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HomeMy WebLinkAbout11-1719 i .. 3 1 I L. 4J r1 ; Z l . 'D ? .> . .. E .m 4 e McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 The Bank of New York Mellon formerly known as The Bank of New York as successor Trustee to JPMorgan Chase Bank, National Association as Trustee for the Certificateholders of Structured Asset Mortgage Investments II Inc. Bear Stearns ALT-A Trust, Mortgage Pass-Through Certificates Series 2005-10 2780 Lake Vista Drive Lewisville, Texas 75067 V. Geoffrey T. Cragg Lot # 67 Monroe Acres a/k/a 308 Widders Drive Mechanicsburg, Pennsylvania 17055 Attorneys for Plaintiff Cumberland County Court of Common Pleas Number // 0/ff CIVIL ACTION/MORTGAGE FORECLOSURE 0? 141,I-l# l 3 a 3s7 t#hj '#70"44j"c 4NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demands en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMATION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARR EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 CIVIL ACTION/MORTGAGE FORECLOSURE 1. Plaintiff is The Bank of New York Mellon formerly known as The Bank of New York as successor Trustee to JPMorgan Chase Bank, National Association as Trustee for the Certificateholders of Structured Asset Mortgage Investments H Inc. Bear Stearns ALT-A Trust, Mortgage Pass-Through Certificates Series 2005-10, a corporation duly organized and doing business at the above captioned address. 2. The Defendant is Geoffrey T. Cragg, who is the mortgagor and real owner of the mortgaged property hereinafter described, and his/her last-known address is Lot # 67 Monroe Acres a/k/a 308 Widders Drive, Mechanicsburg, Pennsylvania 17055. 3. On July 15, 2005, mortgagor made, executed and delivered a mortgage upon the premises hereinafter described to Mortgage Electronic Registration Systems, Inc., as nominee for Aegis Wholesale Corporation which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1915, Page 2272. 4. The aforesaid mortgage was thereafter assigned by Mortgage Electronic Registration Systems, Inc., as nominee for Aegis Wholesale Corporation to The Bank of New York Mellon formerly known as The Bank of New York as successor Trustee to JPMorgan Chase Bank, National Association as Trustee for the Certificateholders of Structured Asset Mortgage Investments II Inc. Bear Stearns ALT-A Trust, Mortgage Pass-Through Certificates Series 2005-10 , by Assignment of Mortgage, to be duly recorded in the Office of the Recorder of Cumberland County. 5. The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as Lot # 67 Monroe Acres a/k/a 308 Widders Drive, Mechanicsburg, Pennsylvania 17055. 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due February 1, 2010 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 7. The following amounts are due on the mortgage: Principal Balance $ 177,596.96 Interest through February 7, 2011 $ 13,480.35 (Plus $33.45 per diem thereafter) Attorney's Fee $ 1,250.00 Late Charges $ 428.60 Escrow Advance $ 2,274.52 GRAND TOTAL $ 195,030.43 8. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendant by regular mail with a certificate of mailing and by certified mail, return receipt requested. A copy of the EMC Homeowner's Packet for EMC Customers is attached hereto and labeled as Exhibit "B". WHEREFORE, Plaintiffdemands in rem Judgment against the Defendant in the sum of $195,030.43, together with interest at the rate of $33.45 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. McCABE, WEISBERG AND CONWAY,P.C. BY. Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative, who is out of jurisdiction and not available to sign this verification at this time, and are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. McCABE, WEISBERG AND CONWAY,P.C. BY: Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE The Bank of New York Mellon formerly known as The Bank of New York as successor Trustee to JPMorgan Chase Bank, National Association as Trustee for the Certificateholders of Structured Asset Mortgage Investments II Inc. Bear Stearns ALT-A Trust, Mortgage Pass-Through Certificates Series 2005-10 v. Geoffrey T. Cragg COMMITMENT FOR TITLE INSURANCE SCHEDULE A (continued) File No. 2010-9004 LEGAL DESCRIPTION ALL THAT CERTAIN tract or Parcel of land and premises, situate, lying and being in the Township of Monroe in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the North side of Widders Drive, a 50 foot wide street; thence along Lot No. 68, North 26 degrees 10 minutes 40 seconds West, 145.92 feet to a point at Lot No. 76; thence along Lot No. 76; thence along Lot No. 76, North 60 degrees 44 minutes 22 seconds East, 103.68 feet to a point at lands now or formerly of Henry M. Thomton; thence along the last mentioned lands, South 30 degrees 30 seconds 20 minutes East, 151.93 feet to a point on the Northern side of Widders Drive; thence along the Northern side of Widders Drive, South 63 degrees 49 minutes 20 seconds West, 115 feet to a point on the Northern side of Widders Drive and Lot No. 68, being the Place of BEGINNING. BEING Lot No. 67 of Monroe Acres as shown on Section C, in accordance with a survey of Larsen and Brilhart, Inc., registered Surveyors, dated March 10, 1971 and recorded in Plan Book 22, Page 98. HAVING THEREON ERECTED a brick and aluminum two story dwelling numbered 308 Widders Drive. Being the same property acquired by Geoffrey T. Cragg, by Deed recorded 07/21/2005, of record in Deed Book 269, Page 5106, in the Office of the Recorder of Cumberland County, Pennsylvania. NSA Schedule A - Page 2 of 2 File #: 2010-9004 - REO America Abstract Co. ALTA Commitment (6-17-06) - TIRBOP & STG modifications (4-1-07) ?- 7 e a L title guaranty company hNlu NorfRage Corporation In order for us to evaluate your request you must complete the enclosed packet and fax or mail it to EMC with the required documentation. Please keep a copy for your records. This packet contains the following items that must be completed, in full, in order for your evaluation request to be completed in a timely manner: Section 1. Required Documentation for Borrower and Co-Borrower Checklist - Detailed list of the documents you must send to us in addition to the packet Section 2. Financial Information Form - Provides information about your property, loans, income, etc. Section 3. Home Affordable Modification Program Hardship Affidavit - Explains the circumstances that have made it difficult for you to stay up-to-date with your mortgage payments Section 4.4506T-EZ Request for Transcript of Tax Return Form - Allows EMC to receive a transcript of your tax return to verify income information If you need any assistance completing this packet please contact us at 800-723-3004. Please send the completed packet as well as all required documentation to EMC: By Regular Mail: By Overnight Mail: EMC Fulfillment Center EMC Fulfillment Center P.O. Box 469030 4500 Cherry Creek Drive South Glendale, CO 80246 Suite #100 Glendale, CO 80246 By Fax: 866-282-5682 Important Information EMC Mortgage Corporation is attempting to collect a debt, and any information obtained will be used for that purpose. We may report information about your account to credit bureaus. Late payments, missed payments, or other defaults on your account may be rejected in your credit report. If you are represented by an attorney, please refer this letter to your attorney and provide us with the attorney's name, address, and telephone number. If you are currently a debtor in bankruptcy proceedings and subject to the protections of the automatic stay, or if you have received a final discharge in a bankruptcy, this notice is for compliance and/or informational purposes only and not an attempt to impose personal liability for the debt in violation of the bankruptcy laws. However, EMC Mortgage Corporation still has the right under the mortgage to foreclose on the Property. An Important reminder for all our customers: As stated in the "Questions and Answers for Borrowers about the Homeowner Affordability and stability Plan" distributed by the Obama Administration, "Borrowers should beware of arty organhation that attempts to charge a fee for housing counseling or modification of a delinquent loan, especially If they require a fee In advance." EMC offers loan modification assistance free of charge (i.e., no modification fee required). Please call us immediately at 800-723-3004 to discuss your options. The longer you delay the fewer options you may have. 8705K EMCCVR-12-18-09 Borrower(s) Name(s): Loan Number(s): ? Owner Occupied ? Non-Owner Occupied EMC' uoriaag. C?rprra a-a SECTiQhI 1 iequ?DcC ° R}iov?r ar?d Eo borrower If you are a Wage Earner (you received a W-2 from your employer) please use the following checklist: ? Two (2) most recent Pay Stubs (two for each borrower) Length of service with Current Employer. Borrower Year(s): Month(s): Co-Borrower Year(s): Month(s): ? Most recent one (1) month's of Complete Bank Statement (must provide all pages) ? Most recent statement(s) supporting assets listed on page 2 of the Financial Information Form (must provide all pages of statements) ? Most recent Tax Return Completed (signed with all pages) or most recent filed and proof of extension (signed with all pages) ? Proof of Income for other household members living in the home (Alimony, Child Support, Pension, etc.) if you want such income considered for a loan workout ? Proof of any other Income received (Alimony, Rental, Child Support, Pension, etc.) ? Proof of occupancy -a recent utility bill in your name at property address ? Proof of payment of Homeowner's Association Fees (if applicable) ? If loan is Non-Escrowed A) Copy of the most recent property tax bill(s) with a copy of the canceled check for all applicable taxes (County, City, School, etc.) B) Copy of the current insurance declaration page for all applicable coverage types (must show premium amount for homeowners, flood, and wind) ? Non-Owner Occupied (ONLY) A) Rental Income with copies of Rental Agreement B) Principal, Interest, Taxes, and Insurance for Primary Residence $ C) Mortgage Holder(s) for Primary Residence D) Primary Residence Address (input below) ? Completed Financial Information Form (enclosed) ? Completed Hardship Affidavit (enclosed) -completed and signed by all Borrowers (no notary required) ? Completed 4506-T EZ Form - Request for Transcript of Tax Return (enclosed). Be sure to sign and date this form. If you are Self Employed, please use the following checklist: ? P & L Statement / Audited or reviewed YTD Income Statement (must provide) ? Most recent two (2) years Tax Returns Completed (personal and business, signed with all pages) or 1099s or most recent two (2) years filed and proof of extension ? Last four (4) months of complete Business and Personal Bank Statements (must provide all pages. If a business account is not used, provide a written statement stating a business account is not used.) ? Most recent statement(s) supporting assets listed on page 2 of the Financial Information Form (must provide all pages of statements) ? Length of time of Business Ownership: Borrower Year(s): Month(s): Co-Borrower Year(s): Month(s): ? Proof of Income for other household members living in the home (Alimony, Child Support, Pension, etc.) if you want such income considered for a loan workout ? Proof of any other Income received (Alimony, Rental, Child Support, Pension, etc.) ? Proof of occupancy -a recent utility bill in your name at property address ? Proof of payment of Homeowner's Association Fees (if applicable) ? If loan is Non-Escrowed A) Copy of the most recent property tax bill(s) with a copy of the canceled check for all applicable taxes (County, City, School, etc.) B) Copy of the current insurance declaration page for all applicable coverage types (must show premium amount for homeowner's, flood, and wind) ? Non-Owner Occupied (ONLY) A) Rental Income with copies of Rental Agreement B) Principal, Interest, Taxes, and Insurance for Primary Residence $ C) Mortgage Holder(s) for Primary Residence D) Primary Residence Address (input below) ? Completed Financial Information Form (enclosed) ? Completed Hardship Affidavit (enclosed) -completed and signed by all Borrowers (no notary required) ? Completed 4506-T EZ Form - Request for Transcript of Tax Return (enclosed). Be sure to sign and date this form. Primary Address: Comments: EMCCHKLST 12-18.09 EMC Loan Number: SECTION 2: Financial Information Form Page 1 of 3 E"C0VWW"1"r@MVu19yQ11rhWW loon answer questions as y accurate pass a This k#b madm will only be used to akin the evaf &"Wim of opdom not foranyother pose. Borrower Co-Borrower Name (Include Jr. or Sr. if applicable) Name (Include Jr. or Sr. if applicable) Social Security Number Soda[ Security Number Home Phone ( ) Best Time to Cal Home Phone ( ) Best Time to Call: Work Phone ( ) Best Time to Call: Work Phone ( ) Best Time to Call: Other Phone ( ) Best Time to gall: Other Phone ( ) Best Time to Call: E-mail Address E-mail Address Permission to Contact Via E-mail? ? Yes ? No Permission to Contact Via E-mail? ? Yes ? No Marital Status Marital Status ? Unmarried ? Married ? Separated ? Divorced ? Unmarried ? Married ? Separated ? Divorced Property Address (street, city, state & rip code) Mailing Address (If different than Property Address) Reside at Property? Want to Retain Property? # of People in Household # of Dependents ? Borrower ? Co-Borrower ? Yes ? No # of Units at Property Property Condition? Is the Property for sale? Listing Amount: ? Good ? Fair ? Poor ? Yes ? No $ Realtor Name Realtor Address Realtor Phone Loan Account Number Months Past Due Second Loan Account Number Second Loan Months Balance Past Due Mortgage Com $ Are you currently working with EMC on a foreclosure Which foreclosure resolution is in process? prevention resolution? ? Refinance ? Repayment Plan ? Short Sale ? Yes ? No ? Modification ? Deferment ? Deed-in-Lieu EMC Associate Name EMC Associate Phone Date Process Began V 'A IJyouan M an acUUebanb?tcy, wM wglneed to wnk wlrhyarattaroyon a pors?le nsoludon. Are you in an Active Bankruptcy? Bankruptcy Chapter Type Bankruptcy Case Number Date of Bankruptcy Filing ?Yes ?No Bankruptcy Associate Name Bankruptcy Attorney Address Bankruptcy Attorney Phone Ell Borrower Co-Borrower Employer 7 mploer y Employer Address Address Employ yer Employer Phone How long Self Employed? Employer Phone How long Self Employed? employed? ?Yes ?No ( ) employed? ?Yes ?No EMCFIF 12-18-09 EMC' ?r,,.rf„?, rb.pon,ri?.. Borrower Name: Loan Number: SECTION 2: Financial Information Form Page 2 of 3 QRS Borrower Co-Borrower Income Source (Employer Name, Rental etc) Monthly Gross Income Income Source (EmployerName? Renta4 etc) Monthly Gross Income Employer. $ Employer $ Employer: $ Employer. $ Employer: $ Employer. $ Employer: $ Employer. $ Rental Income: $ Rental Income: $ Other. $ Other. $ Other: $ Other. $ Total $ Total $ Borrower / CO-Borrower Additional Income Description Alimony, childsupporC orseparate maintenance income need not be revealedtjBorrowerorCo-Borrowerdoesnotchoose tohave itconsidered for approval of a loan workout. Monthly Amount Total $ y Asset Amount Owed Value Vehicle Model/Year Amount Owed Value Home $ $ Automobile $ $ Other Real Estate $ $ Automobile $ $ Retirement Funds $ $ Automobile $ $ Investments $ $ Motorcycle $ $ Checking Balance $ $ Boat $ $ Savings Balance $ $ Motor Home $ $ Other: $ $ Airplane $ $ Other. $ $ Other. $ $ Other. $ $ Other: S $ Total $ $ Total $ $ EMCFIF 12-18-09 EMC- 1rurlRn?r ('urr,urnfiun Borrower Name: Loan Number: SECTION 2: Financial Information Form Page 3 of 3 y, t t e .. .: ± ryrnV! q .,.t. 5c Monthly Expense Borrower Co-Borrower Other Home Loans, Rents & liens $ $ Auto Loan(s) $ $ Auto Insurance & Other Auto Expenses $ $ Credit Cards & Installment Loans $ $ Health Insurance $ $ Medical Expenses $ $ Child Care, Child Support & Alimony $ $ Food $ $ Miscellaneous Spending Money $ $ Utilities $ $ Communications $ $ (Phone Cell Phone, Internet) Other $ $ TOTAL $ $ lagree that the financial information provided Is true and accurateasof the dateset forth opposite myslgnature and that any intentional or negligent misrepresentation of the information contained in this document mayresult in civil liability, including monetary damages, to anyperson who may suffer any loss due to reliance upon the document; and/orin criminal penalties including but not limited to fine or imprisonment or both under the provisions of Title 18 United States Code, Sec. 1001, etseq. I understand and acknowledge that anyaction taken by the lender is in strict reliance on the financial information provided. My signature/acceptance belowgrants the holder of mymortgage or its designee the authority to confirm the information that I have disclosed in this financial statement, to verify it as accurate by ordering a credit report and to contact myrealtorand/or credit counseling service. By providing a wireless telephone number, you consent to receiving autodialed and pre-recorded message calls from the lender or its third-party debt collectorat that number. Irepresentthat ?lam ? I am not currently occupying the property securing the loan asmypdmary residence and thatI intend to continue occupying the propertyas my primary residence. Borrower Signature Date Co-Borrower Signature Date EMCFIF 12-18-09 SECTION 3: Home Affordable Modification Program Hardship Affidavit Borrower Name (first, middle, last): _ Co-Borrower Name (first, middle, last): Property Street Address: Property City, State and ZIP: Servicer: Loan Number: In order to qualify for 's ("Servicer") offer to enter into an agreement to modify my loan under the federal government's Home Affordable Modification Program (the "Agreement"), I/we am/are submitting this form to the Servicer and indicating by my/our checkmarks ("?") the one or more events that contribute to my/our difficulty making payments on my/our mortgage loan. Borrower Co-Borrower Yes No Yes No My income has been reduced or lost. For example: unemployment, ? ? ? ? underemployment, reduced job hours, reduced pay, or a decline in self-employed business earnings. I have provided details under "Explanation" (page 3). Yes No Yes No My household financial circumstances have changed. For example: death in family, ? ? ? ? serious or chronic illness, permanent or short-term disability, increased family responsibilities (adoption or birth of a child, taking care of elderly relatives or other family members). I have provided details under "Explanation" (page 3). Yes No Yes No My expenses have increased. For example: monthly mortgage payment has ? ? ? ? increased or will increase, high medical and health-care costs, uninsured losses (such as those due to fires or natural disasters), unexpectedly high utility bills, increased real property taxes. I have provided details under "Explanation" (page 3). Yes No Yes No My cash reserves are insufficient to maintain the payment on my mortgage loan ? ? ? ? and cover basic living expenses at the same time. Cash reserves include assets such as cash, savings, money market funds, marketable stocks or bonds (excluding retirement accounts). Cash reserves do not include assets that serve as an emergency fund (generally equal to three times my monthly debt payments). I have provided details under "Explanation" (page 3). Yes No Yes No My monthly debt payments are excessive, and I am overextended with my ? ? ? ? creditors. I may have used credit cards, home equity loans or other credit to make my monthly mortgage payments. I have provided details under "Explanation" (page 3). Yes No Yes No There are other reasons I/we cannot make our mortgage payments. I have ? ? ? ? provided details under "Explanation" (page 3). Date of Birth: Date of Birth: Page 1 of 4 HIFAFF-0909 Borrower Name: Loan Number: Information for Government Monitoring Purposes The following information is requested by the federal government in order to monitor compliance with federal statutes that prohibit discrimination in housing. You are not required to furnish this information, but are encouraged to do so. The law provides that a lender or servicer may not discriminate either on the basis of this information, or on whether you choose to furnish it. If you furnish the information, please provide both ethnicity and race. For race, you may check more than one designation. If you do not furnish ethnicity, race, or sex, the lender or servicer is required to note the information on the basis of visual observation or surname if you have made this request for a loan modification in person. If you do not wish to furnish the information, please check the box below. BORROWER CO-BORROWER ? I do not wish to furnish this information ? I do rat wish to furnish this information Ethnicity: ? Hispanic or Latino Ethnicity: ? Hispanic or Latino ? Not Hispanic or Latino ? Not Hispanic or Latino Race: ? American Indian or Alaska Native Race: ? American Indian or Alaska Native ? Asian ? Asian ? Black or African American ? Black or African American ? Native Hawaiian or Other Pacific Islander ? Native Hawaiian or Other Pacific Islander ? White ? White Gender: ? Female Gender: ? Female ? Male ? Male To be completed by Interviewer ? Face-to-face interview Interviewer's Name and Phone Number Interviewer's Signature ? Mail (print or type) ? Telephone ? Internet Date Name and Address of Interviewer's Employer Borrower/Co-Borrower Acknowledgement 1. Under penalty of perjury, I/we certify that all of the information in this affidavit is truthful and the event(s) identified above has/have contributed to my/our need to modify the terms of my/our mortgage loan. 2. I/we understand and acknowledge the Servicer may investigate the accuracy of my/our statements, may require me/us to provide supporting documentation, and that knowingly submitting false information may violate Federal law. 3. I/we understand the Servicer will pull a current credit report on all borrowers obligated on the Note. 4. I/we understand that if I/we have intentionally defaulted on my/our existing mortgage, engaged in fraud or misrepresented any fact(s) in connection with this Hardship Affidavit, or if I/we do not provide all of the required documentation, the Servicer may cancel the Agreement and may pursue foreclosure on my/our home. 5. I/we certify that my/our property is owner-occupied and I/we have not received a condemnation notice. 6. I/we certify that I/we am/are willing to commit to credit counseling if it is determined that my/our financial hardship is related to excessive debt. 7. I/we certify that I/we am/are willing to provide all requested documents and to respond to all Servicer communication in a timely manner. I/we understand that time is of the essence. Page 2 of 4 HIFAFF-0909 Borrower Name: Loan Number: 8. I/we understand that the Servicer will use this information to evaluate my/our eligibility for a loan modification or other workout, but the Servicer is not obligated to offer me/us assistance based solely on the representations in this affidavit. 9. I/we accept and agree to all terms of the Home Affordable Modification Trial Period ("Trial Period") Plan which is incorporated herein by reference as if set forth in full. 10. I/we agree that when the Servicer accepts and posts a payment during the Trial Period it will be without prejudice to, and will not be deemed a waiver of, the acceleration of my loan or foreclosure action and related activities and shall not constitute a cure of my default under my loan unless such payments are sufficient to completely cure my entire default under my loan. 11. I/we agree that any prior waiver as to payment of escrow Items in connection with my loan has been revoked. 12. I/we agree to the establishment of an escrow account and the payment of escrow items if an escrow account never existed on my loan. 13. I/we understand that Servicer will collect and record personal information, including, but not limited to, my name, address, telephone number, social security number, credit score, income, payment history, government monitoring information, and information about account balances and activity. I understand and consent to the disclosure of my personal information and the terms of the Trial Period Plan and Modification Agreement by Servicer to (a) the U.S. Department of the Treasury, (b) Fannie Mae and Freddie Mac in connection with their responsibilities under the Homeowner Affordability and Stability Plan; (c) any investor, insurer, guarantor or servicer that owns, insures, guarantees or services my first lien or subordinate lien (if applicable) mortgage loan(s); (d) companies that perform support services for the Home Affordable Modification Program and the Second Lien Modification Program; and (e) any HUD certified housing counselor. Borrower Signature Date Co-Borrower Signature Date E-mail Address: E-mail Address: Social Security Number: - Phone Numbers: Home: Social Security Number, Phone Numbers: Cell: Home: Work: Work: Page 3 of 4 HIFAFF-0909 Borrower Name: Loan Number: Explanation (continued): Page 4 of 4 HIFAFF-0909 V Form 4506T-EZ Short Form Request for Individual Tax Return Transcript (October 2009) OMB No. 1545-2154 Department of the Treasury ? Request may not be processed if the form Is incomplete or illegible. Internal Revenue Service Tip: Use Fonn 4506T-EZ to order a 1040 series tax return transcript free of charge. 1a Name shown on tax return. If a joint return, enter the name shown first. 1b First social security number on tax return 2a If a joint retum, enter spouse's name shown on tax return. 2b Second social security number If joint tax return 3 Current name, address (Including apt., room, or suite no.), city, state, and ZIP code 4 Previous address shown on the last return filed if different from line 3 5 If the transcript is to be mailed to a third party (such as a mortgage company), enter the third party's name, address, and telephone number. The IRS has no control over what the thins party does with the tax information. Third party name Telephone number EMC Fulfillment Center 800-723-3004 Address (including apt., room, or suite no.), city, state, and ZIP code Regular Mail: PO Box 469030, Glendale, CO 80246 Overnight Mail: 4500 Cherry Creek Drive, Sutte# 100, Glendale, CO 80246 6 Year(s) requested. Enter the year(s) of the return transcript you are requesting (for example, "2008'J. Most requests will be processed within 10 business days. 2008 Caution. If the transcript is being mailed to a third party, ensure that you have filled in line 6 before signing. Sign and date the form once you have filled in line 6. Completing these steps helps to protect your privacy. Note. If the IRS is unable to locate a return that matches the taxpayer Identity Information provided above, or if IRS records indicate that the return has not been filed, the IRS may notify you or the third party that it was unable to locate a return, or that a return was not filed, whichever is applicable. Signature of taxpayer(s). I declare that I am either the taxpayer whose name is shown on line 1 a or 2a. If the request applies to a joint return, either husband or wife must sign. Note. This form must be received within 60 days of signature date Telephone number of taxpayer on line 1 a or 2a ' Sign Signature (see instructions) Date Here ' Spouse's signature Date For Privacy Act and Paperwork Reduction Act Notice, see page 2. Cat. No. 54185S Form 4506T-EZ (10-2009) , Form 4506T-EZ(10-2009) Page 2 Purpose of form. Individuals can use Form 4506T-EZ to request a tax return transcript that includes most lines of the original tax return. The tax return transcript will not show payments, penalty assessments, or adjustments made to the originally filed return. You can also designate a third party (such as a mortgage company) to receive a transcript on line 5. Form 4506T-EZ cannot be used by taxpayers who file Form 1040 based on a fiscal tax year (that is, a tax year beginning in one calendar year and ending in the following year). Taxpayers using a fiscal tax year must file Form 4506-T, Request for Transcript of Tax Return, to request a return transcript. Use Form 4506-T to request the following. • A transcript of a business return (including estate and trust returns). • An account transcript (contains information on the financial status of the account, such as payments made on the account, penalty assessments, and adjustments made by you or the IRS after the return was filed). • A record of account, which is a combination of line item information and later adjustments to the account. • A verification of nonfiling, which is proof from the IRS that you did not file a return for the year. • A Form W-2, Form 1099 series, Form 1098 series, or Form 5498 series transcript. Form 4506-T can also be used for requesting tax return transcripts. Automated transcript request. You can call 1-800-829-1040 to order a tax return transcript through the automated self-help system. You cannot have a transcript sent to a third party through the automated system. Where to file. Mail or fax Form 4506T-EZ to the address below for the state you lived in when that return was filed. If you are requesting more than one transcript or other product and the chart below shows two different RAIVS teams, send your request to the team based on the address of your most recent return. Where to mail ... If you filed an Mail or fax to the individual return "Internal Revenue and lived in: Service" at: Alabama, Delaware, RAIVS Team Florida, Georgia, P.O. Box 47-421 North Carolina, Stop 91 Rhode Island, South Doraville, GA 30362 Carolina, Virginia 770-455-2335 Kentucky, Louisiana, Mississippi, RAIVS Team Tennessee, Texas, a Stop 6716 AUSC foreign country, or Austin, TX 73301 A.P.O. or F.P.O. 512-460-2272 address Alaska, Arizona, California, Colorado, District of Columbia, Hawaii, Idaho, Iowa, Kansas, Maine, Maryland, Massachusetts, RAIVS Team Minnesota, Montana, Stop 37106 New Hampshire, New Fresno, CA 93888 Mexico, New York, 559-456-5876 North Dakota, Oklahoma, Oregon, South Dakota, Utah, Vermont, Washington, Wisconsin, Wyoming Arkansas, Connecticut, Illinois, RAIVS Team Indiana, Michigan, Stop 6705-841 Missouri, New Jersey, Kansas City, MO Ohio, Pennsylvania, 64999 816-292-6102 West Virginia Signature and date. Form 4506T-EZ must be signed and dated by the taxpayer listed on line 1a or 2a. If you completed line 5 requesting the information be sent to a third party, the IRS must receive Form 4506T-EZ within 60 days of the date signed by the taxpayer or it will be rejected. Transcripts of jointly filed tax returns may be furnished to either spouse. Only one signature is required. Sign Form 4506T-EZ exactly as your name appeared on the original return. If you changed your name, also sign your current name. Privacy Act and Paperwork Reduction Act Notice. We ask for the information on this form to establish your right to gain access to the requested tax information under the Internal Revenue Code. We need this information to properly identify the tax information and respond to your request. Sections 6103 and 6109 require you to provide this information, including your SSN. If you do not provide this information, we may not be able to process your request. Providing false or fraudulent information may subject you to penalties. Routine uses of this information include giving it to the Department of Justice for civil and criminal litigation, and cities, states, and the District of Columbia for use in administering their tax laws. We may also disclose this information to other countries under a tax treaty, to federal and state agencies to enforce federal nontax criminal laws, or to federal law enforcement and intelligence agencies to combat terrorism. You are not required to provide the information requested on a form that is subject to the Paperwork Reduction Act unless the form displays a valid OMB control number. Books or records relating to a form or its instructions must be retained as long as their contents may become material in the administration of any Internal Revenue law. Generally, tax returns and return information are confidential, as required by section 6103. The time needed to complete and file Form 4506T-EZ will vary depending on individual circumstances. The estimated average time is: Learning about the law or the form, 9 min.; Preparing the form, 18 min.; and Copying, assembling, and sending the form to the IRS, 20 min. If you have comments concerning the accuracy of these time estimates or suggestions for making Form 4506T-EZ simpler, we would be happy to hear from you. You can write to the Internal Revenue Service, Tax Products Coordinating Committee, SE:W:CAR:MP:T:T:SP, 1111 Constitution Ave. NW, IR-6526, Washington, DC 20224. Do not send the form to this address. Instead, see Where to file on this page. McCABE, WEISBERG & CONWAY, P.C. TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 KEVIN McQUAIL, ESQUIRE-ID # 307169 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 The Bank of New York Mellon formerly known as The Bank of New York as successor Trustee to JPMorgan Chase Bank, National Association as Trustee for the Cerdficateholders of Structured Asset Mortgage Investments II Inc. Bear Stearns ALT-A Trust, Mortgage Pass-Through Certificates Series 2005-10 Plaintiff V. Geoffrey T. Cragg Defendant IED-OFFICE c; r- T t ar PRO THOSO jhprney for Plaintiff 2911 iL1L 11 10: 1 CjIF??h?SYLVA OllNT?, NIA CUMBERLAND COUNTY COURT OF COMMON PLEAS !t-11!9 N - it AFFIDAVIT OF SERVICE OF AMENDED AFFIDAVIT PURSUANT TO RULE 3129 The undersigned attorney for the Plaintiff in the within matter, hereby certifies that on the 6th day of July, 2011, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s) as set forth in Amended Affidavit Pursuant to 3129 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part hereof. SWORN AND SUBSCRIBED BEFORE ME THIS J}h DAY OF jt 3W 2011 _Ij NOTAR PUBLIC CGMMQN??c.Aq CF PENNSYLVANIA twi ` .TRIAL SEAL ?V n uu' ?'.:?I Notary Public I Njcgan C. Pv O ry of Philadelphia, Philadelphia County ,?,y CCMh!ISSION EXPIRES JAN, 06, 2014 McCABE, M Attorneys for By: Y, P.C. TERRENC. McCABE, ESQUIRE - ID # 16496 MARC S. EISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 KEVIN McQUAIL, ESQUIRE-ID # 307169 McCABE, WEISBERG & CONWAY, P.C. TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 KEVIN McQUAIL, ESQUIRE-ID # 307169 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 The Bank of New York Mellon formerly known as The Bank of New York as successor Trustee to JPMorgan Chase Bank, National Association as Trustee for the Certificateholders of Structured Asset Mortgage Investments II Inc. Bear Stearns ALT-A Trust, Mortgage Pass-Through Certificates Series 2005-10 Plaintiff V. Geoffrey T. Cragg Defendant Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 11-1791 Civil AMENDED AFFIDAVIT PURSUANT TO RULE 3129 The undersigned attorney for Plaintiff in the above action sets forth the following information concerning the real property located at Lot # 67 Monroe Acres a/k/a 308 Widders Drive, Mechanicsburg, Pennsylvania 17055, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property is attached hereto. Name and address of Owner or Reputed Owner Name Address Geoffrey T. Cragg 8220 East Green Hollow Court Parker, Colorado 80134 2. Name and address of Defendant in the judgment: Name Address Geoffrey T. Cragg 8220 East Green Hollow Court Parker, Colorado 80134 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein Name and address of the last recorded holder of every mortgage of record: Name Address Mortgage Elecrtonic Registration 3010 Briarpark Drive Systems, Inc., as nominee for AEGIS Suite 700 Wholesale Corporation Houston, Texas 77042 Mortgage Elecrtonic Registration P.O. Box 2026 Systems, Inc., as nominee for AEGIS Flint, Michigan 48501 Wholesale Corporation Name and address of every other person who has any record lien on the property: Name Dillsburg Area Authority Address 98 Widders Drive Dillsburg, Pennsylvania 17019 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants Lot # 67 Monroe Acres a/k/a 308 Widders Drive Mechanicsburg, Pennsylvania 17055 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard Commonwealth of Pennsylvania 110 North 8t' Street Inheritance Tax Office Suite #204 Philadelphia, PA 19107 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department #280601 Inheritance Tax Division Harrisburg, PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O. Box 8486 Recovery Program Harrisburg, PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg, PA 17128-1230 Compliance ATTN: Sheriff's Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 Domestic Relations P.O. Box 320 Cumberland County Carlisle, PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 United States of America c/o U.S. Dept of Justice, Room 5111 Atty General of the United States 950 Pennsylvania Avenue NW Washington, DC 20530-0001 United States of America c/o U.S. Dept of Justice, Room 4400 Atty General of the United States 950 Pennsylvania Avenue NW Washington, DC 20530-0001 8. Name and address of Attorney of record: Name Address I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. McCABE, W CONWAY, P.C. July 6, 2011 Attorneys fo I * iff DATE By: TERRE E J. M AB SQUIRI MARC . WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE KEVIN McQUAIL, ESQUIRE McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 The Bank of New York Mellon formerly known as The Bank of New York as successor Trustee to JPMorgan Chase Bank, National Association as Trustee for the Certificateholders of Structured Asset Mortgage Investments II Inc. Bear Stearns ALT-A Trust, Mortgage Pass-Through Certificates Series 2005-10 Plaintiff V. Geoffrey T. Cragg Defendant DATE: July 6, 2011 TO: ALL PARTIES IN INTEREST AND CLAIMANTS Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 11-1791 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS: Geoffrey T. Cragg PROPERTY: Lot # 67 Monroe Acres a/k/a 308 Widders Drive, Mechanicsburg, Pennsylvania 17055 IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriffs Sale on September 7, 2011 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty (30) days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the filing of the schedule. ?LL yy O tLL 0 r- rn 'Ss a Q7 ? N g .J V U- U n 4 ?tyl b ? LL Lu ® C S ? 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Vi vm i~ i; 0 CO as a, a> AFx3a;x os ? a a,aaa;x O? .. eA F+ U a U x? p C C a? •" O p ?F3a?oAt WA At AO Ua 0 CC a;U • i C M O •r "' CX e? 3 . 0 0 s C N N eE ?x x V] O ea G .+ ???3 n N N * 09 O .-? .r .r N r• M rt ?' rt ti McCABE, WEISBERG AND CONWAY, P.C. -,*BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 The Bank of New York Mellon formerly known as The Bank of New York as successor Trustee to JPMorgan Chase Bank, National Association as Trustee for the Certificateholders of Structured Asset Mortgage Investments II Inc. Bear Stearns ALT-A Trust, Mortgage Pass-Through Certificates Series 2005-10 Plaintiff V. Geoffrey T. Cragg Defendant Attorneys for Plaintiff ?.. .;I1O'd?JTi.i, ?.011 fl U3 I S A 111- L6 !CUMBERLAND COUNT'1' COURT OF COMMON PLEAS PENNSYLVANIA CUMBERLAND COUNTY [I-nq it AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF PHILADELPHIA I, undersigned, Esquire, attorney for Plaintiff in the within matter, being duly sworn according to law, deposes and says that a true and correct copy of the Notice of Sheriff's Sale was served upon Geoffrey T. Cragg, by regular mail, certificate of mailing, and certified mail, return receipt requested, dated July 27`h, 2011 and addressed 8220 East Green Hollow Court, Parker, Colorado 80134. The regular mail was never returned, and the certified mail was delivered on July 30`h, 2011 and signed for by an Defendant, Geoffrey T. Cragg. A true and correct copy, certificate of mailing, certified receipt number 7010-3090-0001-8825-5330, and signed green cards are attached hereto, made part hereof, and marked as Exhibit "A". SWORN TO AND SUBSCRIBED BEFORE ME THIS //1AY OF , 2011. NOTARY PUBLIC `-? COMMONWEALTH. OF PENNSYLVANIA NOTARIAL SEAL Barbara J. Moyer- Notary Public City of Philadelphia, Philadelphia County MY COMMISSION EXPIRES JAN. 12, 2014 McCABE SBERG AND CONWAY, P.C. Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET CAIRO, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE HEIDI R. SPIVAK, ESQUIRE EXHIBIT A rte: _ a ?s a ? tits ? ? e e ? Z a a - c = ? 4 r d c " R YC Z,_x?:G • X ? u A ? ? O ?z?. o e - E. o - ? a - z U V G C ? C O U v > M y i. ? ? ? ? ?" 00 ? t C G . ?? Fr Q . i ) y v?a w? .? ? ?a C ti 4 U ? ? ? ? ? W V) y v U Q ? a? °. N a C7 v -F v ? 000 ? bD o o ? j Ci ftS ?n to ( w (? v a' ° 0 5 C ? ? u y CC v z?NaQU o F C O a W m O w L .3 d a d d E 0 U O O O N y au cam' r M Ct. O m m n OFFIC IA L U' ME Poet?Qe ------» -? ------ co m cormw roe a Roturn Receipt Fee (EndonerrWtu Req?red) Paehnelt Hve C3 geetrlctee Dsllvsry ree .?,?,.. 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