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HomeMy WebLinkAbout11-2906UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, ESQU: STUART WINNEG, ESQUIRI LORRAINE DOYLE, ESQUII ALAN M. MINATO, ESQUIR] CHANDRA M. ARKEMA, ESQ SHERRI J. BRAUNSTEIN, ES MARGUERITE L. THOMAS, DANIEL S. SIEDMAN, ESQU: JEROME B. BLANK, ESQUI1 WOODCREST CORPORATE 111 WOODCREST ROAD, SU CHERRY HILL, NJ 08003-362 856-669-5400 nleadin2s i.udrer ATTORNEY FOR PLAINTIFF RE - ID #04302 - ID #45362 E - ID #34576 - ID #75860 UIRE - ID #203437 ?DIRE - ID #90675 :SQUIRE - ID #204460 2E - ID #306534 E - ID #49736 200 Deutsche Bank National Trus Company, as Trustee for Argent Securiti s Inc., Asset-Backed Pass-Through rtificates, Series 2006-M2 CARE OF 4600 Regent Blvd Suite 200 Irving, TX 75063 Plaintiff V. WENDELL C. BIGGS 222 EAST MAIN STREET SHIREMANSTOWN, PA 17011 Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. il- ?rl?f? q7- 1 t' 1H COMPLAINT IN MORTGAGE FORECLOSURE q YOU HAVE BEEN SUED IN URT. 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 ppearance personally or by attorney and filing in writing with the Court your defenses or object ons to the claims set forth against you. You are warned that if you fail to do so the case may pr ceed 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 P PER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO R TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROM E YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNO AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE Y U WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVI ES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cuberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 AVISO Le han demandado a usted en la '!Corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tione veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asc ntar una comparencia escrita o en persona o con un abogado y entregar a la Corte en forma escri a sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si uste no se dafiende, la Corte tomara medidas y puede continuar la demanda en contra suya sin prev o aviso o notificacion. Ademas, la Corte puede decidir a favor del demandante y requiere que u ted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propi ades u otros derechos importantes para usted. LLEVE ESTA DEMANDA UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE L DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENT ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTE CIA LEGAL. CumIberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 NOTICE The amount of your debt s as stated in the attached document. The name of the creditor to whom the debt is o ed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judg# ent against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection! of your debt. This law firm is deemed to be ?a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 I . Plaintiff is the corporation designated as such in the caption on a preceding page. Plaintiff is the legal older of the Mortgage that is the subject of this Action. Plaintiff is either the current ortgagee of record, is the legal holder of the Mortgage by virtue of being successor in interest to the current mortgagee of record, or is the legal holder of the Mortgage by *irtue of Assignment of Mortgage. If Plaintiff is the legal holder of the Mortgage by virtue of Assignment of Mortgage, it is by the following Assignments of Mortgage, all of which have either been recorded or Plaintiff is in the process of formalizing the actual Assignment of Mortgage in Plaintiff s favor: Assignor: CITI Residential Lending Inc., as Attorney-in-Fact for Argent Mortgage Company, LLC Assignee: Deutsche Bank National Trust Company, as Trustee for, Argent Securities Inc., Asset- Backed Pass-Through Certificates, Series 2006-M2, under the Pooling and Servicing Agreement dated August 1, 2006 Date of Assignment: 01/20/2009 Recorded Date: 02/13/2009 Book/Instrument #: Instrument #400903952 Page: n/a 2. Upon information and be?ief Defendant(s): Wendell C. Biggs (hereinafter "Defendannts"), are the owners of property located at 222 East Main Street, Shiremanstown, PA 7011, by virtue of Deed dated 08/01/1996 and recorded 08/13/1996 in Officio Records Book 144 at Page 97 of the Public Records of Cumberland County Pennsylvania (hereinafter the "Property"). On 06/29/2006, Defendant(s): promised to pay tj the order of Argent Mortgage Company, LLC, the principal sum of $ 69,350.0 payable with interest thereon provided in the Note. 4. By Mortgage dated 06/29/006, Defendant(s): WENDELL C. B$GGS to secure the Note, mortgaged to Argent Mortgage Company, LLC , the Property which is the subject of this action. The Mortgage was recorded on 07/07/2006 in Official Records B?ok 1957 at Page 3245 . Said Mortgage is incorporated herein by referenced in accordance with Pa.R.C.P 1019(g). A legal description of the mortgage premises lis attached hereto and made a part hereof. Said mortgage is in default in that the payment due 11/01/2010, and all subsequent payments have not bees made, and by its terms, upon breach and failure to cure said breach after notice, all ?ums secured by said Mortgage, together with the other charges i authorized by said Mortgage and itemized below, shall be immediately due. 6. After demand, the Def4ndant(s) continues to fail or refused to comply with the terms of the Mortgage as follow: (a) By failing or refusi*g to pay the installments of principal and interest when due in the amounts indicated below; (b) By failing or The following amounts to pay other charges, if any, indicated below. due on the said Mortgage or modification agreement as of the date stated below Unpaid Principal Balance $66,586.80 Accumulated Interest' $2,119.25 Accumulated Late Cha gas $365.52 Escrow Deficit/(Rese e) $2,462.57 Title Report $325.00 Court Cost - Estimat i ad $300.00 Attorney Fees - Esti#nated $1,300.00 Suspense Balance $-419.93 Recoverable Balance $228.80 Grand Total $73,268.01 The above figures are calculated ?s of 2/24/2011: The interest rate is subject to adjustment as more fully described in the note and mortgage. The interest rate on the subject note is at 7.97500 %. The per diem interest accruing on this debt is $14.55 and that su should be added each day after the above date. The late charge is subject o adjustment as more fully described in the note and mortgage. The late charge rate on the subjec note should be added in accordance to the terms of the note and mortgage charged monthly at $30.46. 7. Breach letters have been s nt to Defendant(s) in accordance with the requirements of the subject mortgage, The Pennsylv is Act 6 of 1974 of the Commonwealth of Pennsylvania and the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983. Copies of the breach letters are a ached hereto as Exhibit "A". WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $73,268.01 plus interest, posts and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. UDREN LA'i FICES, P.C. BY: 22004460 Esquire /"O ro "Pl n r ? Stewart Title Guaranty Company Commitment Number: DA-3201 EXHIBIT A SCHEDULE C PROPERTY DESCRIPTION The land referred to In this Commitment is described as follows: ALL that certain house and lot of I *d situate in the Borough •of Shiremanstown, County of Cumberland and State of Pennsylvania, bounded and escribed as follows, to wit: BEGINNING at a point on the south rn street line of East Main Street, comer of land of Daisy Wentz; thence along said southern street line of Ea Main Street in an eastwardly direction twenty and two-tenths (20.2) feet to a point; thence along the line of oth r lands of John E. Carbauth and Frances E. Carbaugh, his wife, of which this was a part, and through the pa ition wall of the dwelling on the lot Immediately adjacent on the East, and beyond, In a southwardly direction uth 2 degrees East one hundred sixty-one and seven-tenths (161.7) feet (passing through the center of a dou le fram garage building) to a point marked by an Iron pipe In the northern line of Cortland Alley; thence along s id northern line of Cortland Alley in a westwardly direction twenty (20) feet to a pipe; thence along the line of I nd of Daisy Wentz, aforesaid, in a northwardly direction North 3 degrees West one hundred sixty-one and Be en-tenths (161.7) feet to a point on the southern line of East Main Street, the point and place of Beginning. HAVING erected thereon the weste one-half of a double , two and one-half (2-1/2) story frame dwelling house known and numbered as 222 East M in Street, Shiremanstown, Pennsylvania, EXHIBIT A ALTA Commitment SchedWe C (BIGGS, WENDELL.PFD/DA-3201/4) Aux, di o,,o?„? 71IIIIIIIaDII2IYIIYIIIIIr9YI179 11111111 Wendell C Biggs 222 E Main St Shiremanstown, P, 17011 (Rev. 9/2008) Date: January 10, 2011 This is an official notice that the mortgage on your of the default is provided in the attached pages. IMPORTANT INFORMATION CONCERNING Y C 91 NOTICE ON TO SAVE YOUR IM FOR-'CLOSURE is in default, and the lender intends to foreclose. Specific information about the nature RIGHTS IS CONTAINED ON PAGE FOUR The HOMEOWNER'S EMERGENCYMORTGAG ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEM can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NO ICE. Take this Notice with you when you meet with the Counseling Agency. The name, address, and phone number of Consume Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania ousing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACIO'N EN ADJUNTO ES DE SO SU CASA. SI NO COMPRENDE EL CO] INMEDIATAMENTE LLAMANDO ESTA A( NUMERO MENCIONADO ARRIBA. PUEDE "HOMEOWNER'S EMERGENCY MORTGAGE DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT SERVICER: CURRENT LENDER: [A IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN TENIDO DE ESTA NOTIFICACIO'N OBTENGA UNA TRADUCCIO'N ENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL SER ELEGIBLE PARA UN PRE'STAMO POR EL PROGRAMA LLAMADO ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA Wendell C Biggs 222 E Main St Shiremanstown, PA 17011 4001372723 F=)(W T A R TT T A ARGENT MORTGAGE COMPANY American Home Mortgage Servicing, Inc. Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset-Backed Pass-Through Certificates, Series 2006-M2 Page two 4001372723 HOMEOWNER'S EMER, GENCY MORTGAGE ASSISTANCE PROGRAM YOUMAYBE ELIGIBLE FOR F ANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AN HELP YOUMAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PR VISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE " CT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN * IF YOU HAVE A REASONABLE AND * IF YOU MEET OTHER HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSU mortgage for thirty (30) days from the d arrange and attend a "face-to-face" meetii Notice. THIS MEETING MUST OCCU. IF YOU DO NOT APPLY FOR EMERGE TO DATE. THE PART OF THIS NOTICE TO BRING YOUR MORTGAGE UP TO L BY CIRCUMSTANCES BEYOND YOUR CONTROL, OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA E - Under the Act, you are entitled to a temporary stay of foreclosure on your e of this Notice (plus three (3) days for mailing). During that time you must with one of the consumer credit counseling agencies listed at the end of this WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. CY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP ALLED "HOW TO CURE YOUR MORTGAGE DEFAULT"; EXPLAINS HOW TE. CONSUMER CREDIT COUNSELING A ENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender m NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end f this Notice. It is only necessary to schedule one face-to face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASS] Notice (see following pages for specific it financial assistance from the Homeowner's file a completed Homeowner's Emergency counseling agencies listed at the end of thi program and they will assist you in submit temporarily stop the lender from filing a fo within thirty (30) days of your face-to face 'TANCE - Your mortgage is in default for the reasons set forth later in this )rmation about the nature of your default). You have the right to apply for mergency Mortgage Assistance Program. To do so, you must fill out, sign and fssistance Program Application with one of the designated consumer credit Notice. Only consumer credit counseling agencies have applications for the ng a complete application to the Pennsylvania Housing Finance Agency. To >closure action, your application MUST be forwarded to PHFA and received teeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLI ATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 AYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHI 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SEC ION CALLED "TEMPORARY STAY OF FORECLOSURE." YOU HAVE THE RIGHT TO FILE A H AP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT HE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUAL Y APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCYACTION - Available funds foremergency 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 YOUARE CURRENTLY TECTED BY THE FILING OFA PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTPI IS FOR INFORMATION PURPOSES ONLYAND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO LLECT THE DEBT. (If you have filed bankruptcy you can still apply for mergency Mortgage Assistance.) Page three 4001372723 HOW TO CURE FOUR MORTGAGE DEFAULT (Bring it up to date): NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 222 E Main St, Shiremanstown, PA 17011 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY M?RTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payments from 11 /0 12010: $1,635.59 (b) Late charge(s): $304.60 (c) Other charge(s): NSF and Ad?ances $219.20 (d) Less: Credit Balance $419.93 (e) Total amount required as of b1/10/2011: $1,739.46 HOW TO CURE THE DEFAULT - You ay cure this default within THIRTY (30) DAYS from the date of this Notice BY PAYING THE TOTAL AMOUNT PAS DUE TO THE LENDER, WHICH IS $1,739.46, PI, US ANY MORTGAGE PAYMENTS AND LATE CHARGES (an other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either b cash, cashier's check, certified check, or money order made payable and sent to: can Home Mortggage Servicin?gg,, Inc. S. Beltline Rd. Copp ell, TX T5019 IF YOU DO NOT CURE THE DEFAUL - If you do not cure the default within THIRTY (30) DAYS of date of this Notice, the lender intends to exercise its right to accelerate the mortgage debt This means that the entire outstanding balance of this debt will be considered due immediate and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due s not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property IF THE MORTGAGE IS FORECLOSE mortgage debt. If the lender refers your c, proceedings against you, you will still be i $50.00. However, if legal proceedings are incurred by the lender even if they exceed 1 may also include other reasonable costs., required to pay attorney's fees. OTHER LENDER REMEDIES - The sums due under the mortgage. 0 UPON - The mortgaged property will be sold by the Sheriff to pay off the e to its attorneys, but you cure the delinquency before the lender begins legal quired to pay the reasonable attorney's fees that were actually incurred, up to tarted against you, you will have to pay all reasonable attorney's fees actually 0.00. Any attorney's fees will be added to the amount you owe the lender, which you cure the default within the THIRTY (30) DAYperiod, you will not be may also sue you personally for the unpaid principal balance and all other RIGHT TO CURE THE DEFAULT PRIG TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAYperiod and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attor ey's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specifre in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the ma ner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SAL mortgaged property could be held would be actual date of the Sheriffs Sale will be sen increase the longer you wait. You may fi contacting the lender. T DATE - It is estimated that the earliest date that such a Sheriffs Sale of the approximately five (5) months from the date of this Notice. A notice of the to you before the sale. Of course, the amount needed to cure the default will id out at any time exactly what the required payment or action will be by Page four Name of Lender: Address: Telephone Number: Fax Number: Contact Person: E-mail Address: EFFECT OF SHERIFF'S SALE - You property and your right to occupy it. If you and your furnishings and other belongings ASSUMPTION OF MORTGAGE - You mortgage debt, provided that all the outsta sale and that the other requirements of the ° TO SELL THE PROPERTY TO OI MONEY FROM ANOTHER LENT; TO HAVE THIS DEFAULT CUREI ° TO HAVE THE MORTGAGE RES' IF YOU CURE THE DEFAULT. (H MORE THAN THREE TIMES IN A TO ASSERT THE NONEXISTEN OTHER LAWSUIT INSTITUTED ° TO ASSERT ANY OTHER DEF] LENDER. TO SEEK PROTECTION UNDER T CONSUMER ARE American Home Mortgage Servicing, Inc for that purpose. #0W TO CONTACT THE LENDER 4001372723 American Home Mortgage Servicing, Inc. 1525 S. Beltline Rd. Coppell, TX 75019 1-877-304-3100 1-866-497-1263 Brandon Wirth, Michael Heath brandon.wirth@ahmsi3.com, michael.heath@ahmsi3.com d realize that a Sheriffs Sale will end your ownership of the mortgaged nue to live in the property after the Sheriffs Sale, a lawsuit to remove you be started by the lender at any time. iay not sell or transfer your home to a buyer or transferee who will assume the ding payments, charges and attorney's fees and costs are paid prior to or at the nortgage are satisfied. 0U MAYA LSO HAVE THE RIGHT. TAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW NG INSTITUTION TO PAY OFF THIS DEBT. BY ANY THIRD PARTY ACTING ON YOUR BEHALF URED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, )WEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT dY CALENDAR YEAR.) 'E OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY UNDER THE MORTGAGE DOCUMENTS. !SSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE FEDERAL BANKRUPTCY LAW. COUNSELING AGENCIES SERVING YOUR COUNTY ON THE ATTACHED PAGES. is attempting to collect a debt, and any information obtained will be used Unless you notify us within 30 days after eceiving this notice that you dispute the validity of this debt or any portion thereof, we will assume this debt is valid. If you notify us in writing within 30 days from receiving this notice that you dispute the validity of this debt or an portion thereof, we will obtain verification of the debt or obtain a copy of a judgment and mail you a copy of such judgment or verification. Upon your written request within thirty days after the receipt of this notice, we will provide you with the name and address of the original creditor, if the original creditor is different from the current creditor. Sincerely, American Home Mortgage Servicing, Inc. American Home Mortgage Servi?ing, Inc. 1525 S. Beltline Rd. Coppell, TX 75019, 1-877-304-3100 AGENCY NAME ADDRESS PHONE COUNTIES SERVED Action-Housing, Inc 425 6th Ave; STE 950 ibsburgh, PA 15219 800.792.2801 412.281.2102 Allegheny, Beaver, Butler, Fayette, Greene, Washington, Westmoreland Advocates for Financial Independence -Philadelphia 1628 JFK Blvd-8 Penn tr; STE 2210 Philadelphia, PA 19103 215.218.4342 Philadelphia Advocates for Financial Independence -Philadelphia 1503 Wadsworth Ave. iladelphia, PA 19150 267.323.2696 Delaware Affordable Housing Centers of America 846 North Broad Street 1st Floor Philadelphia, PA 19130 215.765.1221 Philadelphia American Credit Alliance, Inc. 2 S Delmon Ave Morn: ville, PA 19067 215.295.7195 Bucks, Montgomery American Credit Counseling Agency 6800 Market St., I st FI or, Upper Darby, PA 19130 888.212.6741 Delaware, Philadelphia American Credit Counseling Institute 100 Porter Road Suite 1 08 Pottstown, PA 19464 888.212.6741 Berks,Bucks, Chester, Lehigh, Montgomery American Credit Counseling Institute 212 Berwick-Hazelton wy Nescopeck, PA 18635 888.468.8847 Carbon, Columbia, Lackawanna, Lehigh, Luzeme, Monroe, Skhulkill American Credit Counseling Institute 526-528 Dekalb Street orristown, PA 19401 610.971.2210 888.212.6741 Delaware, Montgomery American Credit Counseling Institute 229 E Chestnut Street i t Floor Coatesville, PA 19320 888.212.6741 Chester, Lancaster American Credit Counseling Institute Financial Counseling Services Inc. 586 West Street Road PA 18974 , 215.444.9429 888.212.6741 Banks, Montgomery, Philadelphia American Credit Counseling Institute 21 South Church Street West Chester, PA 19380 888.212.6741 Chester American Credit Counseling Services Inc. 827 N 19th Street Allen own, PA 18104 888.468.8847 Bucks, Carbon, Lehigh, Monroe, Northampton, Skhuylkill American Financial Counseling Services Inc. 175 Strafford Avenue S ire One Wayne, PA 19087 267.228.7903 800.490.3039 Barks, Bucks, Chester, Delaware, Montgomery, Philadelphia American Financial Counseling Services Inc. 906 Penn Avenue Wyo timing, PA ]9610 267.228.7903 800.490.3039 gceks American Financial Counseling Services Inc. 2880 Bergey Road Suit H Hatfield, PA 19440 267.228.7903 800.490.3039 Barks, Chester, Montgomery American Financial Counseling Services Inc. 111 Buck Road Horning on Valley, PA 19006 267.228.7903 Bucks, Montgomery, Philadelphia American Financial Counseling Services Inc. 259 Veterans Lane Suit 101 Doylestown, PA 18901 267.228.7903 800.490.3039 Bucks, Montgomery American Financial Counseling Services Inc. 404 Executive Drive Lai ghome, PA 19047 267.228.7903 800.490.3039 Bucks, Montgomery American Financial Counseling Services Inc. 1080 N. Delaware Aven a Suite 200 Philadelphia, PA 19125 267.228.7903 800.490.3039 Bucks, Delaware, Montgomery American Financial Counseling Services Inc. 3008 Hamilton East Suit e 2 Stroudsburg, PA 18360 267228.7903 Carbon, Monroe American Financial Counseling Services Inc. 405 West Germantown ike Norristown, PA 19403 267.228.7903 800.490.3039 Delaware, Montgomery American Red Cross - Hanover Chapter 529 Carlisle Street Hano ver, PA 17331 717.637.3768 Adams, Franklin, York American Red Cross of Chester 1729 Edgemont Avenue Chester, PA 19013 610.874.1484 Chester, Delaware Armstrong County Community Action Agency 705 Butler Rd Kittanning , PA 16201 724.548.3613 Armstrong (APM) 600 W Diamond St Phil I hia, PA 19122 p 215.235.6070 267.953.4615 Delaware, Philadelphia, Chester BASE, Incorporated 447 S. Prince St Lancas , PA 17603 717.392.5467 Lancaster, York BerksMont Housing and Financial Counseling, Inc. 50 East Philadelphia Ave ., Boyertown, PA 19512 484.955.9494 Berks, Montgomery Blair County Community Action Agency 2100 6th Ave; STE 102, O Box 1833 Altoona, PA 16602 814.946.3651 Blair Booker T. Washington Center 1720 Holland Street Erie PA 16503 814.453.5744 Crawford, Erie, Warren Bucks County Housing Group 2324 Second St Pike; ST E 17 Wrightstown, PA 18940 866.866.0280 Bucks Bucks County Housing Group 349 Durham Road Penn 1, PA 19047 866.866.0280 Bucks Bucks County Housing Group 200 West Bridge Street orrisville, PA 19067 866.866.0280 Bucks Bucks County Housing Group 470 Old Dublin Pike Do lestown, PA 18901 866.866.0280 Bucks Bucks County Housing Group 515 West End Boulevard Quakertown, PA 18951 866.866.0280 Bucks Budget Counseling Center 247 N Fifth St Reading A 19601 610.375.7866 Barks, Schuylkill, Chester Carroll Park Community Council, Inc. 5218 Master St Philadelp ia, PA 19131 215.877.1157 Chester, Delaware, Philadelphia Catholic Social Services Diocese of Scranton 516 Fig Street Scranton, A 185051 570.207.2283 Lackawanna, Monroe, Wayne, Wyoming CCCS of Delaware Valley 1717 Swede Road Suite I 10 Blue Bell, PA 19422 215.563.5665 Montgomery CCCS of Delaware Valley 1230 New Rodgers Road Suite Fl Bristol, PA 19007 215.563.5665 Bucks CCCS of Delaware Valley One Cherry Hill Suite 21 Cherry Hill, PA 08002 215.563.5665 Philadelphia CCCS of Delaware Valley - Center City Philadelphia 1608 Walnut St; I Oth FL hiladelphia, PA 19103 215.563.5665 Bucks, Delaware, Montgomery, Philadelphia CCCS of Delaware Valley - Coatesville 1003 East Lincoln Hwy; nine 102 Coatesville, PA 19320 215.563.5665 Bucks, Chester, Delaware, Montgomery, Philadelphia Ketneved December 6, 2010 from http://www.phfa.org/forms/counseling?gencies/hemap_agencies/hemap.pdf CCCS of Delaware Valley - Media 280 N Providence Rd Media, PA 19063 215.563.5665 Delaware CCCS of Delaware Valley - West Chester 770 E Market St; STE 10 West Chester, PA 19382 215.563.5665 Chester, Delaware CCCS of Delaware Valley -Philadelphia hia y p Catholic Social Servicel Philadel hia PA 19136 Building 7340 Jackson St 800.989.2227 215.5615665 Philadelphia, Bucks CCCS of Delaware Valley -Philadelphia 4400 North Reese S[ Ph iladelphia, PA 19140 800.989.2227 215.563.5665 Bucks, Chester, Delaware, Montgomery, Philadelphia CCCS of Delaware Valley (Community Action Development Comm- CADCO 113 East Main Street 2 Floor Norristown, PA 19401 215.563.5665 Bucks, Chester, Delaware, Montgomery, Philadelphia CCCS of Lehigh Valley -Quakertown 127 S. 5th St STE 155, uakeriown, PA 18951 610.585.9518 888.845.5669 Bucks CCCS of Lehigh Valley Division of Money Management International 3671 Crescent Court E Whitehall, PA 18052 610.821.4011 800.837.9815 Carbon, Lancaster, Lehigh, Schuylkill, Northampton, Berks, Bucks CCCS of Northeastem PA 129 Rolling Ridge Driv g g State College, PA 16801 814238.3668 800.922.9537 Blair, Centre, Clearfield, Clinton, Huntingdon, Juniata, Mifflin CCCS of Northeastem PA 201 Basin Street Suite Williamsport, PA 17701 570.323.6627 800.922.9537 Centre, Clinton, Lycoming, Northumberland, Union CCCS of Northeastern PA -Pittston 401 Laurel St Pittston, A 18640 800.9219537 570.602.2227 Bradford, Carbon, Luzeme, Clinton, Columbia,Lackawanna, Lycoming, Mifflin, Mourne, Montour, Northumberland Pike Sullivan Tio a Union CCCS of Northeastem PA - Stroudsburg 411 Main St; STE 104 oudsbur , PA 18360 9 800.922.9537 570.420.8980 Bradford, Carbon, Monroe, Pike, Wayne CCCS of Westen PA The Franklin Center 52 Ali ui a PA 15001 Franklin Avenue 888.511.2227 Cameron CCCS of Westen PA 41 E. Chestnut Street M adville, PA 15301 888.511.2227 Washington CCCS of Westen PA 312 Chestnut Street Suit - 227 Meadville, PA 16335 888.511.2227 Lawrence CCCS of Westen PA -Altoona Royal Remax Plaza 917 Altoona PA 16602 Logan Blvd; Royal Remax Plaza 800.5111227 570.602.2227 Armstrong, Bedford, Blair, Cambria, Centre, Clearfield, Huntingdon, Juniata, Mifflin Union CCCS o(Westen PA -Butler Butler County Career Li 112 Hollywood Dr; Butl Pullman Commerce Center er, PA 16001 888.511.2227 Butler, Clarion, Jefferson, Mercer, Vrnango CCCS of Westen PA -Erie 4402 Peach St Lower vel Erie, PA 16509 888.511.2227.108 Crawford, Erie, Warren CCCS of Westen PA - Greensburg 9 I N Gate Square; #2 G Greensburg PA 15601 den Center Drive 888.511.2227 Indiana, Westmoreland, Fayette, Greene, Somerset, Washington CCCS of Westen PA 2000 Linglestown Rd; H arrisburg, PA 17110 888.511.2227 Dauphin,Perry, York, Snyder, Adams, Cumberland, Franklin CCCS of Westen PA - Pittsburgh 2403 Sidney St; STE Pittsburgh, PA 15203 River Park Commons 888.5112227 Allegheny CCCS of Westen PA -York 55 Clover Hill Road Dal astown, PA 17313 988.511.2227 Franklin,Lancaster, York, Fulton Center fm Family Services, Inc. 213 Center St Meadville PA 16335 814.337.8450 Crawford, Venango Center in the Park 5818 Germantown Ave hiladelphia, PA 19144 215.848.7222 Philadelphia Central Pennsylvania Community Action, Inc. PO Box 792; 207 East C terry Street, Clearfield, PA 16830 814.765.1551 Centre, Clearfield Chester Community Improvement Project. 412 Ave of the States, C hester, PA 19016 610.876.8663 Chester, Delaware, Montgomery, Philadelphia Comm. On. Econ Opportunity of Luzeme County 163 Amber Lane, Wilk -Barre, PA 18702 570.826.0510 Carbon, Luzeme, Potter, Wyoming Community Action Commission - Capital Region 1514 Deny St Harrisburg , PA 17104 717.232.9757 Cumberland, Dauphin, Franklin, Perry, Snyder Community Action Committee of the Lehigh Valley 1337 E Fifth St Bethlehe , PA 18015 610.691.5620 Berks, Carbon, Lehigh, Monroe, Northampton Community Action Southwest 150 W Beau SS STE 304 Washington, PA 15301 724.225.9550 Washington Community Action Southwest 58 E Greene St Waynesb urg, PA 15370 724.852.2893 Allegheny, Fayette, Greene. Washington, Westmoreland CONGRESO 216 W Somerset St Phil elphia, PA 19133 215.763.8870 Philadelphia Council of Spanish Speaking Organization 705-09 N Franklin St Phi ladelphia, PA 19123 215.627.3100 Philadelphia Credit Counseling Center 832 2nd St Pike Richb , PA 18954 215.348.8003 Bucks Credit Counseling Center 60 North Main Street Lo er Level Doylestown, PA 18901 215/348-8003 Bucks Credit Counseling Center 8150 Route 13, Levittow n, PA, 19057 215.348.8003 Bucks, Montgomery, Philadelphia Deliverance Community Development Corp, Inc 2001 W Lehigh Ave. Phi Iphia, PA 19145 215.226.7600 Philadelphia Diversified Community Services Dotson House 1920 S. 20 th St. Philadelphia, PA 19145 215.336.3511 Bucks, Chester, Delaware, Philadelphia Esperanza 4261 North 5th St. Philad elphia, PA 19140 215.324.0746 Philadelphia Fair Housing Partnership of Greater Pittsburg, Inc. 2840 Liberty Ave.; STE 05, Pittsburg, PA 15222 412.391.2535 Allegheny Fayette Co. Community Action Agency, Inc. 140 N Beeson Blvd Umo town, PA 15401 800.427.INFO 724.437.6050 Fayette, Somerset FOB CDC 1201 West Olney Aven Philadelphia, PA 19141 215.549.8755 Bucks, Chester, Delaware, Philadelphia, Garfield Jubilee Associates 5138 Penn Ave Pittsburgl , PA 15224 412-665-5200 Allegheny Germantown Settlement 5538 Wayne Ave; BLDG C Philadelphia, PA 19144 215.849.3104 Bucks, Chester, Delaware, Montgomery, Philadelphia Grace Neighborhood Development Corporation 5200 Oxford Ave Philade lphia, PA 19124 215.535.3885 Philadelphia Hetneved December 6, 2010 from http://www.phfa.org/forms/counseling?gencies/hemap_agencies/hemap.pdf Greater Erie Community Action Committee 18 West 9th St. Erie, P 16501 814.459.4581 Crawford, Venango, Erie, Warren Greater Philadelphia Asian Social Service Center 4943 North 5th St. Phil delphia, PA 19120 215.456.1662 Philadelphia RACE 167 W. Allegheny Ave.1 2nd Floor, Philadelphia, PA 19140 215.426.8025 Bucks, Chester, Delaware, Philadelphia Hispanic Alliance for Community Advancement 2740 North Front Street Philadelphia, PA 19133 215.667.8932 Philadelphia Housing Alliance of York 35 S Duke St York PA 7401 717.854.1541 York Housing Association of Delaware Valley 658 North Watts Street hiladelphia, PA 19123 215. 978.0224 York Housing Association of Delaware Valley 658 North Watts Street hiladelphia, PA 19123 215.978.0224 York Housing Association of Delaware Valley 1500 Walnut St. STE 6 1 Philadelphia 19140 215.545.6010 Philadelphia Housing Authority of Butler County 114 Woody Dr Butler, A 16001 724.287.6797 Butler Housing Opportunities of Beaver County 282 East End Ave Unit Beaver, PA 15009 724.728.7511 Beaver, Lawrence Housing Partnership of Chester County 41 W Lancaster Ave D ingtown, PA 19335 610.5181522 Chester, Delaware, Montgomery Indiana Co. Community Action Program 827 Water St., Box 187, Indiana, PA 15219 724.465.2657 Armstrong, Cambria, Clearfield, Indiana, Jefferson, Westmoreland Intercommunity Action, Inc. 6012 Ridge Av. Philade phia, PA 19128 215.487.0914 Philadelphia Intercultural Family Services, Inc. 4225 Chestnut S1 Philad lphia, PA 19104 215.386.1298 Philadelphia Korean Community Development Services Center 6055 N 5th St Philadelp is, PA 19120 215.276.8830 Philadelphia Lawrence County Social Services, Inc. PO Box 189, 241 W Cyr t St, New Castle, PA 16101 724.658.7664 724.658.7258 Lawrence Liberty Resources 714 Market St; STE 100 Philadelphia, PA 19106 215.634.2000 Philadelphia Mamnatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 Adams, Cumberland, Franklin, Fulton, Perry Media Fellowship House 4302 S Jackson St Medi a, PA 19063 610.565.0434 Chester, Delaware, Montgomery Mon Valley Unemployment Committee 338 E. Ninth Ave., 2nd floor, Homestead PA, 15120 412.462.9962 Allegheny, Washington, Westmoreland Mt. Airy, USA 6703 Germantown Ave. TE 200 Philadelphia, PA 19119 215.844.6021 Philadelphia Nazareth Housing Services 301 Bellevue Road Pitts burgh, PA 15229 412.931.6996 Allegheny Neighborhood Housing Services of Reading 213 N 5th St; STE 1030 Reading, PA 19601 610.372.8433 Berks Neighborhood Housing Services of Lackawanna County 709 E Market St Scranto , PA 18509 570.558.2490 Lackawanna,Luzeme, Wayne, Wyoming NeighborWorks of Western PA 710 Fifth Ave; STE 1000 Pittsburgh, PA 15219 412.281.9773 Allegheny, Armstrong, Beaver, Butler, Fayette, Washington, Westmoreland New Kensington Community Development Corp. 2515 Frankford Ave Phil adelphia, PA 19125 215.4220350 Philadelphia NID-Housing Counseling-Philadelphia 1518 West Susquehanna Avenue Philadelphia, PA 19150 267385.7624 Philadelphia Norris Square Civic Association 149 West Susquehanna A venue Philadelphia, PA 19122 215.426.8723 Philadelphia Northern Tier Community Action Corp. 135 West 4th Street PO ox 389 Emporium, PA 15834 814.486.1161 Cameron, Elk, McKean, Potter Northwest Counseling Service, Inc. 5001 North Broad Street Philadelphia, PA 19141 215.324.7500 Bucks, Chester, Delaware,Montgomery, Philadelphia PA Interfaith Community Programs Inc.Northemt 22 Willow Road Hamb , PA 19526 610.562.2288 Berks, Lebanon, Lehigh, Schuylkill Pennsylvania Housing Finance Agency 2275 Swallow Hill Rd, dg 200, Pittsburg, PA 15220 412.429.2842 Allegheny PA Interfaith Community Programs, Inc. 40 E High St Gettysburg PA 17325 717.334.1518 Adams, Franklin, Cumberland, York PHFA 211 N. Front St Harrisb g, PA 17] ]0 717.780.3940 800.342.2397 Cumberland, Dauphin Philadelphia Council for Community Advancement 1617 JFK Blvd; STE 155 Philadelphia, PA 19103 215.567.7803 800.930.4663 Chester, Delaware,Montgomery, Philadelphia Philadelphia Senior Center 509 South Broad Street iladelphia, PA 19147 215.546.5879 Philadelphia RHD-American Angel Housing Counseling 102 Pickering Way Suite 00 Exton, PA 19341 610.768.2811 Chester RHD-American Angel Housing Counseling 1060 First Avenue Suite 00 King of Prussia, PA 19406 610.733.2985 Montgomery RHD-American Angel Housing Counseling 600 West Germantown Pi PI oath Meetin PA 1 ke Suite 400 462 610.768.2811 Montgomery RHD-American Angel Housing Counseling Two Bala Plaza Suite 3 Bala Cynwyd, PA 19004 610.768.2811 Montgomery RHD-American Angel Housing Counseling Two Penn Center Plaza S ite 200 Philadelphia, PA 19102 610.768.2811 Philadelphia RHD-American Angel Housing Counseling 150 North Radnor Cheste- Radnor. PA 19087 Road Suite F200 610.768.2811 Delaware Schuylkill Community Action 225 N Centre St Pottsville , PA 17901 570.6211995 Berks, Carbon, Lebanon, Lehigh, Luzeme, Northumberland, Schuylkill Shenango Valley Urban League, Inc. 601 Indiana Ave Farrell, A 19121 724.981.5310 Crawford, Lawrence, Mercer South Philadelphia HOMES, Inc. 1444 Point Breeze Ave P iladelphia, PA 19146 215.334.4430 Philadelphia Southwest Community Development Corporation 6328 Paschall Ave Phil Iphia, PA 19142 215.729.0800 Philadelphia tcemevea uecemner o, 2010 Irom http://www.phfa.org/forms/counseling_Agencies/hemap_agencies/hemap.pdf Southwestern PA Legal Services 45 E Main St STE 200 Vniontown, PA 15401 724.439.3591 Fayette Southwestern PA Legal Services 63 S Washington St Wabnesburg, PA 15370 724.627.3127 Greene Southwestern PA Legal Services -Somerset County 218 West Kimberly Av nue Suite 101 Somerset, PA 15501 814.443.4615 Somerset Southwestern PA Legal Services Inc. 10 W Cherry Av. Wash gton, PA 15301 724.225.6170 Washington St. Martin Center 1701 Parade St Erie, P 16503 814.452.6113 Crawford, Erie, Venango, Warren Lycoming-Clinton Counties Commission for Community Action 2138 Lincoln St P.O.Bo 3568 Williamsport, PA 17701 570.326.0587 Centre, Clinton, Lycoming, Union Tableland Services Inc. 535 E Main St Somerse PA 15501 800.452.0148 Bedford, Cambria, Fayette Somerset Westmoreland 814.445.9628 , , TABOR Community Services, Inc. 308 E King St Ste. 1, caster, PA 17608 800.788.5062 Chester, Lancaster, Lebanon 717.397.5182 The Partnership CDC 4020 Market St; STE 1 Philadelphia, PA 19104 215.662.1612 Philadelphia The Pittsburgh Community Reinvestment Group 1901 Centre Avenue; S 200 Pittsburgh, PA 15219 412.391.6732 Allegheny The Trehab Center of Northeastem PA German Street, P.O. Bo 389, Dushore, PA 18614 570.928.9668 Sullivan 800.982.4045 The Trehab Center of Norteastem PA 10 Public Ave PO Box 66 Montrose, PA 18801 800.982.4045 Susquehanna, Wyoming 570.278.3338 The Trehab Center of Norteastern PA ] 47 Oak Ridge Drive To wanda, PA 18848 570.265.6179 Bradford 800.982.4045 The Trehab Center of Norteastem PA 52 Plaza Ln Wellsboro, A 16901 800.982.4045 Tioga 570.724.5252 United Communities Southeast Philadelphia 2029 S 8th St Philadelp is, PA 19148 215.467.8700 Philadelphia United Neighborhood Centers of Northeastern PA 425 Alder Street Scrant , PA 18505 570.346.0759 Lackawanna, Luzeme, Wayne, Wyoming Universal Companies 800 S 15th St Philadetp ia, PA 19146 215.732.6518 Philadelphia Urban League of Philadelphia 121 S Broad St; 9th FL hiladelphia, PA 19107 215.985.3220 Bucks, Chester, Delaware, Philadelphia Urban League of Pittsburgh 610 Wood Street Pittsb gh, PA 15222 412.227.4802 Allegheny Voices for Independence 1107 Payne Ave Erie, P, L 16503 800.838.9890 Erie 814.874.0064 Warren-Forest Counties I Economic Opportunity 1209 Pennsylvania Ave West, P.O.Box 547, Warren, PA Council EOC 16365 814.726.2400 Forest, Warren West Oak Lane Community Development Corporation CDC 7300 Ogontz Avenue Ph ladelphia, PA 19138 215.224.0880 Philadelphia Retrieved December 6, 2010 from VERIFICATION The undersigned, hereby tates that he/she is the attorney for the Plaintiff; that he/she is authorized to make this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents. The statements made in the foregoing pleading are true and correct to the best of his/her information and belief and the source of his information is public records and reports of Plaintiffs agents. The undersigned understands that this statement h ein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification t? authorities. UDREN LAW, OFWES, P.C. BY: ite L. Thomas, EsguWe PA 10 204460 UDREN LAW OFFICES, P. BY: MARK J. UDREN, ES( STUART WINNEG, ESQU] LORRAINE DOYLE, ESQI ALAN M. MINATO, ESQU CHANDRA M. ARKEMA, SHERRI J. BRAUNSTEIN, MARGUERITE L. THOM) DANIEL S. SIEDMAN, ES( JEROME B. BLANK, ESQI WOODCREST CORPORA' 111 WOODCREST ROAD, CHERRY HILL, NJ 08003-; 856-669-5400 AleadinLysnud ?. ATTORNEY FOR PLAINTIFF 2 UIRE - ID #04302 RE - ID #45362 IRE - ID #34576 , RE - ID #75860 SQUIRE - ID #203437 ' - • .- ESQUIRE - ID #90675 S, ESQUIRE - ID #204460 UIRE - ID #306534 IRE - ID #49736 'E CENTER iUITE 200 Deutsche Bank National Ti as Trustee for Argent Secu Asset-Backed Pass-Throug Series 2006-M2 4600 Regent Blvd, Suite 20, 75063 Plaintiff st Company, ties Inc., Certificates, Irving, TX COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. /I - 014111(p ?lw v. WENDELL C. BIGGS 222 EAST MAIN STREET SHIREMANSTOWN, PA 17 11 Defendant(s) TO THE PROTHONOTARY: Kindly enter the appe a Stuart Winneg, Esquire; Lo ir. Braunstein, Esquire; Chandra ?. ENTRY OF APPEARANCE of the following counsel: Mark J. Udren, Esquire; Doyle, Esquire; Alan M. Minato, Esquire, Sherri J. Arkema, Esquire; Marguerite L. Thomas, Esquire; ___ r 4 Daniel S. Siedman, Esquire and Jerome B. Blank, Esquire on behalf of the Plaintiff, in the above-captioned matter. UDREN L OFFICES, P.C. r? BY: 1. Thomas, Esquire M 204460 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ?gttHU? 4rt 4tuubrr?i?? r P 1 Fill Deutsche Bank National Trust Company Case Number vs. Wendell C. Biggs 2011-2906 SHERIFF'S RETURN OF SERVICE 03/10/2011 04:16 PM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on March 10, 2011 at 1616 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Wendell C. Biggs, by making known unto himself personally, at 222 E. Main Street, Shiremanstown, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $43.00 March 11, 2011 RONALD HOOVER, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF ;d! (;euntySURC 5herff Te!eos.)ft. mc, UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset- Backed Pass-Through Certificates, Series 2006-M2 Plaintiff V. WENDELL C. BIGGS 222 EAST MAIN STREETSHIREMANSTOWN, PA 17011 Defendant(s) ft ATTWlkh: FOR PLAINTIFF flnCpaUpNT"I', COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 11-2906 PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification for the Verification attached to the Complaint in Mortgage Foreclosure with regard to the captioned matter. DATED: October 27, 2011 UDRE LAW OFFICES, P.Q: BY,- Aft rn for PI iff Sherri 7. Braunstein, 1qb! PA ID 90675 MJU#: 11020928 CASE#: 11020928-1 UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 SHERRI 1 BRAUNSTEIN, ESQUIRE - ID #90675 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 DANIEL S. SIEDMAN, ESQUIRE - ID #306534 JEROME B. BLANK, ESQUIRE - ID #49736 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadinzs(a-),udren.com Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset-Backed Pass-Through Certificates, Series 2006-M2 Plaintiff V. WENDELL C. BIGGS 222 EAST MAIN STREET SHIREMANSTOWN, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. VERIFICATION The undersigned states that he/she is authorized to make this verification on behalf of the Plaintiff, and that the facts set forth in the foregoing pleading are true and correct to the best of the information and belief of the undersigned. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Date: 3 l Name: onyx op s Title: Assistant Sem "WY Company: American. Home Mortgage Servicing, Inc. as Servicer on behalf of Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc. Asset-Backed Pass-Through Certificates, Series 2006-M2 020q Z-0 - I UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadjngs@udren.com Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset-Backed Pass-Through Certificates, Series 2006-M2 1525 S. Beltline Rd. Coppell, TX 75019 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE V. WENDELL C. BIGGS NO. 11-2906 222 EAST MAIN STREET J m SHIREMANSTOWN, PA 17011 ; Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO - _.• ANSWER AND ASSESSMENT OF DAMAGES , TO THE PROTHONOTARY: C ? Q C J r , Kindly enter judgment in favor of the Plaintiff and against the Defendant(s), WENDELL C. -BIGGS; 6r failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: Unpaid Principal Balance Interest Per Complaint Additional Interest Late Charges Per Complaint Additional Late Charges Escrow Per Complaint Title Report Court Cost - Estimated Attorney Fees - Estimated Suspense Balance Recoverable Balance Grand Total FROM 02/25/2011 02/25/2011 TO 10/27/2011 10/27/2011 $66,586.80 $2,119.25 $3,564.75 $365.52 $243.68 $2,462.57 $325.00 $300.00 $1,300.00 $-419.93 $228.80 $77,076.44 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. UD LAW OFF ES, P.C. BY: Atto f r lal if 9*r" JPArawnst675 E1 DAMAGES ARE HEREBY ASSESSED AS INDICATED Ck?, ASS , i DATE: 1 r PR h G4 V ?° MJU#: 11020928 CASE#: 11020928-1 UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 DANIEL S. SIEDMAN, ESQUIRE - ID #306534 JEROME B. BLANK, ESQUIRE - ID #49736 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Pleadinasr udren.com Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset-Backed Pass-Through Certificates, Series 2006-M2 CARE OF 4600 Regent Blvd Suite 200 Irving, TX 75063 Plaintiff V. WENDELL C. BIGGS 222 EAST MAIN STREET SHIREMANSTOWN, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF rgs r-_ COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. i / ')W) 0111 1 COMPLAINT IN MORTGAGE FORECLOSURE 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 coy /MomC/)e/ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 4sv?farbrte? Jody S Smith Chief Deputy 4 2`` Richard W Stewart Solicitor f E OF s114 CINSF ` Deutsche Bank National Trust Company vs. Case Number Wendell C. Biggs 2011-2906 SHERIFF'S RETURN OF SERVICE 03/10/2011 04:16 PM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on March 10, 2011 at 1616 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Wendell C. Biggs, by making known unto himself personally, at 222 E. Main Street, Shiremanstown, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. RONALD HOOVER, DEPtlTY SHERIFF COST: $43.00 March 11, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF {cj t ou!-'tyS] ;te Sheriff. T6eosoft. l,c. IIDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 #11020928-1 Deutsche Bank National Trust Company, as Trustee for Argent Securities, Inc., Asset-Backed Pass-Through Certificates, Series 2006-M2 Plaintiff V. Wendell C. Biggs Defendant(s) TO: Wendell C. Biggs 222 E. Main Street Shiremanstown, PA 17011 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 2011-2906 Date of Notice: 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 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 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. LAWYER REFERRAL SERVICE Cumberland County Bar Assocation 2 Liberty Avenue Carlisle, PA 17013 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR,, THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED W1`LL BE USED FOR THAT PURPOSE. _.l ll ?? Daniel S. Siedman, Esquire PA ID 306534 Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-2906 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR ARGENT SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2006-M2 Plaintiff (s) From WENDELL C. BIGGS (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: $77,076.44 L.L.: $.50 Interest FROM 10/28/11 TO DATE OF SALE JUNE 6, 2012 - ONGOING PER DIEM OF $14.55 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $3,244.65 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $180.00 Other Costs: Plaintiff Paid: Date: -'/7/12 1 . It.J UA_? David D. Buell, Prothonotary (Seal) Deputy REQUESTING PAR Y: Name: KASSIA FIALKOFF, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 310530 FILEG-OFFiCE UDREN LAW OFFICES, P.C. O E PROTHONOTA TORNEY FOR PLAINTIFF WOODCREST CORPORATE CENT FEB -1 AM 10: 45 111 WOODCREST ROAD, SUITE 20 CHERRY HILL, NJ 08003-3620 CUMBERLANO COUNTY 856-669-5400 PENNSYLVANIA pleacLn$sa,udren.com Deutsche Bank National Trust Company, COURT OF COMMON PLEAS as Trustee for Argent Securities Inc., Asset- CIVIL DIVISION Backed Pass-Through Certificates, Series Cumberland County 2006-M2 Plaintiff MORTGAGE FORECLOSURE V. Wendell C. Biggs NO. 11-2906 Defendant(s) PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due $.77,076.44 Interest From 10/28/11 $ 3,244.65 to Date of Sale June 6, 2012 Ongoing Per Diem of $14.55 to actual date of sale including if sale is held at a later date (Costs to be added) $ S XV& ? 3. oo Ct3? a ?d Q MJU#: 11020928 CASE#. 1020928-1 UDREN LAW OFFICES, P.C. B Attorney for Plaintiff KASSIA FIALKOFF, ESQUIRE PA ID 310530 cat.aS 12 -V? oQ -7b-7 S7 wr?+ or 2cc-- OE201L GI A4 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 lp eadings @udren.com Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset- Backed Pass-Through Certificates, Series 2006-M2 Plaintiff V. Wendell C. Biggs Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 11-2906 C-) c .Vx rnw ?rn ac ? En ? z? --s N 0 ran €a? s -J x+. .c- cn . --z rn? `o ran C> c?-T D --c CERTIFICATE OF ACT 91 I hereby state that as the attorney for the Plaintiff in the above-captioned matter: F? Act 91 procedures have been fulfilled a Premises is not subject to the provisions of Act 91 as this is an FHA insured mortgage This statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. BY;o-? Attorney for Plaintiff KASSIA FIAIKOFF, ESQUIRE PA ID 310530 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadinp.s aO,udren.com Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset- Backed Pass-Through Certificates, Series 2006-M2 V. Wendell C. Biggs ATTORNEY FOR PLAINTIFF Plaintiff Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 11-2906 AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 rv rn? ter'' M M rn_ :--- CD < CD ys ? T 1 ca-? crr Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset- Backed Pass-Through Certificates, Series 2006-M2, Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 222 East Main Street, Shiremanstown, PA 17011 1. Name and address of Owner(s) or reputed Owner(s): Wendell C. Biggs 222 East Main Street Shiremanstown, PA 17011 2. Name and address of Defendant(s) in the judgment: Wendell C. Biggs 222 East Main Street Shiremanstown, PA 17011 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Jr Lien Holders - None 4. Name and address of the last recorded holder of every mortgage of record: Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset- Backed Pass-Through Certificates, Series 2006-M2 1525 S. Beltline Rd. Coppell, TX 75019 Sr Mortgage Holders - None Jr Mortgage Holders - None 5. Name and address of every other person who has any record lien on the property: Sr lien Holders - None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Tenants/Occupants 222 East Main Street Shiremanstown, PA 17011 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: Federal Tax Lien Holders - None Condo/Homeowners Association - None I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: r`llc? UDREN LAW OFFICES, P.C. Bf Attorney for Plaintiff MJU#: 11020928 CASE#: 11020928-1 KASSTA FTALKOFF, ESQUIRE UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings(J&udren.com _ Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset- Backed Pass-Through Certificates, Series 2006-M2 V. Plaintiff Wendell C. Biggs Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 11-2906 AFFIDAVIT OF LAST KNOWN ADDRESS UNDER RULE 76 The Defendant(s) last known address is as follows: WENDELL C. BIGGS 222 EAST MAIN STREET SHIREMANSTOWN, PA 17011 rnrn r.". -c 2G O --t This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. Attorney for Plaintiff ran 70o C-) --i v ©c 0 KASSIA D ID AR"O"530 DIRE ??C77k.#1?1? ,, '?:?aIE r' UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadinss a()udren.com Deutsche Bank National Trust Company, COURT OF COMMON PLEAS as Trustee for Argent Securities Inc., Asset- CIVIL DIVISION Backed Pass-Through Certificates, Series Cumberland County Y. 2006-M2 C-) - Plaintiff MORTGAGE FORECLOSURE .,,3 V. W -'9 ro ? ct?r- ! g WENDELL C. BIGGS NO. 11-2906 --? Defendant(s) :Cc y c) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY Z5 v TO: Wendell C. Biggs 222 East Main Street Shiremanstown, PA 17011 Your house (real estate) at 222 East Main Street, Shiremanstown, PA 17011 is scheduled to be sold at the Sheriffs Sale on June 6, 2012 at 10:00 am at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $77,076.44, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. 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 cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) r" 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 856-669-5400. 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 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. 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 Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin -s u)udren.com Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset- j Backed Pass-Through Certificates, Series 2006- M2 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE ATTORNEY FOR PLAINTIFF V. WENDELL C. BIGGS, Defendant(s) NO 11-2906 AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: r-rl 1-71 -Z.,J u? r- ?F. < tzw r? 1. A copy of the Notice of Sheriffs Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriffs Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: MJU#: 11020928 CASE#: 11020928-1 PAIGE M. BELLINO, ESQUIRE PA ID 309091 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY MILL, NJ 08003-3620 856-669-5400 pleadings udren.com Deutsche Dank National Trust Company, as Trustee for Argent Securities Inc., Asset- Backed Pass-Through Certificates, Series 2006-M2 Plaintiff V. Wendell C. Biggs Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 11-2906 AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset- Backed Pass-Through Certificates, Series 2006-M2, Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 222 East Main Street, Shiremanstown, PA 17011 1. Name and address of Owner(s) or reputed Owner(s): Wendell C Biggs 8 Deer Lake, Apartment A Lewisberry, PA 17339-9730 2. Name and address of Defendant(s) in the judgment: Wendell C. Biggs 8 Deer Labe, Apartment A Lewisberry, PA 17339-9730 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Jr Lien Holders - None 4. Name and address of the last recorded holder of every mortgage of record: Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset- Backed Pass-Through Certificates, Series 2006-M2 1525 S. Beltline Rd. Coppell, TX 75019 Sr Mortgage Holders - None Jr Mortgage Holders - None 5. Name and address of every other person who has any record lien on the property: Sr lien Holders - None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Real Estate Tax Department 1 Courthoudse Square Carlisle, PA 17013 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, Pal 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Tenants/O cupants 222 East Main Street Shiremanstown, PA 17011 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: Federal Tax Lien Holders - None Condo/HoMeowners Association - None I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: / UDR W OFFICES BY: -n I rV 00V Attorney f laintiff MJU#: 11020928 CASE#: 11020928-1 OUW* P : SELLmo, ESQUIRE PA 10- 309091 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY )}TILL, NJ 08003-3620 856-669-54 0 eutsc a 'an ahona rust ompany, COURT OF COMMON PLEAS as Trustee! for Argent Securities Inc., Asset- Backed Phss-Through Certificates, Series CIVIL DIVISION 2006-M2 Cumberland County Plaintiff V. MORTGAGE FORECLOSURE WENDELL C. BIGGS Defendant(s) NO. 11-2906 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S)I: WENDELL C. BIGGS PROPERTY: 222 East Main Street, Shiremanstown, PA 17011 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on 06/06/2012 at 10:00 AM, at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013. Our records indicate that you may hold a mortgage or judgment on the property, which will be extinguished by the sale. You may wish to attend the sale to protect your interests. The Sheriff will file a Schedule of Distribution on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. MJU#: 110210928 CASE#: 11020928-1 XHIBIT A c cn 0 M 0 tD C7 V V co v N 2 O N O co N 00 c C CD 3 O Q 3 C w O Q 7 xr ?1 O A m L" A W N -i O V O 0 A W N - Dd am * C Z m y C CL ? 0 8i Q w i o> gm w ZN !c a0jgc zmj8 0 ? ? ¢ Q 0 ?Z ? r z? qAD o ?c ? ;V 5q; W m0 cf) 0 06 Zr"(A rM -i 0- moo o cj) C ? pc OZ?o n 0 ) ,m x ,m. ;mmo8 CD c co 0 m 7 ?7CGDv ?n r- 2 (1) Z m N mn D0 m ry-D $ o n ? NS D D? ? g m n? m o o p W W , ???? 2891 m 3 ?16ti2?51???16 ?? ? O 0A i3 0/2012 Mailed From 0$003 gO y cp US POSTAGE o 9 n? ??R B - 1-0 ill ? IC ? W ^D A u o ?v I ?" ? • _ m ?. _ m a' C S I U II ? ? 9. 8 - aa.x 2 n? ?N Q m ? a og -n ? y m. c3 O a a T1 fn b ,,, Q y Tm CCD 3 1T UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODICREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset-Backed Pass-Through Certificates, Series 2006-M2 Plaintiff V. WENDELL C. BIGGS Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County i NO. 11-2906 PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: 'W41- UDREN LAW OFFICES, P.C. BY: Attc PAIGE M. 6eLLIN0, ESQUIRE PA ID 309091 EXHIBIT B 41'111'2012 2:55 PM FROM: Fax Civil Action Group, Ltd. TO: 17172448D49 PAGE: 001 OF D02 Deutsche Bank National Trust Company, as Trustee, eL al., Plaintiff(s) VS. Wendell C. Biggs, eL al., Defendant(s) UDREN LAW OFFICES Ms. Henni Crpmnrarty 111 Woodcrest Rd., Ste. 200 Cherry Hill, NJ 08003-3620 Service of Process by APS International, Ltd. 1-800-328-7171 APS INTBRNAT10NA1 APS International Plaza 7800 Cienroy Rd. Minneapolis, MN 55439-3122 APS File #: 116159-0001 AFFIDAVIT OF SERVICE -- Individual Service of Process on: --Wendell C. Biggs Court Case No. 11-2906 State of• - - -? ,?' -) ss- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - County of: O ,- H ` 7? Name of Server: /) L V r3 !>? / 1 I- , undersigned, being duly sworn, deposes and says that at the time of service, s/he was of legal age and was not a party to this action; Date/Time of Service: that on the day of Ogg 20 1_ {j at 7:4 0o'clock m Place of Service: at 8 Deer Lake - U-T . , in Lewisberry. PA 17339-9730 Documents Served: the undersigned served the documents described as: Notice of Sheriff's Sale of Real Property Service of Process on: A true and correct copy of the aforesaid document(s) was served on: Wendell C. Biggs Person Served, and By personally delivering them into the hands of the person to be served. Method of Service: ? By delivering them into the hands of , a person of suitable age, who verified, or who upon questioning stated, that he/she resides with Wendell C. Biggs / at the place of service, and whose relationship to the person is: Description of Person The person receiving documents is described as follows: Receiving Documents: Sex _jQ21; Skin Color k//ti i ; Hair Color b AT ;Facial Hair Approx. Age Approx. Height ,S-° J ,Approx. Weight ! ? t\ ? To the best of my knowledge and belief, said person was not engaged in the US Military at the time of service. Signature of Server. Undersigned declares under penalty of perjury that the foregoing is true and correct. Signature of Server APS International, Ltd. Subscfibed and s7 rn to before me this day of 20 tMy N(C missi on Ex ires NOTARIAL SEAL JAYNE L ENGLAND Notary Public CHESTER TWP., YORK COUNTY mission Expires Dec 17, 2013 EXHIBIT E l UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY IIILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset-Backed Pass-Through Certificates, Series 2006-M2 Plaintiff V. WENDELL C. BIGGS Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 11-2906 PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: r_ ::7? Kindly file the attached Proofs of Service with regard to the captioned matter. Date: a?,j?ly UDREN LAW OFFICES, P.C. BY: Attc PAIGE M. kiLINO, ESQUIRE PA ID 309091 4,17!2012 2:55 PM FROM: Fax Civil Action Group, Ltd. TG: 17172498049 PAGE: 001 OF O07 Deutsche Bank National Trust Company, as Trustee, et. al., Plaintiff(s) VS. Wendell C. Biggs, et. al, Defendant(s) UDREN LAW OFFICES Ms. Henni Croinmarty 111 Woodcrest Rd., Ste. 200 Cherry Hill, NJ 08003-3620 Service of Process by APS International, Ltd. 1-800-328-7171 APS International Plaza 7800 Clenroy Rd. Minneapolis, MN 55439-3122 APS File #: 116159-0001 AFFIDAVIT OF SERVICE -- Individual Service of Process on: --Wendell C. Biggs Court Case No. 11-2906 State of- 17 ',;X:? -_) ss. -- - - - - - - - - - - - - - - - - County of: Q /, /< l T Name of Server: /,) ?L , undersigned, being duly sworn, deposes and says that at the time of service, s/he was of legal age and was not a party to this action; Date/Time of Service: that on the day of 20 JA at 7 4''o'clock ?2 M Place of Service: at 8 Deer Lake - / . in Lgydsberrv. PA 17339-9730 Documents Served: the undersigned served the documents described as: Notice of Sheriff's Sale of Real Property Service of Process on: A true and correct copy of the aforesaid document(s) was served on: Wendell C. Biggs .uv__.-.___.____.._ _ Person Served, and Method of Service: X By personally delivering them into the hands of the person to be served. ? By delivering them into the hands of a person of suitable age, who verified, or who upon questioning stated, that he/she resides with Wendell C. Biggs ?X L/ at the place of service, and whose relationship to the person is: Description of Person The person receiving documents is described as follows: Receiving Documents: Sex Skin Color Hair Color ?; ?4j It T ;Facial Hair Approx. Age-Approx. Height Approx. Weight ?D ? To the best of my knowledge and belief, said person was not engaged in the US Military at the time of service. Signature of Server: Undersigned declares under penalty of perjury Subsefibed and s rn to before me this that the foregoing is true and correct. day of , 20 . Signature of Server NtMy (Commission Expires) APS International, Ltd. NOTARIAL SEAL JAYNE L ENGLAND Notary Public CHESTER TWP., YORK COUNTY mission Expire s Dec 17, 2013 __ _ _ r __ SHERIFF'S OFFICE OF CUMBERLAND COUNTY RonnyRAnderson ~'{~.;~~-~;'-.c. ~~- ~~ Sheriff ~±' i ~~ ~n~7N~'r(,-~ ~,~ ~~~1ttS~ of +:1unbPp~~~~ ; t5~ ~~i~"S Jody S Smith ~ ~. p~~ ~~ ~~ ~. ~~ Chief Deputy ~,j ~-f:; ;r~ Richard W Stewart ~ ~" ~~~.~, ~~ Solrc~tor i=$ ~F ~ -~~ ~ ~: ~F v i~~~ Deutsche Bank National Trust Company Case Number vs. Wendell C. Biggs 2011-2906 SHERIFF'S RETURN OF SERVICE 03/21/2012 04:37 PM -Deputy Shawn Gutshall, being duly sworn according to law, states service was performed E posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action upon the property located at 222 E. Main Street, Shiremanstown Borough, Shiremanstown, PA 17011, Cumberland County. 03/21/2012 04:37 PM -Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligE search and inquiry for the within named Defendant, to wit: Wendell C. Biggs, but was unable to locate t Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in tl above titled action, as "Not Found" at 222 East Main Street,- Shiremanstown, PA 17011, defendant is rn known at address by the post office, neighbor states that defendant moved from premises in October 2011. 06/05/2012 As directed by Marguerite L. Thomas, Attorney for the Plaintiff, Sheriffs Sale Continued to 8/8/2012 08/01/2012 As directed by Marguerite L. Thomas, Attorney for the Plaintiff, Sheriffs Sale Continued to 10/3/2012 08/22/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $1,487.58 SO ANSWERS, August 23, 2012 RON R ANDERSON, SHERIFF a• mss' ,~ . ~o . ,~~ ~_ c ~ ~~ ~"~r~ " ~~ >s~ (c) ~cu^:ySuite She^'f, Te!eesoft, :rn. :' UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIF~ pleadings a(~,udren.com Deutsche Bank National Trust Company ~ COURT OF COMMON PLEAS as Trustee for Argent Securities Inc., Asset- ~' CIVIL DIVISION Backed Pass-Through Certificates, Series ~ Cumberland County 2006-M2 Plaintiff 'MORTGAGE FORECLOSURE v. Wendell C. Biggs Defendant(s) NO. 11-2906 AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset- Backed Pass-Through Certificates, Series 2006-M2, Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of th date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 222 East Main Street, Shiremanstown, PA 17011 1. Name and address of Owner(s) or reputed Owner(s): Wendell C. Biggs 222 East Main Street Shiremanstown, PA 17011 2. Name and address of Defendant(s) in the judgment: Wendell C. Biggs 222 East Main Street Shiremanstown, PA 17011 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Jr Lien Holders -None 1r 4. Name and address of the last recorded holder of every mortgage of record: Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset- Backed Pass-Through Certificates, Series 2006-M2 1525 S. Beltline Rd. Coppell, TX 75019 Sr Mortgage Holders -None Jr Mortgage Holders -None 5. Name and address of every other person who has any record lien on the property: Sr Lien Holders -None 6. Name and address of every other person who has any record interest in the property and interest maybe affected by the sale: Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Tenants/Occupants 222 East Main Street Shiremanstown, PA 17011 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which maybe affected by the sale: Federal Tax Lien Holders -None Condo/Homeowners Association -None I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: ~ ~~`3~c"~CI~. UDREN LAW OFFICES, P.C. B~ Attorney for Plaintiff MJU#: 11020928 CASE#: 11020928-1 KASSTA FTALKOFF, ESQUIRE ' ,G530 .' ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County Plaintiff '~ MORTGAGE FORECLOSURE ~• I WENDELL C. BIGGS NO. 11-2906 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadinss(a ,udren.com Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset- ~, Backed Pass-Through Certificates, Series 2006-M2 TO: Wendell C. Biggs 222 East Main Street Shiremanstown, PA 17011 Your house (real estate) at 222 East Main Street, Shiremanstown, PA 17011 is scheduled to sold at the Sheriff s Sale on June 6, 2012 at 10:00 am at the Cumberland County Courthou Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgme of $77,076.44, obtained by Plaintiff above (the mortgagee) against you. If the sale is postpone the property will be relisted for the Next Available Sale. 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: The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonably attorney's fees. To fmd out how much you must pay, you may call: (856) 669-5400. 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. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) T 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 856-669-5400. 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 fins out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You maybe 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 within 30 days after the sale. 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 Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800)990-9108 __~_. All that certain house and lot of land situate in the Borough of Shiremanstown, Cumberland County, Pennsylvania, bounded and described as follows, to wit: Beginning at a point on the Southern Street line of East Main Street, corner of land of Daisy Wentz; thence along said Souther: Street line of East Main Street in an eastwardly direction twenty and two-tenths (.20.2) feet to a point; thence along the line of other lands of John B. Carbaugh and Frances F. Carbaugh, his wife, of which this was a part, and through the partition wall of the dwelling erected on the premises herein described any the dwelling on the lot immediately adjacent on the East, and beyond, in a southwardly direction South 2 degrees East one hundred sixty-one and seven-tenths (161.7) feet (passing through the center of a double frame garage building), to a poin marked by an iron pipe in the northern line of Cortland Alley; thence along said northern line of Cortland Alley in a westwardl direction twenty (20) feet to a pipe; thence along the line of land of Daisy Wentz, aforesaid, in a northwardly direction North 2 degrees West one hundred sixty-one and seven-tenths (161.7) feet to a point on the southern line of East Main Street, the point and place of Beginning. Having erected thereon the western one-half of a double, two and one-half (2 1/2) story, frame dwelling house, known and numbered as 222 East Main Street, Shiremanstown, Pennsylvania. BEING KNOWN AS: 222 East Main Street, Shiremanstown, PA 17011 PROPERTY ID NO.: 37-23-0555-211 TITLE TO SAID PREMISES IS VESTED IN Wendell C. Biggs, single person BY DEED FROM Arthur G. Biggs and Frances I. Biggs, his wife DATED 08/01/1996 RECORDED 08/13/1996 IN DEED BOOK 144 PAGE 97. ' ~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 11-2906 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR ARGENT SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2006-M2 Plaintiff (s) From WENDELL C. BIGGS (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRII'TION . (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: $77,076.44 L.L.: $.50 Interest FROM 10/28/11 TO DATE OF SALE NNE 6, 2012 -ONGOING PER DIEM OF $14.55 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $3,244.65 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $180.00 Other Costs: Plaintiff Paid: Date: 2/7/12 David D. Buell, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: KASSIA FIALKOFF, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 TRUE COPY FROM RECORD to Testimony whereof, 1 here unto set my h CHERRY HILL, NJ 08003-3620 and the seal of said Court~a~!si 20 L Attorney for: PLAINTIFF This _~,_day of prot~ Telephone: 856-669-5400 ~~'~ ~~ Supreme Court ID No. 310530 On February 9, 2012 the Sheriff levied upon the defendant's interest in the real property situated in the Borough of Shiremannstown, Cumberland County, PA, known and numbered 222 East I~flain Street, Shiremanstown, PA, 17011 more fu!!y described on Exhibit"A" filed with this writ and by this reference incorporated herein. Date: Feb uary 9, 20:12. Ry. w For Claudia Brewbaker, Real Estate Coordinator € 0 ~~ c~ ~ - ~?.~ llOl a~l~:',J _: , CUMBERLAND LAW JOURNAL Wdt No. 2011-2906 Civil Term Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset-Backed Pass-Through Certificates, Series 2006-M2 vs. Wendell C. Biggs Atty.: Kassia Fialkoff ALL THAT CERTAIN lot of land sit- uate in Borough of Shiremanstown, Cumberland County, Pennsylvania: BEING KNOWN AS 222 East Main Street, Shiremanstown, PA 17011. PARCEL NUMBER: 37-23-0555- 211. IMPROVEMENTS: Residential Property. 37 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 anc State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland La` Journal, a legal periodical published in the Borough of Cazlisle in the County and State aforesa 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 regulazl; issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regulaz editions and issues of the said Cumberland Law Journal on the following dates, 27, May 4, and May 11, 2012 Affiant further deposes that he is authorized to verify this statement by the Cuml Law Journal, a legal periodical of general circulation, and that he is not interested in the matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and chazacter of publication aze true. sa arie Coyne, Edito SWORN TO AND SUBSCRIBED before me this da of Ma ~, 2012 Notary ~ NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 The Patriot-News Co "'020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERiF~F `> OFi~=iGE CUMBERLAND COUNTY CO' JRT F!i)USE t~he~Jahiot-'News NOw you know CARLISLE Pr 17013 7HE PATRIOT NEWS -THE SUNDAY PATRIOT NEWS Proof of Publication ~naer Act No 587 Approved May 16, 1929 ~ornmc~lweal'h of Pennsylvania, County of Dauphin) ss Holly Btain. being duly sworn accord:r g tc 'aw. 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 30i), in the Township of Hampden, County of Cumberland State of Pennsylvania, owner and publisher of The Patriot-News and The Sunray Patriot-News newspapers of general circulation. panted 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. 194 respectively, and all have been continuously published ever since; That the printed notice or publicaban which is securely attached hereto is exactly as printed and published in their reguia 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 c;f said printed notice or advertising, and that all of the allegations of th s statemen+ <~s 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 th;s statement o'' behalf of The Patriot-News Co. aforesaid by r rtue and pursuant to a resolution unanimously passed and adopted ~:everally by :h stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of DeE~d 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: 04/27/12 2011.2gOg Ch-11 Term ~ sche Bank National 'r'ust as TFustee fo ~ nY' gent Securlites InC., ASSet- Backed pass-Through CerHt2~ ,Series M2 VS Wendell C. Biggs AnY: Kassla Fialkoff ~ 7iTHAT CERTAIN LOT OF SITUATE IN BOROUGH OF S MANSTOWN CUMBERLAnrD CO;INTy, PENNSYLVANIA: BEING KNOWN ~ 222 East Main Street, Shiremanstown, PA 17011 PARCEL NUMBER: 37-23-0555-211 IMPROVEMENTS: Residential Progeny 05!04112 05/1111 :~ ,t y Swc!n to and subscribed before~ln~,this 22 day of May. 2012 A.D Notary Public COMMONWEALTH Of PENNSYLVANi1~~ Notarial Seai ~ Sherrie 4. Owens, Notary Public i 1_bwer Paxton rwp., Dauphin CounC, L My Commission Expires Nov. 26, 2015 "4FMEER FENNSVLYAivla, ASSOCIATION OF NO-~ARIE