Yorl~ 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, ] 9123 (215) 978-0224 FAX: (215) 765-7614 Contact Khalil Walker County. Philadelphia only HOUSING OPPORTUNITIES, INC. 133 Seventh Street, P.O. Box 9 Mckeesport, Pa, 15134 (412) 664-1590 FAX: (412) 664-f1873 Contact Allen Sethman Counties: Allegheny, Beaver, Butler, Washington and Wesmoreland JOHN F. KENNEDY CENTER, INC. 2021 East 20th Street Erie, Pa., 16510 (814} 898-0400 FAX: (814)898-1243 Contact: Mary Gavin Counties: Crawford, Elk, Erie, Jefferson, Mckean and Venango KEYSTONE ECONOMIC DEVELOPMENT CORP. ] 954 Mary Grace Lane Johnstown, Pa., 15901 (814) 539-1688 FAX: (814)539-1688 Contact David Kennedy Counties: Bedford, Blair, Cambria, Clea~eld, Indiana, Somerset and Westmoreland tXf ... ACT 91 AGENCY LISTING CONTIl~UED LA CASA DEL PUEBLO 815 W. Bahimore Turnpike Kennet Square, Pa, 19348 (215) 4443731 FAX (215) 4443178 Contact Dawn Vega Counties: Chester, Delaware, Montgomery, Lancaster and Becks LYCOMWG-CLWTON COUNTIES COMMISSION FOR COMMUNITY ACTION 2138 Lincoln Street, PO Box 1328 Williamsport, Pa., 17703 (717) 326-0587 FAX: (717)322-2197 Contact Dan Mork Counties: Clinton and Lycoming MIDIA FELLOWSHIP HOUSE 302 South Jackson Street Malin, 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: (21 S) 277-2123 Contact: Charles Mason County. Montgomery only HON-VALLEY UNEMPLOYED COMMITTEE 116 Fifth Avenue Mckeesport, Pa, 15132 (412)678-1409 Contact: Ray Ganczlc Counties: Allegheny, Beaver, Butler, Fayette, Green Washington and Westmoreland NORTHERN TIER COMMUNITY ACT10N CORP. 135 West 4th Street Emporium, Pa, 15834 (8]4)486-1161 FAX: (814) 486-3370 Contact: Fred Fish Counties: Cameron, Elk, Mckean and Potter PHILADELPHIA COUNCII, FOR COMMUNITY ADVANCEMENT 100 North 17th Street, Suite 600 Philadelphia,Pa., 19]03 (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 SER~rlCES, INC. 131 North Centres- Avenue Some Pa,1S501 (814)445-9628 FAX (814) 443-•3690 Contact Mary A.nn Strong Counties: Bedford, Cambria, Fayette, Somerset and Westmoreland TABOR COMHUTIITY SERVICES, INC. 439 East King Street Lancastu, Pa, 17602 (717) 397-5182 or (800) 788-5062 (Homeowners only) FAX (717) 399••4127 Contact Nevin Borst Counties: Chesnx, Lebanon and Lancaster THE TRIIiAB CENTER OF NORTHEASTERN PENN. A) 7 Lake Avenue, Box 366 Montrose, Pa, 18801 (800) 982.045 FAX (717) 278-1889 B) 185 Elmira Street, P.O. Box 218 Troy, Pa, 16947 (717) 297-2101 Contact Carolc:Munn Counties: Bradfi>rd, Sullivan, Susquehanna, Tioea, Wayne and Wyoming URBAN LEAGUE OF METROPOLITAN HARRISBURG 25 North Front Street Harrisburg, Pa., 17101 (7]7)234-5925 FAX (717)232-4985 Contact Kelly Sloane URBAN LEAGUE OF PHILADELPHIA Urban Educ~tioa Foundation 4601 Haricot Street, 2nd Floor/South Wing Philadelphia, Pa., 19139 (215) 476{140 FAX (215) 476•d667 Contact Hcrb Brunson County: Philadelphia only URBAN LEAGUE OF PTITSBURGH, INC. One Smithfield Street Pittsburgh, Pa., 15222-2222 (412) 261-] ] 30 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 S~+van Counties: Forrest. and Warren YWCA OF CARLISLE 301 G Street Cazliste, Pa, 17013 (717) 243-3818 FAX: (717) 243-:3948 Contact: Pamela :Line Counties: Cumberland, Franklin and Perry txf SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson r Sheriff ! _ .. . Jody S Smith 1 i ? Chief Deputy -Ai f 3 Richard W Stewart + {^ F?, '.i {1 ? f L t "f% 4 { e t l a J ? Solicitor » 1 4 ? i? Deutsche Bank National Trust Company Case Number vs. 2010-7744 Robert E. Kern (et al.) SHERIFF'S RETURN OF SERVICE 12/20/2010 03:44 PM - Deputy Shawn Harrison, being duly sworn according to law, attempted service to the Defendant, to wit: Heather A. Troup at 210 Susquehanna Avenue, East Pennsboro Township, Enola, PA 17025. The address was found to be vacant. 12/28/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Robert E. Kern, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Robert E. Kern. Request for service at 210 Susquehanna Avenue, Enola, Pennsylvania 17025 is vacant. The Enola Postmaster has confirmed, Robert E. Kern has moved and left no forwarding address. 12/28/2010 06:58 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on Decembe 28, 2010 at 1858 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Heather A. Troup, by making known unto Barbara Troup, Mother of defendant at 1000 Good Hope Road, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. IA A RO ERT BITNER, D PUT SHERIFF COST: $71.50 January 04, 2011 SO ANSWERS, RbNl`V R ANDERSON, SHERIFF COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW KEVIN P. DISKIN, ESQUIRE STERN AND EISENBERG 410 The Pavilion, 261 Old York Road r- Jenkintown, PA 19046 4_- (215) 572-8111 -n I.D. #86727 C:j --? c° Deutsche Bank National Trust Company, =C:) C) n As Trustee, By its attorney in fact, Ocwen Loan Servicing, LLC VS. ROBERT E. KERN AND HEATHER A. TROUP NO. 10-7744 CIVIL TERM MOTION FOR SPECIAL ORDER DIRECTING SERVICE BY POSTING AND CERTIFIED MAIL PURSUANT TO PA. R.C.P. 430(a) TO DEFENDANT ROBERT E. KERN 1. Plaintiff is Deutsche Bank National Trust Company, assignee of a loan to defendant' s secured by a mortgage on their real estate at 210 Susquehanna Avenue, Enola, PA 17025. As a result of defendants' default on said mortgage, Plaintiff filed a Civil Action on December 23, 2010. 2. The whereabouts of defendant ROBERT E. KERN whose last known address according to Plaintiff s records is 210 Susquehanna Avenue, Enola, PA 17025 is unknown, and accordingly, an attempt to serve such defendants pursuant to the usual process prescribed by Pa. R.C.P. 400-405 would be futile. 3. Pursuant to Pa. R.C.P. 430(a), an investigation has been made to determine the whereabouts of the Defendants and the reason 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. 4. 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 Plaintiffs Civil Action and all further notices requiring personal service, if any, on the most public part of 210 SUSQUEHANNA AVENUE, ENOLA, PA 17025 and by certified mail, return receipt requested to Defendant, ROBERT E. KERN, at his last known address being 210 SUSQUEHANNA AVENUE, ENOLA, PA 17025. WHEREFORE, Plaintiff by its attorney moves this Honorable Court to enter a special order directing that service be made by posting a copy of Plaintiffs Civil Action on premises 210 SUSQUEHANNA AVENUE, ENOLA, PA 17025 and by sending a copy of same to Defendant, ROBERT E. KERN at his last known address being 210 SUSQUEHANNA AVENUE, ENOLA, PA 17025 by certified mail, return receipt requested and regular mail. The Court is further requested to direct that all further notices required in the above-captioned matter, requiring personal service, if any, be served on Defendants in the same manner as permitted for service of Plaintiff s Civil Action in this case. STERN AND EISEN E BY: KEVIN P. DISKIN, Attorney for Plaintiff 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. 10-7744 CIVIL TERM ROBERT E. KERN AND HEATHER A. TROUP 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 ROBERT E. KERN: 1. Service of Plaintiff, s Civil Action was attempted by the sheriff of Cumberland County at the mortgaged property address being 210 SUSQUEHANNA AVENUE, ENOLA, PA 17025, per the sheriff, the property is vacant. See Exhibit "B" which is attached hereto and made a part hereof. 2. Plaintiff sent an inquiry to the Department of Motor Vehicles in order to obtain information concerning the defendant and defendant ROBERT E. KERN is registered at 210 Susquehanna Avenue, Enola, PA 17025. See Exhibit "C" which is attached hereto and made a part hereof. 3. Moreover, Plaintiff did an inquiry to the Post Office and according to the records it maintains, the defendant moved and did not leave a forwarding address with the Post Office. See collective Exhibit "D" which is attached hereto and made a part hereof. J:\ANGELA\POSTING\CUMBERLAND\OC WEN.KE 4. Plaintiff also sent an inquiry to the Department of Voter Registration in Cumberland County and according to the records it maintains, the defendant, ROBERT E. KERN is registered at the mortgaged property address, 210 Susquehanna Avenue, Enola, PA 17025. See collective Exhibit "E" 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 ROBERT E. KERN is registered at 210 Susquehanna Avenue, Enola, PA 17025. See Exhibits "F" 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 ROBERT E. KERN 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. STERN AND COMMONWEALTH OF pENNSYWA A B NOW" saw prpeia Hartigan, , Notary County M0"ao mow! 21L 9012 own 0MW M NOMW ES-EVIN P. DISKIN, Attorney for Plaintiff J:\ANGELA\POSTING\CUMBERLAND\OCWEN.KERN.2.1 LDOC Sworn to and subs, ribed before me this!/Day of Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY Deutsche Bank National Trust Company vs. Robert E. Kern (et al.) SHERIFF'S RETURN OF SERVICE Case Number 2010-7744 12/20/2010 03:44 PM - Deputy Shawn Harrison, being duly sworn according to law, attempted service to the Defendant, to wit: Heather A. Troup at 210 Susquehanna Avenue, East Pennsboro Township, Enola, PA .17025. The address was found to be vacant. 12/28/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Robert E. Kern, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Robert E. Kern. Request for service at 210 Susquehanna Avenue, Enola, Pennsylvania 17025 is vacant. The Enola Postmaster has confirmed, Robert E. Kern has moved and left no forwarding address. 12/28/2010 06:58 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on Decembe 28, 2010 at 1858 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Heather A. Troup, by making known unto Barbara Troup, Mother of defendant at 1000 Good Hope Road, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $71.50 January 04, 2011 RO ERT BITNER, D PU SO ANSWERS, RONW R ANDERSON, SHERIFF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION BUREAU OF DRIVER LICENSING BASIC DRIVER INFORMATION DEC 22 2010 DRIVER: ROBERT EUGENE KERN 210 SUSQUEHANNA AVE ENOLA, PA 17025 DRIVER LICENSE (DL) LICENSE CLASS : C M LICENSE ISSUE DATE: MAR 11 2009 LICENSE EXPIRES : DEC 13 2012 BRIG ISSUE DATE : OCT 11 2001 MED RESTRICTIONS : 1 LEARNER PERMITS LICENSE STATUS PAGE 1 DRIVER LICENSE NO : 26892203 DATE OF BIRTH : DEC 12 1983 SEX : MALE RECORD TYPE . REG LICENSE 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 *** Postmaster Enola, PA 17025 City, State, ZIP Code Date: December 20, 2010 Request For Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or the name and street address (if a boxholder) for the following: Name: Robert Kern Address: 210 Susquehanna Ave., Enola, PA 17025 NOTE: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester (e.g., process server, attorney, party representing himself): Attorney 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se - except a corporation acting pro se must cite statute): N/A 3. The names of all known parties to the litigation: DEUTSCHE BANK NATIONAL TRUST COMPANY VS. ROBERT KERN AND HEATHER TROUP 4. The court in which the case has been or will be heard CCP CUMBERLAND COUNTY 5. The docket or other identifying number if one has been issued 6. The capacity in which this individual is to be served (e.g., defendant or witness): Defendant WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (Title 18 U.S.C. Section 1001). STERN AND EISENBERG THE PAVILION gnature 261 OLD YORK RD.SUITE 410 /Printed evin P. Diskin, Esquire JENKINTOWN, PA 19046 Name City, State, ZIP Code FOR POST OFFICE USE ONLY No change of address order on file. Not known at address given. Moved, left no forwarding address. No such address. NEW ADDRESS or BOXHOLDER'S POSTMARK NAME and STREET ADDRESS BirthDate: Social Sec: Driver's Lic_: Phone: U: ? Sex: Race Lan ua e: Assistance: 12/12/1983 >=-X {-9018 26892203 717-802-2510 r M Party: Other Part : Last Voted: REPUBLICAN -11 Must Vote r Poll WorkerF. In Person Precinct Split: 05-09-1 Insert r Poll Worker Interest EAST PENNSBO , Clear '-' OK Cancel Record: 1 15of t Page 1 of 1 ROBERT E KERN Gender - Male 210 SUSQUEHANNA AVE ENOLA, PA 17025-2424 SSN - 172-64-xxxx Age - 26 DOB - 12/12/1983 Dates - Oct 10 Phone - 717-525-9354 - EST https: //secure. accurint. com/app/bps/main 11/16/2010 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW KEVIN P. DISKIN, ESQUIRE rnca STERN AND EISENBERG a 410 The Pavilion, 261 Old York Road Jenkintown PA 19046 C C7 -p z - (215) 572-8111 . na p ? I.D. #86727 77 ?C Deutsche Bank National Trust Company, As Trustee, By its attorney in fact, Ocwen Loan Servicing, LLC VS. : NO. 10-7744 CIVIL TERM ROBERT E. KERN AND HEATHER A. TROUP CERTIFICATE OF SERVICE I, KEVIN P. DISKIN, attorney for the within Plaintiff, hereby certify that a true and correct copy of Plaintiffs Motion 7, r Al ernative Service was mailed to the following by first class, postage prepaid mail on ?? ROBERT E. KERN 210 Susquehanna Avenue Enola, PA 17025 STERN AND EIS NBERG BY: K IN P. , Attorney for Plaintiff DATE: J:\ANGELA\POSTING\CUMBERLAND\OC WEN.KERN.2. I .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 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) 4r I T19'.. i t1+1 i 2011 FEB 24 FM I FSLENNYVCOUNTY IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Deutsche Bank National Trust Company, as trustee for the registered holders of Soundview Home Loan Trust 2006 EQ2 Asset-Backed Certificates, Series 2006-EQ2, by its attorney in fact, Ocwen Loan Servicing, LLC 1661 Worthington Road, Suite 100 West Palm Beach, FL 33409 v. Robert E. Kern and Heather A. Troup 210 Susquehanna Avenue Enola, PA 17025 Defendant(s Civil Action Number: 10-7744 COMPLAINT IN MORTGAGE FORECLOSURE PRAECIPE TO REINSTATE CIVIL ACTION Kindly reinstate the civil action in the above captioned matter. STERN AND EISENBERG BY: KEVIN P. DISKIN, ESQ. Attorney for Plaintiff J:\ANGELA\REINSTATEMENTS\CUMBERLAND\OCWEN.KERN.2.11.DOC &10.00 `?cl a ??a s? e#a 5 i0h r 40 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ?.. CIVIL ACTION-LAW ' M CD KEVIN P. DISKIN, ESQUIRE rn STERN AND EISENBERG LLP The Pavilion o = -`rl 261 Old York Road, Suite 410 v c-) =ca -,' Jenkintown, PA 19046 v _ •• yfr (215) 572-8111 , _ I.D. #86727 Deutsche Bank National Trust Company, as trustee for the registered holders of Soundview Home Loan Trust 2006 EQ2 Asset-Backed Certificates, Series 2006-EQ2, by its attorney in fact, Ocwen Loan Servicing, LLC 1661 Worthington Road, Suite 100 West Palm Beach, FL 33409 V. Robert E. Kern and Heather A. Troup 210 Susquehanna Avenue Enola, PA 17025 Defendant(s) Civil Action Number: lb- 1111d COMPLAINT IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I, KEVIN P. DISKIN, ESQ., attorney for the within Plaintiff, hereby certify that reinstated Civil Action was mailed to the Defendant by certified mail, return receipt requested and regular mail on March 2, 2011, pursuant to court order, as evidenced by copy of said order, certified mail receipt and certificates of mailing attached. STERN AND EISENBERG LLP KEVIN P. DISKIN Attorney for Plaintiff 03/02/11 N a C H ,w q?S POST ?Gt -PITNEY 130WES 02 1 P $ 001.15° co, N l0 7 C f0 7 r co m E O LL 1n a 9TL LL` E 9689 ?000 ` OLQT O't0L 4 5 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW Deutsche Bank National Trust Company, As Trustee, By its attorney in fact, Ocwen Loan Servicing, LLC VS. ROBERT E. KERN AND HEATHER A. TROUP NO. 10-7744 CIVIL TERM ORDER / / ?1 AND NOW, this . S day of , tfi6 , 2011, upon consideration of Plaintiff' s Motion for Special Order Directing Service of its Civil Action by Posting and Certified Mail Pursuant to Pa. R.C.P. 430(a), it is hereby ORDERED AND DECREED that defendant ROBERT E. KERN shall be served by posting a copy of Plaintiff s Civil Action on the mortgaged premises, 210 SUSQUEHANNA AVENUE, ENOLA, PA 17025 and by sending a copy of same to defendant ROBERT E. KERN at his last known address being 210 SUSQUEHANNA AVENUE, ENOLA, PA 17025 by certified mail, return receipt requested and regular mail. BY THE COURT: J. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor r fl????1?, of 4tatuGrr(??r V 1. ?_, a P 'ti r H i 1 3 A 11 9: EE y?_aA ,'•U I tt Deutsche Bank National Trust Company Case Number vs. Robert E. Kern (et al.) 2010-7744 SHERIFF'S RETURN OF SERVICE 02/25/2011 04:05 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on February 25, 2011 at 1605 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Robert E. Kern, pursuant to order of court by posting the premises located at 210 Susquehanna Avenue, Enola, Cumberland County, Pennsylvania 17025 with a true and correct copy according to law. RO ERT BITNER, DEPUTY SHERIFF COST: $47.50 February 28, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF c; CountySute Sheaf ieleocso`t In: F 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 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) .E_D-li-f ICE p ? F riO OT ,rk I 11??1 ?'? fu eta-111 1 BERL a ID C0UP T'i' F'p~fiIN3YLVANIA IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Deutsche Bank National Trust Company, as trustee for the registered holders of Soundview Home Loan Trust 2006 EQ2 Asset-Backed Certificates, Series 2006-EQ2, by its attorney in fact, Ocwen Loan Servicing, LLC V. Robert E. Kern and Heather A. Troup Defendant(s) Civil Action Number: 10-7744 MORTGAGE FORECLOSURE PRAECIPE FOR ENTRY OF JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Enter judgment in favor of Plaintiff and against Defendant(s), Robert E. Kern and Heather A. Troup, for failure of said Defendant(s) to file a responsive pleading to the Complaint within twenty (20) days of service thereof. PRINCIPAL BALANCE .......................................................$65,859.22 INTEREST accrued thru 11/23/2010 of ...............................$2,331.88 Interest after 11/23/2010 shall accrue at the per diem rate of $16.39.) LATE CHARGES accrued thru 11/23/2010 of .....................$109.12 Late charges after 11/23/2010 shall accrue at the monthly rate of $54.56.) ESCROW ADVANCES ........................................................$586.67 J:\Supriya\Sales\Cumberland\Ocwen.Kem.04. l l .docx CV* 939kL3 • • FEES BILLED .......................................................................$121.50 LEGAL COSTS .....................................................................300.00 ATTORNEY'S FEE ..............................................................$3,300.00 Sub-Total Through Date of Complaint ............................$72,608.39 ACCRUED INTEREST after 11/23/2010 shall accrue at the per diem rate of $16.39 to April 14, 2011 ..............................................$2,327.38 ACCRUED LATE CHARGES Late charges after 11 /23/2010 accruing at the monthly rate of $54.56 through April 14, 2011 ...............................................$272.80 TOTAL DUE THROUGH DATE OF REQUEST FOR JUDGMENT .................................................................$75,208.57 STERN AND EISENBERG LLP B (;YARD F. STERN, ESQUI STEVEN K. EISENBERG, ESQUIRE KEVIN P. DISKIN, ESQUIRE Date: April 14, 2011 Attorney for Plaintiff J: \Supriya\Sales\Cumberland\Ocwen.Kem.04. l l .docx RICHARD F. STERN, ESQUIRE STEVEN K. EISENBERG, ESQUIRE KEVIN P. DISKIN, ESQUIRE 1+) {,? (? t, t a I A? . ; R STERN AND EISENBERG LLP THE PAVILION # P, >?I1 8 J 261 OLD YORK ROAD, SUITE 410 JENKINTOWN, PENNSYLVANIA 19046 r UtMGERLAFIU C0UNT TELEPHONE: (215) 572-8111 PENNSYLVANIA FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA Deutsche Bank National Trust Company, as trustee for the registered holders of Soundview Home Loan Trust 2006 EQ2 Asset-Backed Certificates, Series 2006-EQ2, by its attorney in fact, Ocwen Loan Servicing, LLC V. Robert E. Kern and Heather A. Troup Civil Action: 10-7744 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': Last-known address is Robert E. Kern: 210 Susquehanna Avenue, Enola, PA 17025 and Heather A. Troup: 1000 Good Hope Road, Mechanicsburg, PA 17050 2. Is over the age of twenty-one. 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. STERN AND EISENBERG LLP COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL HELEN CAPASSO, Notary Public Jenkintown Boro., Montgomery County My Commission Expires October 21, 2012 Sworn to and subscribed before me this Day of 4 2011. Notary Public FOR CUMBERLAND COUNTY BY: ? EVEN K. EISENBERG RICHARD F. STERN KEVIN P. DISKIN Attorney for Plaintiff J:\Supriya\Sales\Cumberland\Ocwen.Kem.04.1 I . docx } 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 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) 0- I?ILE tt 1CERE; 30 COUNT-( FENNSY(_V N, I IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Deutsche Bank National Trust Company, as trustee for the registered holders of Soundview Home Loan Trust 2006 EQ2 Asset-Backed Certificates, Series 2006-EQ2, by its attorney in fact, Ocwen Loan Servicing, LLC V. Robert E. Kern and Heather A. Troup Defendant(s) Civil Action: 10-7744 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 BY. y 7STTEVEN K. EISENBERG ARD F. STERN KEVIN P. DISKIN Attorney for Plaintiff J: \Supriya\Sales\Cumberland\Ocwen.Kern.04.1 I .docx F • 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 CUMBERLAND COUNTY Deutsche Bank National Trust Company, as trustee for the registered holders of Soundview Home Loan Trust 2006 EQ2 Asset-Backed Certificates, Series 2006-EQ2, by its attorney in fact, Ocwen Loan Servicing, LLC (Plaintiff) V. Robert E. Kern and Heather A. Troup Docket #: 10-7744 TEN DAY NOTICE NOTICE PURSUANT TO Pa.R.C.P. 237.1 TO: Heather A. Troupe Robert E. Kern 1000 Good Hope Road 210 Susquehanna Avenue Mechanicsburg, PA 17050 Enola, PA 17025 Date of Notice: Friday, April 1, 2011 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN 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 IMPORTANT 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 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 Bar Association 32 South Bedford Street Carlisle, PA 17013 800-990-9108 717-249-3166 S ENBERG, LLP_ By Kevin . Di$)rr' Esquire - - Attorney for Plaintiff J:\Angela\Ten Day\Cumberland\Ocwen.Kem.Troupe.4.11.docx 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 FAcsIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) it'., 110P4'Ol ? IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Deutsche Bank National Trust Company, as trustee for the registered holders of Soundview Home Loan Trust 2006 EQ2 Asset-Backed Certificates, Series 2006-EQ2, by its attorney in fact, Ocwen Loan Servicing, LLC V. Robert E. Kern and Heather A. Troup Defendant(s) Civil Action: 10-7744 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 BY- --?- EV N K. EISENBERG RICHARD F. STERN KEVIN P. DISKIN Attorney for Plaintiff J:\Supriya\Sales\Cumberland\Ocwen. Kem.04.1 I .docx RICHARD F. STERN, ESQUIRE STEVEN K. EISENBERG, ESQUIRE !y? !r ,, KEVIN P. DISKIN, ESQUIRE STERN AND EISENBERG LLP THE PAVILION € f t5 n? 261 OLD YORK ROAD, SUITE 410 JENKINTOWN, PENNSYLVANIA 19046 "a'LfINSCh'LAND COUNT" L ' E N!NI A" TELEPHONE: (215) 572-8111 S Y VA N N FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA Deutsche Bank National Trust Company, as trustee for the registered holders of Soundview Home Loan Trust 2006 EQ2 Asset-Backed Certificates, Series 2006-EQ2, by its attorney in fact, Ocwen Loan Servicing, LLC v. Robert E. Kern and Heather A. Troup FOR CUMBERLAND COUNTY MORTGAGE FORECLOSURE 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) Robert E. Kern 210 Susquehanna Avenue Enola, PA 17025 and and Heather A. Troup 1000 Good Hope Road Mechanicsburg, PA 17050 (Defendant(s)) STERN AND EISENBERG LLP BY: '- EN K. EISENBERG RICHARD F. STERN KEVIN P. DISKIN Attorney for Plaintiff Civil Action: 10-7744 J: \Supriya\Sales\Cumberland\Ocwen.Kem.04.11.docx IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Deutsche Bank National Trust Compan : ? Confessed Judgment Plaintiff P Other c: vs. File No. 10-7744 - Robert E. Kern and Heather A. Troup Defendant Address: 210 Susquehanna Avenue Enola, PA 17025 TO THE PROTHONOTARY" OF THE SAID COURT: Amount Due $75,208.57 Interest from 04/15/2011 at $16. . Atty's Comm Z c) Costs ca"i 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 County, for debt, interest and costs, upon the following described property of the defendant (s) 210 Susquehanna Avenue Enola, PA 17025 PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). 0 (Indicate) Index this writ against the garnishee (s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. ---? Date 04/14/2011 Signature: Print Name: evin P. Diskin S ?1.50 WF 4?. 50 u if 10 . DOS ?• ?y_ Cott k d. so %( u S F all Address: 261 Old York Road, The Pavilion. Suite 410 Jenkintown, PA 19046 Attorney for: Plaintiff Telephone: (215)572-8111 Supreme Court ID No: 86727 $ a, oa 15U C6 • 3 , $o L1. i _t ak,W, a39Y3 t4Ws'ra64 1 I 1 _' t n r 0 r ALL THAT CERTAIN tract or Parcel of land and premises, situate, lying and being in the township of East Pennsboro in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the Easterly line of Susquehanna Avenue, which point is ninety-nine and six hundred ninety-nine one-thousandths (98.699) feet North of the Northeasterly comer of Susquehanna Avenue and Dauphin Street; thence along the Easterly line of Susquehanna Avenue North (5) degrees nine (9) minutes thirty (30) seconds East twenty (20) feet to a point; thence further along the Easterly line of Susquehanna in an arc having a radius of seven hundred twenty-five (725) feet in a Northerly direction to the left thirty (30) feet to a point; thence through the center of a partition wall and beyond South eighty- seven (87) degrees twelve (12) minutes forty-five (45) seconds East one hundred fifty and seventu-five one-hundredths (150.75) feet to a point; thence South five (5) degrees nine (9) minutes thirty (30) seconds West fifty-six (56) feet to a point, the place of BEGINNING. BEING premises known as 210 Susquehanna Avenue. BEING the same premises which Gladys K. Rhodes, formerly known as Gladys K. Lenker and Gary C. Rhodes, wife and husband, by Deed dated October 3, 2006 and recorded October 25, 2006, in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 277 Page 1323, granted and conveyed unto Robert E. Kern and Heather A. Troup. PARCEL NO. 09-14-0832-131 J:\Supriya\Sales\Cumberland\Ocwen.Kem.04.11.docx RICHARD F. STERN, ESQUIRE STEVEN K. EISENBERG, ESQUIRE ?a r' ` I i, C ' KEVIN P. DISKIN, ESQUIRE r?. ruoN0TAR STERN AND EISENBERG LLP THE PAVILION a 4 A f f ; , f 261 OLD YORK ROAD, SUITE 410 JENKINTOWN, PENNSYLVANIA 19046 ` ?' C Ui j ?!? TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA Deutsche Bank National Trust Company, as trustee for the registered holders of Soundview Home Loan Trust 2006 EQ2 Asset-Backed Certificates, Series 2006-EQ2, by its attorney in fact, Ocwen Loan Servicing, LLC FOR CUMBERLAND COUNTY v. Robert E. Kern and Heather A. Troup Civil Action: 10-7744 MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 1, 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 21.0 Susquehanna Avenue, Enola, PA. 1. Name and address of Owner(s) or Reputed Owner(s): Robert E. Kern 210 Susquehanna Avenue Enola, PA 17025 and and Heather A. Troup 1000 Good Hope Road Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: Robert E. Kern 210 Susquehanna Avenue Enola, PA 17025 and and Heather A. Troup 1000 Good Hope Road Mechanicsburg, PA 17050 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: J:\Supriya\Sales\Cumberland\Ocwen.Kem.04. l I.docx N/A 4. Name and address of the last recorded holder of every mortgage of record: MERS, Inc., as nominee for Equifirst Corporation 500 Forest Point Circle Charlotte, NC 28273 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 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 210 Susquehanna Avenue Enola, PA 17025 and 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 unswom falsification to authorities. Date: April 14, 2011 Sworn o and subscribed b fore me this Day of 2011. Notary Pub rc J:\Supriya\Sales\Cumberland\Ocwen.Kem.04. I l .docx STERN AND EISENBERG LLP BY: ` EVEN K. EISENBERG RICHARD F. STERN KEVIN P. DISKIN Attorney for Plaintiff COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL HELEN CAPASSO, Notary Public Jenkintown Boro., Montgomery County My Commission Expires October 21, 2012 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 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA Deutsche Bank National Trust Company, as trustee for the registered holders of Soundview Home Loan Trust 2006 EQ2 Asset-Backed Certificates, Series 2006-EQ2, by its attorney in fact, Ocwen Loan Servicing, LLC FOR CUMBERLAND COUNTY V. Robert E. Kern and Heather A. Troup Civil Action: 10-7744 MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Robert E. Kern 210 Susquehanna Avenue Enola, PA 17025 and and Heather A. Troup 1000 Good Hope Road Mechanicsburg, PA 17050 Your real estate at 210 Susquehanna Avenue, Enola, PA is scheduled to be sold at Sheriffs Sale on Wednesday, September 7, 2011 at 10:00 A.M., at Sheriffs Office, Cumberland County Courthouse, Carlisle, PA 17013 (location of sale) to enforce the court judgment of $75,208.57 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 Sheriff s 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 (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. J:\Supriya\Sales\Cumberland\Ocwen.Kem.04.1 Ldocx 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 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 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 Sheriff s 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\Cumberland\Ocwen.Kem.04.11.docx 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 :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 Soundview Home Loan Trust 2006 EQ2 Asset-Backed Certificates, Series 2006-EQ2, by its attorney in fact, Ocwen Loan Servicing, LLC V. Robert E. Kern and Heather A. Troup Civil Action: 10-7744 MORTGAGE FORECLOSURE RE: PREMISES: 210 Susquehanna Avenue, Enola, 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, September 7, 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 $75,208.57 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 Sheriffs 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. April 14, 2011 STERN AND EISENBERG LLP BY: VEN K. EISENBERG CHARD F. STERN KEVIN P. DISKIN Attorney for Plaintiff J:\Supriya\Sales\Cumberland\Ocwen.Kem.04.11.docx ALL THAT CERTAIN tract or Parcel of land and premises, situate, lying and being in the township of East Pennsboro in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the Easterly line of Susquehanna Avenue, which point is ninety-nine and six hundred ninety-nine one-thousandths (98.699) feet North of the Northeasterly corner of Susquehanna Avenue and Dauphin Street; thence along the Easterly line of Susquehanna Avenue North (5) degrees nine (9) minutes thirty (30) seconds East twenty (20) feet to a point; thence further along the Easterly line of Susquehanna in an are having a radius of seven hundred twenty-five (725) feet in a Northerly direction to the left thirty (30) feet to a point; thence through the center of a partition wall and beyond South eighty- seven (87) degrees twelve (12) minutes forty-five (45) seconds East one hundred fifty and seventu-five one-hundredths (150.75) feet to a point; thence South five (5) degrees nine (9) minutes thirty (30) seconds West fifty-six (56) feet to a point, the place of BEGINNING. BEING premises known as 210 Susquehanna Avenue. BEING the same premises which Gladys K. Rhodes, formerly known as Gladys K. Lenker and Gary C. Rhodes, wife and husband, by Deed dated October 3, 2006 and recorded October 25, 2006, in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 277 Page 1323, granted and conveyed unto Robert E. Kern and Heather A. Troup. PARCEL NO. 09-14-0832-131 J:\Supriya\Sales\Cumberland\Ocwen.Kem.04.1 l .docx RICHARD F. STERN, ESQUIRE STEVEN K. EISENBERG, ESQUME KEVIN P. DISKIN, ESQUIRE '' D Q t ,; ,'l` STERN AND EISENBERG LLP , LJ h? THE PAVILION I F, ? ` IIJ i 261 OLD YORK ROAD, SUITE 410 JENKINTOWN PENNSYLVANIA 19046 , TELEPHONE: (215) 572-8111 VA N l A 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 Soundview Home Loan Trust 2006 EQ2 Asset-Backed Certificates, Series 2006-EQ2, by its attorney in fact, Ocwen Loan Servicing, LLC V. Robert E. Kern and Heather A. Troup Cavil Action: 10-7744 MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Robert E. Kern 210 Susquehanna Avenue Enola, PA 17025 and and Heather A. Troup 1000 Good Hope Road Mechanicsburg, PA 17050 Your real estate at 210 Susquehanna Avenue, Enola, PA is scheduled to be sold at Sheriffs Sale on Wednesday, September 7, 2011 at 10:00 A.M., at Sheriff s Office, Cumberland County Courthouse, Carlisle, PA 17013 (location of sale) to enforce the court judgment of $75,208.57 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 (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. J:\Supriya\Sales\Cumberland\Ocwen.Kem.04.I Ldocx 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 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 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\Cumberland\Ocwen.Kern.04.11.docx ALL THAT CERTAIN tract or Parcel of land and premises„ situate, lying and being in the township of East Pennsboro in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the Easterly line of Susquehanna Avenue, which point is ninety-nine and six hundred ninety-nine one-thousandths (98.699) feet North of the Northeasterly comer of Susquehanna Avenue and Dauphin Street; thence along the Easterly line of Susquehanna Avenue North (5) degrees nine (9) minutes thirty (30) seconds East twenty (20) feet to a point; thence further along the Easterly line of Susquehanna in an arc having a radius of seven hundred twenty-five (725) feet in a Northerly direction to the left thirty (30) feet to a point; thence through the center of a partition wall and beyond South eighty- seven (87) degrees twelve (12) minutes forty-five (45) seconds East one hundred fifty and seventu-five one-hundredths (150.75) feet to a point; thence South five (5) degrees nine (9) minutes thirty (30) seconds West fifty-six (56) feet to a point, the place of BEGINNING. BEING premises known as 210 Susquehanna Avenue. BEING the same premises which Gladys K. Rhodes, formerly known as Gladys K. Lenker and Gary C. Rhodes, wife and husband, by Deed dated October 3, 2006 and recorded October 25, 2006, in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 277 Page 1323, granted and conveyed unto Robert E. Kern and Heather A. Troup. PARCEL NO. 09-14-0832-131. J:\Supriya\Sales\Cumberland\Ocwen.Kem.04.1 l.docx WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-7744 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY Plaintiff (s) From ROBERT E. KERN AND HEATHER A. TROUP (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 $75,208.57 L.L.$.50 Interest FROM 4/15/11 AT $16.39 Atty's Comm % Due Prothy $2.00 Atty Paid $261.50 Other Costs Plaintiff Paid Date: 411$111 I avid D. Buel , Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: KEVIN P. DISKIN, ESQUIRE Address: STERN AND EISENBERG LLP 261 OLD YORK ROAD, THE PAVILLION, 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 Soundview Home Loan Trust 2006 EQ2 Asset-Backed Certificates, Series 2006-EQ2, by its attorney in fact, Ocwen Loan Servicing, LLC v. Robert E. Kern and Heather A. Troup Defendant(s) f.. CD r ---t c;) ?v °-n ? o .- o c? yc - ?M Civil Action Number: 10-7744 Civil Term 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 and regular mail on July 5, 2011, pursuant to court order as evidenced by copy of said order, certified mail receipts and certificates of mailing attached. I further certify that notice of the Sheriff's Sale was mailed to each lienholder by regular, first-class, postage prepaid mail on July 5, 2011, as evidenced by copy of certificates of mailing attached. 7/5/11 STERN AND EISENBERG LLP BY: IN P. DISKIN Attorney for Plaintiff S COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW Deutsche Bank National Trust Company, As Trustee, By its attorney in fact, Ocwen Loan Servicing, LLC VS. ROBERT E. KERN AND HEATHER A. TROUP : NO. 10-7744 CIVIL TERM ORDER AND NOW, this /)"' - day of :?KC , 2011, upon consideration of Plaintiff' s Motion for Special Order Directing Service of its Civil Action by Posting and Certified Mail Pursuant to Pa. R.C.P. 430(a), it is hereby ORDERED AND DECREED that defendant ROBERT E. KERN shall be served by posting a copy of Plaintiff s Civil Action on the mortgaged premises, 210 SUSQUEHANNA AVENUE, ENOLA, PA 17025 and by sending a copy of same to defendant ROBERT E. KERN at his last known address being 210 SUSQUEHANNA AVENUE, ENOLA, PA 17025 by certified mail, return receipt requested and regular mail. BY THE COURT: J. 1 0N F? Y `a r? O O aka a 69 o • W m LL LLm m m Cfj O U e m r U 2 U ¢ Wf 14. r,y ,. ._ c cm 'aEi ° m m 0? m mE o jN i9S5 h6 jq hD m v w ¢c f°- w .e:m ti Cl) c mO;n m ;v4 , 20p0 060E ?T04 m }q ? m m m? a a? 0 m? m ?m m D m LL p - ? h ° . mQ _ m m U ¢m mQ ' m ?m m lz c ?m m` mm o cN _ a N iak .¢ o m C W N O m? 2 H Lll C : d Q. ? :? O U-55 h6TV 2000 060E OTOZ 9 061 3400 diZV408-4 LWz so lnr Z9L9 oIV6'Z00 $ 63MOS A3Nlld .ti o r. ? w coo y ,., z ? _ A w _ N ~ p ?c Oo J O? cn A w t".) r _. C G ? o " O o Y o z ??J x CD ?,) c a w CD Y, rn 0 -n a R CD o o ? rn v1D, O ? ? y '-h o N < R CD o _ O ? C7 < CD ^ C -? a o o a ? ? to m a. ? " 'nom x CD s? FD o CD a a ° < a m ? J ro o o a c CD _ CD z a C o o o a o < CD o o 00 a CD CD O tQ , x f» a 00 o CD , 5 ?. x CD o N N O 00 N W W O fM 06000 dl Zo M c Z ? a z f9 p 'S G Cr N V1 r ? O? ?.az A H b 0 A 0 G yd}, bl? 'ZS'od 6 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff OFF t.P -F -P "E"IFF 1- PH L": E £11 i Jody S Smith Chief Deputy Richard W Stewart Solicitor Deutsche Bank National Trust Company I vs. Robert E. Kern (et al.) Case Number 2010-7744 SHERIFF'S RETURN OF SERVICE 06/20/2011 11:27 AM - Deputy Stephen Bender, 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 210 Susquehanna Avenue, Enola, PA 17025, Cumberland County. 06/20/2011 11:27 AM - Deputy Stephen Bender, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Robert E. Kern, pursuant to Order of Court by "Posting" the premises located at 210 Susquehanna Avenue, East Pennsboro Township, Enola, PA 17025, Cumberland County with a true and correct copy according to law. 06/20/2011 11:52 AM - 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: Heather A. Troup, 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 1000 Good Hope Road, Mechanicsburg, PA 17050. 07/01/2011 04:47 PM - Deputy Shawn Harrison, 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 ONIX REYES - BOYFRIEND, who accepted as "Adult Person in Charge" for Heather A. Troup at 5340 Oxford Circle, Apt 52, Mechanicsburg, PA 17055, Cumberland County. 09/07/2011 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, Carlisle, Cumberland County, PA on September 7, 2011 at 10:00 a.m.. He sold the same for the sum of $1.00 to Attorney Kevin Diskin, on behalf of, Deutsche Bank National Trust Company, et. al. of, 1661 Worthington Road, Suite 100, West Palm Beach, FL 33409, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $905.29 SO ANSWERS, October 11, 2011 RON RANDERSON, SHERIFF r0.c'0fd. z 5`3??s 2 6 S- - cj Goun`y3uito Sher!ft. Tieleosott. Inc, ' ' - r 1 On May 11, 2011 the Sheriff levied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, PA, Known and numbered as, 210 Susquehanna Avenue, Enola, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 11, 2011 By: Real Estate Coordinator CUMBERLAND LAW JOURNAL Writ No. 2010-7744 Civil Deutsche Bank National Trust Company vs. Robert E. Kern Heather A. Troup Atty.: Kevin P. Diskin ALL THAT CERTAIN tract or Parcel of land and premises, situ- ate, lying and being in the township of East Pennsboro in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the Easterly line of Susquehanna Av- enue, which point is ninety-nine and six hundred ninety-nine one- thousandths (98.699) feet North of the Northeasterly corner of Susque- hanna Avenue and Dauphin Street; thence along the Easterly line of Susquehanna Avenue North (5) degrees nine (9) minutes thirty (30) seconds East twenty (20) feet to a point; thence further along the Easterly line of Susquehanna in an arc having a radius of seven hundred twenty-five (725) feet in a Northerly direction to the left thirty (30) feet to a point; thence through the center of a partition wall and beyond South eighty-seven (87) degrees twelve (12) minutes forty-five (45) seconds East one hundred fifty and seventu-five one-hundredths (150.75) feet to a point; thence South five (5) degrees nine (9) minutes thirty (30) seconds West fifty-six (56) feet to a point, the place of BEGINNING. BEING premises known as 210 Susquehanna Avenue. BEING the same premises which Gladys K. Rhodes, formerly known as Gladys K. Lenker and Gary C. Rhodes, wife and husband, by Deed dated October 3, 2006 and recorded October 25, 2006, in the Office of the Recorder of Deeds in and for Cumber- land County in Deed Book 277 Page 1323, granted and conveyed unto Robert E. Kem and Heather A. Troup. PARCEL NO. 09-14-0832-131. 38 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 15, July 22 and July 29, 2011 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Lisa Marie Coyn Editor SWORN TO AND SUBSCRIBED before me this day of Jul 2011 ^ Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE f Patriot News Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 07/15/11 07/22/11 07/29/11 ......... G,.. Sworn to an scribed before s 18 f August, 2011 A. D. - Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L Kl ner, Notary Pubilc 7 Lower Paxton Twp., Dauphin County My Commission Expires Nov. 26, 2011 Member Penns?Averia Association of Notaries MO-7744 04 TOM Dwbeb 1111001 towamd TWO co"Pany vs Robwt E Kam , A. Atlp Kw A* P-=In ALL THAT CERTAIN tract or Parcel of land and premises, situate, b* and being in the township of East PeWL in the County of Cumberland and Commonwealth of Pennsylvania, moil particularly described as follows: BEGWN NG at aj)oiot ostho Easterly line of Susquehanna Avemte, which point is ' eine"W ones *84AW ft* Of tl1e 1?11?1lwi?r ne?±rx±?f?Qauas.t?* Aveaataaodl tilpaRtiaeaedong the Edsa*hhiac paiiaeea Avenue North (S) deem Woe (9) minutes thirty (30) sew East twenty (20) 4-to a point; thence further along the Easterly tine of Susquehamta in an we hat>oga raalius of seven hundred twenty-five (725) feet in a Northerly direction to the left thirty (30) feet to a point; them through the center of a partition wall and beyond South eighty- seven (87) degrees twelve (12) minutes forty-five (45) seconds East one hundred fifty and seventu-five one-hundredths (150.75) feet to a point; thence South five (5) degrees nine (9) minutes thirty (30) seconds West fifty-six (56) feet to a point, the place ofBEGINNING. BEING premises known as 210 Susquehanna Avenue. BEING the same premises which Gladys K Rhodes, formerly known as Gladys K _i eker and Gary C. Rhodes, wife and h?lry Deed dated October 3, 2006 and i=ded October 25, 2006, in the office of the Recorder of Deeds in and for Cumberland County in Deed Book 277 Page 1323, granted and convoyed unto Robert E. Kern and Headier A. Roup. PARCEL NO.09-14 32-131. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Registered Holders of Soundview Home Loan Trust 2006-EQ2 is the grantee the same having been sold to said grantee on the 7th day of September A.D., 202011, under and by virtue of a writ Execution issued on the 18th day of Aril, A.D., 202011, out of the Court of Common Pleas of said County as of Civil Term, 2010 Number 7744, at the suit of Registered Holders of Soundview Home Loan Trust 2006-EQ2 against Robert E. Kern and Heather A. Troup is duly recorded as Instrument Number 201128274. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ?1 day of A.D. of Deeds Recorder of Deedsumberland County, Carlisle, PA My Commission res the First Monday of Jan. 2014