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HomeMy WebLinkAbout11-4730UDREN 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 HEATHER RILOFF, ESQUIRE - ID #309906 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsAudren.com Deutsche Bank National Trust Company, As Trustee For The Pooling And Servicing Agreement Dated As Of January 1, 2007 Securitized Asset Backed Receivables LLC Trust 2007-NC1 C/O Ocwen Loan Servicing, LLC 1661 Worthington Road #100 West Palm Beach, FL 33409 Plaintiff V. CHAD MILLER P. O BOX 633 SHIPPENSBURG, PA 17257-0633 Defendant(s) ATTORNEY FOR PLAINTIFF c-> M COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County No. II- y?3° Ciu0 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 FORT BELOW. # , g; ao g4;g- W1 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. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed 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 judgment 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 1. Plaintiff is the entity designated in the caption on a preceding page. Plaintiff is the legal holder of the Mortgage that is the subject of this Action. Plaintiff is either the current mortgagee 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 virtue 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: Mortgage Electronic Registration Systems, Inc. as nominee for Mercantile Mortgage Company Assignee: Deutsche Bank National Trust Company, As Trustee For The Pooling And Servicing Agreement Dated As Of January 1, 2007 Securitized Asset Backed Receivables LLC Trust 2007- NC1 Date of Assignment: 09/01/2010 Recorded Date: 04/29/2011 Book/Instrument #: Instrument #201112564 Page: n/a 2. Upon information and belief Defendant(s): Chad Miller (hereinafter 'Defendants"), are the owners of property located at 21-23 North Washington Street, Shippensburg, PA 17257, by virtue of Deed dated 07,124/2006 and recorded 08/10/2006 in Official Records Book 276 at Page 614 of the Public Records of Cumberland County, Pennsylvania (hereinafter the 'Property"),. 3. On 08/08/2006, Defendant(s): CHAD MILLER promised to pay to the order of Mercantile Mortgage Company, the principal sum of $ 127,120.00 payable with interest thereon provided in the Note. 4. By Mortgage dated 08/08/2006, Defendant(s): CHAD MILLER to secure the Note, mortgaged to Mortgage Electronic Registration Systems, Inc. as nominee for Mercantile Mortgage Company, the Property which is the subject of this action. The Mortgage was recorded on 08/10/2006 in Official Records Book 1961 at Page 4585. Said Mortgage is incorporated herein by referenced in accordance with Pa.R.C.P 1019(g). A legal description of the mortgage premises is attached hereto and made a part hereof. 5. Said mortgage is in default in that the payment due 11/01/2010, and all subsequent payments have not been made, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with the other charges authorized by said Mortgage and itemized below, shall be immediately due. 6. After demand, the Defendant(s) continues to fail or refused to comply with the terms of the Mortgage as follows: (a) By failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) By failing or refusing to pay other charges, if any, indicated below. The following amounts are due on the said Mortgage or modification agreement as of the date stated below Unpaid Principal Balance Accumulated Interest Accumulated Late Charges Escrow Deficit/(Reserve) Title Search Attorney Fees - Estimated Property Inspection Fee Prior Servicer Fees Other Suspense Balance Grand Total The above figures are calculated as of 05/31/2011: $122,884.44 $7,167.12 $100.26 $2, 0'79.97 $300.00 $1,300.00 $:31.50 $10.50 $-649.39 $133,224.40 The interest rate is subject to adjustment if more fully described as such in the note and mortgage. The interest rate on the subject note is at 8.77500 %. The per diem interest accruing on this debt is $29.77 and that sum should be added each day after the above date. The late charge is subject to adjustment if more fully described as such in the note and mortgage. The late charge rate on the subject note should be added in accordance to the terms of the note and mortgage charged monthly at $50.13. 7. Breach letters have been sent to Defendant(s) in accordance with the requirements of the subject mortgage, The Pennsylvania 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 attached hereto as Exhibit "A". WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $133,224.40 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged premises. UDREN LAW OFFICES, P.C. BY. +4c- ?'a iCJ a'67Z fill I - q, ?F IL. ??KS? X46 P? qtr * a?a! .? Tri tsix ?}. UN-T _ qF = t E t t flits l-R? T TILI T Ocwen Loan Servicing, LLC P.O. Box 24737 . C .. W - E - N ' West Palm Beach, Florida 33416-4 73 7 O C (Do not send correspondence or payments to the above address) X1'1 VV.OCWEN.COM December 31, 2010 VIA First Class Mail VIA Certified Mail (return receipt requested) Certified Number: 71069017515138628552 Reference Code: 1011 Chad Miller Po Box 633 Shippensburg, PA 17257-0633 Loan Number: 705984441 Property Address: 21-23 Washington Street , Shippensburg, PA 17257-0000 PLEASE SEE THE ENCLOSED DOCUMENT DACT91.19 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt Ocwen Loan Servicing, LLC 0P.O. Box 24737 O C W E N West Palm Beach, Florida 33416-4737 -- •° - (Do not send correspondence or payments to the above address.) W W V,_nC; WEN.Com December 31, 2010 APPENDIX A ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that he mortgage on your home is in default and the lender intend to foreclose. Specific information about the nature of the default is provided in the attached pages The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP may be able to hem to save your home.. This Notice explains how the program works. To see if HEMAP can help you must MEET WITH A CONSUMER EDIT COUNSELING AGENCY WITHIN THIRTY (30) DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the_ Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice If you have any questions. you may call the Pennsylvania Housing Finance Agency toll free at (800) 342-2397 (Persons with impaired hearing can call (712) 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 to contact an attorney in_your area, The local bar association may be able to help you find a lawyer LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION, OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO A ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. USTED PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: Chad Miller 21-23 Washington Street Shippensburg, PA 17257-0000 705984441 OCWEN DACT91.19 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt Ocwen Loan Servicing, LLC P.O. Box 24737 `-O' West Palm Beach Florid 0 0 W E N , a 33416-4 73 7 (Do not send correspondence or payments to the above address) HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE YOU CH AN AVE YO IR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPO RARY STAY OF FORECL OSURE Under the Art, you Are e ntitled to a temDoraM st ay of foreclosure on. your mo rtgage for thirty _(30) days fr om the date of this Notice. During t hat time you must arrang e and attend a "fac to-face" with one f th me ti di e- MUST O o e con e ng CCUR WITHIN THE NE sumer cre t counseling agencies di XT (30) DAYS IF YOU DO NOT ted at the end of this Noti APPLY FOR ce, T HIS ni "TIN ASSISTA NCE. YOU MUST BRIN , G YOUR MORTGAGE UP TO EMERGE DATF THE PART NCY MORTGAGE OF THIS NOTiCE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLA INS HOW TO BRING Y - DiiR MORT(_AGF UP TO DATE. CONSUMER EDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the proper is located are et forth at the end of this Notice. It is only necessary to schedule one face- to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORT A ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance). HOW TO CURE. YO MORTGAGE DEF-A T (Bring it up to date)iVW 1V.OCWEN.COM DACT9I.19 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt Ocwen Loan Servicing, LLC P.O. Box 24737 0 C °• W E N West Palm Beach, Florida 33416-4737 O C (Do not send correspondence or payments to the above address) WX " QCVEN ('QM NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property located at: 21-23 Washington Street, Shippensburg, PA 17257-0000 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 2 payments in the amount of $ 1,321.70 from November 01 2010 through Dece DETAIL M ARY mber 31, 2010 : Principal and Interest ................................. $ 2,005.20 Interest Arrearage ..................................... S O.00 Escrow .................................................. $ 638.20 Late Charges ........................................... S 100.26 Insufficient Funds Charges ........................... $ 0.00 Fees / Expenses ........................................ $ 10.50 Suspense Balance (CREDIT) ........................ $ 649.39 Interest Reserve Balance (CREDIT) ................ $ 0.00 TOTAL DUE .......................................... $ 2,104.77 HOW TO CURE T DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,104.77, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by Money Gram Cashier's Check Certified Check or Money Order ma e. payable and sent to: OCWEN P.O. BOX 6440 CAROL STREAM, IL 60197-6440 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intend to exercise i rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your lortgage property. IF THE MORT A IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, yo u will not be required to ply attorney's fees OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DE AU p IOR TO SHERIFF' SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff ale You may do so by no the total amount then. past due. plus anv late or other ch9raes then aue reocnn.hln ..++ ............. 'r___ ______ _ - other requirements nnaer the mort?a??g. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EAUIEST PO SIB H iFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default DACT91.19 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt Ocwen Loan Servicing, LLC P.O. Box 24737 `-° O G W E - E N West Palm Beach, Florida 33416-4737 (Do not send correspondence or payments to the above address) WWW.OCWEN.COM will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the servicer. HOW TO CONTACT THE SERVICER: Name of Servicer: OCWEN Address:: P.O. BOX 24737 WEST PALM BEACH, FL 334164737 Phone Number: 800-310-9229 Fax Number: 407-737-6300 Contact: Early Intervention Dept EFFECT OF SHERIFF'S SALE _ You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE _ You may or X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO V THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE (3) TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER RFT)LT OLJNSFL rN A FNCI S SFILVING YOUR nr1NTY DACT91.19 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt Ocwen Loan Servicing, LLC P. 0. Box 24737 O O W E N West Palm Beach, Florida 33416-4737 (Do not send correspondence orpayments to the above address.) R W4L OCW'EN.COM December 31, 2010 'VIA First Class Mail VIA Certified Mail (return receipt requested) Certified Number: 71069017515138628569 Reference Code: 1011 Chad Miller 21-23 Washington Street Shippensburg,PA 17257-0000 Loan Number: 705984441 Property Address: 21-23 Washington Street , Shippensburg, PA 17257-0000 PLEASE SEE THE ENCLOSED DOCUMENT DACT91.19 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt Ocwen Loan Servicing, LLC 0P.O. Box 24737 0 c w e w West Palm Beach, Florida 33416-4737 (Do not send correspondence or payments to the above address) W'Wi1 .OCWEti.COM December 31, 2010 APPENDIX A ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intend In-foreclose. Specific information about the nature of the default i provided in the attached page. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (H MAP) 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 OUN FLIN A EN Y WITHIN THIRTY (30) DAYS OF DATE OF THIS NOTICE, Take this Notice with you when you meet with the- Counseling Agency. The name. address and phone number of Consumer Credit Counseling Agencies serving your County are L'cted at the end of this Notice If you have any questions you may call the Pennsylvania Housing Finance Agency toll free at (800) 342-2397 (Person with impaired hearing can call (717) 780-1869). This Notice contains important legal information If you have any questions, representatives at the on umer Credit Counseling Agency may be able to helplegplain it. You may also want to contact an attorney??your area The-local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION, OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO A ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. USTED PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: Chad Miller 21-23 Washington Street Shippensburg, PA 17257-0000 705984441 OCWEN DACT91.19 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt Ocwen Loan Servicing, LLC P.O. Box 24737 ' O C W E N West Palm Beach, Florida 33416-4737 (Do not send correspondence or payments to the above address) WW\h%.OC:WEN.COM HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH N AVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPO RARY STAY OF FORECL OSURE -Under the Act, you are e ntitled to a -temporary stay of foreclos ure on your mo rtgage for thirty (30) da s fr om the date of this Notice D i th t ti " y ur ng a me you must arrange and attend a face- to-face" meeting with one of the con sumer credit counseling ncies lief THIS MEE a at the d of this Notice TING MUST O CCUR WITHIN THE NE XT (30) DAYS IF YOU DO NOT . APPLY FOR EMERGENCY MORT GAGE ASSIST rAi.I.FD ANCE YOU MUST BRIN 1914nW TA !`ITDF VnITD G YOUR MORTGAGE P TO MnD'IVr A I-V Y%V V A WTr •rn 10%- sT I DATE, THE PART OF THIS NO TwTn TICE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of designated consumer credit counseling agencies for the_ county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face- to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance). HOW TO CURE YOU MORTGAGE DEFAULT (Bring it up to date) DACT91.19 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt Ocwen Loan Servicing, LLC P.O. Box 24737 - O C W E N West Palm Beach, Florida 33416-4737 (Do not send correspondence orpayments to the above address.) NY " .OCWEN.COM NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property located at: 21-23 Washington Street, Shippensburg, PA 17257-0000 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 2 payments in the amount of $ 1,321.70 from November 01. 2010 through December 31. 20 DETAIL SUM ARY Principal and Interest ................................. Interest Arrearage ..................................... Escrow .................................................. Late Charges ........................................... Insufficient Funds Charges ........................... Fees / Expenses ........................................ Suspense Balance (CREDIT) ........................ Interest Reserve Balance (CREDIT) ................ TOTAL DUE .......................................... $ 2,005.20 $ 0.00 $ 638.20 $ 100.26 $ 0.00 $ 10.50 $ 649.39 $ 0.00 $ 2,104.77 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,104.77, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by Money ram, Cashier's heck ertit'ie heck or Money Order made. payable and sent to: OCWEN P.O. BOX 6440 CAROL STREAM, IL 60197-6440 IF YOU DO NOT CURET F. DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debtt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose u on your mortgaged property. IF THE MORTGAGE IS FORECLOSED ON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pa attorney's feeC OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE. DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the heriff ale You may do so by paying the total amount then past due. plus any late or other charges then due, reasonable attorney's fees and costs connecters with the fore losure sale and any other costs connected with the Sheriffs ale a specified in writing by the lender and by performing any. other reguirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POS IB SHERIFF'S A DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default DACT91.19 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt Ocwen Loan Servicing, LLC j P.O. Box 24737 - West Palm Beach, Florida 33416-4737 O `-- C W W -- E N N (Do not send correspondence or payments to the above address) WW_OCWEN.COM will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the servicer. HOW TO CONTACT THE SERVICER: Name of Servicer• OCWEN Address: P.O. BOX 24737 WEST PALM BEACH, FL 334164737 Phone Number: 800-310-9229 Fax Number: 407-737-6300 Contact: Early Intervention Dept EFFECT OF SHERIFF' I - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may or X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE T F RL HT• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE (3) TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING A N I S SERVING YOUR COUNTY DACT91.19 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt VERIFICATION The undersigned, hereby states 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 herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. BY- tl ta?lrv?a,r 1 ? ? p 30 2acZ, o UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 c CHANDRA M. ARKEMA, ESQUIRE - ID #203437 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 '- - MARGUERITE L. THOMAS, ESQUIRE - ID #204460 DANIEL S. SIEDMAN, ESQUIRE - ID #306534 HEATHER RILOFF, ESQUIRE - ID #309906 cT'?" == ' 4 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 ma CHERRY HILL, NJ 08003-3620 x.., " 856-669-5400 pleadings(dudren.com Deutsche Bank National Trust Company, As Trustee For The Pooling And Servicing Agreement Dated As Of January 1, 2007 Securitized Asset Backed Receivables LLC Trust 2007-NC1 1661 Worthington Road #100, West Palm Beach, FL 33409 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. /I- q73LI) ?JW) V. CHAD MILLER P. O BOX 633 SHIPPENSBURG, PA 17257-0633 Defendant(s) ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the following counsel: Mark J. Udren, Esquire; Stuart Winneg, Esquire; Lorraine Doyle, Esquire; Alan M. Minato, Esquire, Sherri J. Braunstein, Esquire; Chandra M. Arkema, Esquire; Marguerite L. Thomas, Esquire; Daniel S. Siedman, Esquire; Heather Riloff, Esquire on behalf of the Plaintiff, in the above-captioned matter. UDREN LAW OFFICES, P.C. BY: (4L-, Gat? PA \D 3ogRd? SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Lowy wy ' of `ttrrGrr(??lA ? ? I ? 7 H, 0 01: Jody S Smith Chief Deputy . 2011 JUN 15 APB 9: 05 Richard W Stewart MMBERLAH COUNTY Solicitor PENNSYLVANIA Deutsche Bank National Trust Company Case Number vs. 2011-4730 Chad Miller SHERIFF'S RETURN OF SERVICE 06/06/2011 08:09 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on June 6, 2011 at 2009 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Occupant of 21 N. & 23 N. Washington Street, Shippensburg, Pennsylvania 17257, by making known unto Katrina Gilbert, current Occupant of 21 N. & 23 N. Washington Street, Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to her personally the said true and correct copy of the same. MICHAEL BARRI K, DEPUTY 06/14/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Chad Miller, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Chad Miller. Request for service at 21 North & 23 North Washington Street, Shippensburg, Pennsylvania 17257 the defendant was not found. The Shippensburg Postmaster has confirmed Chad Miller is not known at this address. SHERIFF COST: $69.00 June 14, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF iC? i„ OUt--TV5UIt9 SN 11f+. Te e:;:;ofl. irc. 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 The Pooling And Servicing Agreement Dated As Of January 1, 2007 Securitized Asset Backed Receivables LLC Trust 2007-NCI Plaintiff V. CHAD MILLER; et al Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION v? Cumberland County =rn r- rv CD -c o NO. 11-4730 C? -- n s; PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint on the above-captioned matter. DATE: June 17, 2011 UDREN LAW OFFICES, P.C. BY • Attorneys for Plaintiff She r n e fit. C')'Zd b)w. ?,_-?_ o? OC 4/o.oa Ord ?L url- R=C .z La 7.?s SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor 01 40tA!(e",41114 TH, ?r'f 2011 AU -5 PM 2: ? Ir"y 83 CUMBERLA140 COUNT', t'ENNSYLVAIN A Deutsche Bank National Trust Company vs. Chad Miller Case Number 2011-4730 SHERIFF'S RETURN OF SERVICE 06/21/2011 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Chad Miller, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Franklin County, Pennsylvania to serve the within Complaint In Mortgage Foreclosure according to law. 07/12/2011 01:30 PM - Franklin County Return: And now July 12, 2011 at 1330 hours I, Dane Anthony, Sheriff of Franklin County, Pennsylvania, do hereby certify and return that I served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Chad Miller by making known unto himself personally, at 8832 Nyesville Road, Chambersburg, Pennsylvania 17202 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 SO ANSWERS, August 02, 2011 RON R ANDERSON, SHERIFF UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadin s a)udren.com Deutsche Bank National Trust Company, As Trustee For The Pooling And Servicing Agreement Dated As Of January 1, 2007 Securitized Asset Backed Receivables LLC Trust 2007-NC1 Plaintiff V. CHAD MILLER 8832 NYESVILLE ROAD CHAMBERSBURG, PA 17202 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 11-4730 PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: r ° F;. .Cd T'° p-r°Y J;' C) Zo 'a c °rn Kindly substitute the attached Verification for the Verification attached to the Complaint in Mortgage Foreclosure with regard to the captioned matter. %I k DATED: August 12, 2011 UDREN LAW OFFICES, P.C. Attorney for Plainti °-_ Alan M. Minato Esquire PA ID 7SMf00 MN#: 11020323 CASE#: 11020323-1 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 HEATHER RILOFF, ESQUIRE - ID #309906 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadin2s(a,udren.com Deutsche Bank National Trust Company, As Trustee For The Pooling And Servicing Agreement Dated As Of January 1, 2007 Securitized Asset Backed Receivables LLC Trust 2007-NC1 Plaintiff V. CHAD MILLER P. O BOX 633 SHIPPENSBURG, PA 17257-0633 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 unsworn falsification to authorities. Date: ?? &\k^- Name: ron ( y Title: Comtmo Management Company: Coordinator dGv%,q\ Lo oN ttl?l X4,TTT fh n?nz?2 r A c-V .9. 11alm'29Z i f r r,) rOTAR`t UDREN LAW OFFICES, P.C. ATTORNEY FOR PCl?, WOOD REST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pkadin s udren.com Deutsche Bank National Trust Company, COURT OF COMMON PLEAS As Trustee For The Pooling And Servicing CIVIL DIVISION Agreement Dated As Of January 1, 2007 Cumberland County Securitized Asset Backed Receivables LLC Trust 2007-NC1 MORTGAGE FORECLOSURE Plaintiff j v. CHAD MILLER 8832 NYESVILLE ROAD CHAMBERSBURG, PA 17202 Defendant(s) NO. 11-4730 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: 13 ??..???3ERLAN? GOUNjY ?E4dP1SYLVA?IA Kindly enter judgment in favor of the Plaintiff and against the Defendant(s), CHAD MILLER; for failure to file an Answer to Plaintiff s Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: Unpaid Principal Balance Interest Per Complaint Additional Interest Late Charges Per Complaint Additional Late Charges Escrow Per Complaint Title Search Attorney Fees - Estimated Property Inspection Fee Prior Servicer Fees Other Suspense Balance Grand Total FROM 06/01/2011 06/01/2011 TO $122,884.44 $7,167.12 $2,202.98 $100.26 $100.26 $2,079.97 $300.00 $1,300.00 $31.50 $10.50 $-649.39 $135,527.64 08/13/2011 08/13/2011 at,} ply. cb IDA 0.6y 0712, Y 8-q 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. UDREEt i-6EP, n M. Minato, Esquire. PA ID 75860 Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE: I ). . W. PRO MJU#: 11020323 CASE#: 11020323-1 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 11.1 WOODCREST ROAD, SUITE 200 CHERR'j.' HILL. NJ 0800:3-3620 856-669-5400 Deutsche Bank National Trust Company, As 'T'rustee For The Pooling And Servicing Agreement Dated As Of January 1, 2007 Securitized Asset Backed Receivables LLC Trust 2007-NC1 Plaintiff V. CHAD MILLER, ET AL Defendant(s) TO:CRAD MILLER 8832 NYESVILLE ROAD CHAMBERSBURG, PA 17202 Date of Notice: August 2, 2011 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 11-4730 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. LA)ATYER REFERRAL SERVICE Cumberland Countv Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTTRA 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 TERMING DE DIEZ (10) DIAS DE ESTAA NOTIFICACION EL. TRI13TJNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCI_A EN' SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEV_4R ESTA NOTIFICACION A UN ABOGADO IEvIMEDLA TAMENTE SI USTED NO TIENE ABOGADO., O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A. LA OFICINA, CUY A DIRECCION SE ENCITEN'TRA ESCRITA ABAJO PAP k AVERIGUAR. DONDE SE PUEDE CANS-IT IR _4SSISTENCIA LEG?,L. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland Counh, Bar Association 2 Liberty, Avenue Carlisle, PA 17013 (800) 990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAVE' FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OB'T'AINED WILL BE USED FOR THAT PURPOSE. UDREN LAW OFFICES, PC. Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leading?udren.com Deutsche Bank National Trust Company, As Trustee For The Pooling And Servicing Agreement Dated As Of January 1, 2007 Securitized Asset Backed Receivables LLC Trust 2007-NC1 Plaintiff V. Chad Miller 8832 Nyesville Road, Chambersburg, PA 17202 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 11-4730 AFFIDAVIT OF NON-MILITARY SERVICE UNDER Pa.R.C.P 76 THE UNDERSIGNED states, upon information and belief, that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Age: Over 18 Residence: As captioned above Employment: Unknown This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. MJU#: 11020323 CASE#: 11020323-1 Name: Title: Company: Alan M. Minato, Esquir, PA ID 75860 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 HEATHER RILOFF, ESQUIRE - ID #309906 WOODCREST CORPORATE CENTER Ill WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadinas(cyudren.com Deutsche Bank National Trust Company, As Trustee For The Pooling And Servicing Agreement Dated As Of January 1, 2007 Securitized Asset Backed Receivables LLC Trust 2007-NCI C/O Ocwen Loan Servicing, LLC 1661 Worthington Road #100 West Palm Beach, FL 33409 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS tn T- try M rs != °r --el ca ? CIVIL DIVISION CUMBERLAND County NO. /I, Plaintiff V. CHAD MILLER P. O BOX 633 SHIPPENSBURG, PA 17257-0633 Defendant(s) 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. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor rFME OF THE 'GRIPE Deutsche Bank National Trust Company Case Number vs. Chad Miller 2011-4730 SHERIF-PS-RETURN -OFA ERVICE 06/21/2011 Ronny R. Anderson, Sheriff who being duly swom according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Chad Miller, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Franklin County, Pennsylvania to serve the within Complaint In Mortgage Foreclosure according to law, 07/12/2011 01:30 PM - Franklin County Return: And now July 12, 2011 at 1330 hours I, Dane Anthony, Sheriff of Franklin County, Pennsylvania, do hereby certify and return that I served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Chad Miller by making known unto himself personally, at 8832 Nyesville Road, Chambersburg, Pennsylvania 17202 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 August 02, 2011 SO ANSWERS, RONNrY R ANDERSON, SHERIFF btihxlrP. • s kcLiUxiv - xt??7uLLPLx CASE NO: 2011-00146 T COMMONWEALTH OF PENNSYLVANIA: COUNTY OF FRANKLIN DEUTSCHE BANK NAT TRUST CO VS CHAD MILLER ANGEL L LAVIENA , Deputy Sheriff of FRANKLIN County, Pennsylvania, who being duly sworn according to law, says, the within COMP MORT FORE was served upon MILLER CHAD the DEFENDANT at 1330:00 Hour, on the 12th day of July 2011 at 8832 NYESVILLE ROAD CHAMBERSBURG, PA 17202 by handing to CHAD MILLER a true and attested copy of COMP MORT FORE _ together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge .00 So Answers: .00 ANGEL L LAV .00 .00 By .00 De iff .00 07/14/2 1 UDREN LAW OFFICES Sworn and Subscribed to before me this 7day of r1/_ A.D. Q)4-. Notary `j COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL RICHARD D. McCARTY, Notary Public Chambersbutg Boro., F=ranklin County My Commission Eires ,fan. 29,20`15 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Mw *4941s: Deutsche Bank National Trust Company vs. Chad Miller 0 N w 0 a. X W v tits " rf 4it>atz rr4 44, SERVICE COVER SHEET Richard W Stewart Solicitor Case Number 2011-4730 _:..._.._r_a:.__ -_.._.._..._.....___? ..a- -....._. .............. ....... .... __.,_.._.,...., u_,.. _...r.,,........... _.... Category: ;Civil Action - Complaint in Mortgage Foreclosure Zone: Manner :Deputize Expires: 07/19/2011 Warrant: _..,.,.._..._.,,....._. ,_._ .,.............. ,_-, .................... _..,.,.,.....,...,..,..,,, ..................... Serve ? 9: Name: `Chad Miller Primary .............._...._._...,._,....._.._ , .. 8832 Nyesville Road Address: Chambersburg, PA 17202 Phone: Altemate . ..... ..... .......... ........ ..---.,........ w,...__..... .... Address: Phone: A##cgmey r C rig rnafv?r Name: Udren Law Offices 1=# Served: Adult In Personally Adult In Charge Posted Other Charge: r/ Relation: .?....... ...... - P ._..._.... Date: L...__..I. ? ?? Time: Deputy: J y' Mileage: f Phone: 856-669-5400 eOP0_, Date:? C - --- -- --x - -{ Time: 410,4 ? Mileage: Deputy: ,rnrs: Q Now, June 21, 2011 f, Sheriff of Cumberland County, Pennsylvania do hereby deputize the Sheriff of Franklin County to execute service of the documents herewith and make return thereof according to law. a? Return To: W -j Cumberland County Sheriff's Office One Courthouse Square Carlisle, PA 17013 onny R Anderson, Sheriff WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-4730 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR THE POOLING AND SERVICING AGREEMENT DATED AS OF JANUARY 1, 2007 SECURITIZED ASSET BACKED RECEIVABLES LLC TRUST 2007-NCI Plaintiff (s) From CHAD MILLER (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: $135,527.64 L.L.: $.50 Interest FROM a/100st TO DATE OF SALE JUNE 6, 2012 - ONGOING PER DIEM OF $29.77 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $8,871.46 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $253.00 Other Costs: Plaintiff Paid: Date: 2/7/12 J?dCLQ1lLJc?i_ David D. B e11, Prothonot ary (Seal) , 'P ?V? Deputy REQUESTING PARTY: Name: SHERRI J. BRAUNSTEIN, 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. 90675 FILED-OFFICE UDREN LAW OFFICES, P.C.EPROTHORT WOODCREST CORPORATE CE , + g 49 111 WOODCREST ROAD, SUIT CHERRY HILL, NJ 08003-3620 ?,tjM6EREAND COUS" 856-669-5400 PENNSYLVANIA pleadinp.sAmdren.com ATTORNEY FOR PLAINTIFF Deutsche Bank National Trust Company, COURT OF COMMON PLEAS As Trustee For The Pooling And Servicing CIVIL DIVISION Agreement Dated As Of January 1, 2007 Cumberland County Securitized Asset Backed Receivables LLC Trust 2007-NCI MORTGAGE FORECLOSURE Plaintiff V. NO. I1-4730 Chad Miller Defendant(s) PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due Interest From 8/14/2011 to Date of Sale June 6, 2012 Ongoing Per Diem of $29.77 to actual date of sale including if sale is held at a later date (Costs to be added) OD Qig. a? u <( MJU#: 11020323 CASE#: 11020323-1 )(4. Oo ci ti a asgoo?a $ 135,527.64 $ 8,871.46 UDREN W OFFICES, P.C. BY: Atto e or Maintl f Sherri J. Braunstein, Esquire PA ID 90675 ,i . a 5 7c L,.o- G' . ?. so c- C?-+t a3a? W o X7 ()-?S& 1Sc,.?„/ WM or I$,-, F1..Eil.-OFF1i11r UDREN LAW OFFICES, P.ClJF THE FROTHONOTAR't WOODCREST CORPORATE CE gR.? ?4; 49 111 WOODCREST ROAD, SU1 I r CHERRY HILL, NJ 08003-362tUMBERLAND COUNTY 856-669-5400 PENNSYLVANIA plleadings?udrenxom Deutsche Bank National Trust Company, As Trustee For The Pooling And Servicing Agreement Dated As Of January 1, 2007 Securitized Asset Backed Receivables LLC Trust 2007-NC1 Plaintiff V. Chad Miller Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 11-4730 CERTIFICATE OF ACT 91 I hereby state that as the attorney for the Plaintiff in the above-captioned matter: Act 91 procedures have been fulfilled F-1 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. UD LAW OFFICES, P.C BY: Attorn y for Pla ntiff Sherri I Braunstein, Esquire PA ID 90675 i UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadinEs(i )udren.com Deutsche Bank National Trust Company, As Trustee For The Pooling And Servicing Agreement Dated As Of January 1, 2007 Securitized Asset Backed Receivables LLC Trust 2007-NC1 Plaintiff V. Chad Miller Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County ) ,,, C) r =? MORTGAGE FORECLOSURE m rn z rn =::o w - rY, ' -<D NO. 11-4730 r"x J C) ?c:) C? vC E5 C) °r AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 Deutsche Bank National Trust Company, As Trustee For The Pooling And Servicing Agreement Dated As Of January 1, 2007 Securitized Asset Backed Receivables LLC Trust 2007-NC1, 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: 21-23 North Washington Street, Shippensburg, PA 17257 1. Name and address of Owner(s) or reputed Owner(s): Chad Miller 8832 Nyesville Road Chambersburg, PA 17202 Chad Miller 21-23 Washington Street Shippensburg, PA 17257 Chad Miller P. O Box 633 Shippensburg, PA 17257-0633 2. Name and address of Defendant(s) in the judgment: Chad Miller 8832 Nyesville Road Chambersburg, PA 17202 Chad Miller 21-23 Washington Street Shippensburg, PA 17257 Chad Miller P. O Box 633 Shippensburg, PA 17257-0633 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 The Pooling And Servicing Agreement Dated As Of January 1, 2007 Securitized Asset Backed Receivables LLC Trust 2007-NCI 1661 Worthington Road #100 West Palm Beach, FL 33409 Sr Mortgage Holders - None MERS, Inc., as Nominee for Mercantile Mortgage Co. PO Box 2026 Flint, MI 48501-2026 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 21-23 North Washington Street Shippensburg, PA 17257 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: UDRE LAW OFFICES, P.C. BY: Attorn y or Pla tiff Sherri I. Braunstein, Esquire MJU#: 11020323 CASE#: 11020323-1 PA ID 90675 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadinp-s(&udren.com Deutsche Bank National Trust Company, As Trustee For The Pooling And Servicing Agreement Dated As Of January 1, 2007 Securitized Asset Backed Receivables LLC Trust 2007-NC1 Plaintiff V. CHAD MILLER Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County i m z r c ar- t 7M MORTGAGE FORECLOSURE r? --= _J i - z n zo mac, NO 11 4730 c> t. - . NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Chad Miller 8832 Nyesville Road Chambersburg, PA 17202 Your house (real estate) at 21-23 North Washington Street, Shippensburg, PA 17257 is scheduled to be sold at the Sheriffs Sale on June 6, 2012 at 10:00am at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $135,527.64, 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: 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. 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 A 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 pleadinss(a>Aren. com Deutsche Bank National Trust Company, As Trustee Foil The Pooling And Servicing Agreement Dated As Of January 1, 2007 Securitized'Asset Backed Receivables LLC Trust 2007-NC1 Plaintiff V. CHAD MILLER, Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS r - CIVIL DIVISION ID Cumberland County r r-. MORTGAGE FORECLOSURE `-' NO. 11-4730 AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: 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: .? UDRE W OFFICES, P. BY: Attorneys fo laintiff PAIGE M. BELUNO, ESQUIRL PA ID 309091 MJU#: 11020323 CASE#: 11020323-1 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODICREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 eutsc a an ahona rust ompany, As Trustee For The Pooling And Servicing Agreement Dated As Of January 1, 2007 Securitized Asset Backed Receivables LLC Trust 2007-NCI V. CHAD MILLER Plaintiff Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 11-4730 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S): CHAD MILLER PROPERTY: 21-23 North Washington Street,.Shippensburg, PA 17257 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#: 11020323 CASE#: 11020323-1 EXHIBITA 0 -0 Q O w y % V T ?2 O ? N ? O W m W 0 c Q N G. 0 A 0 0 3 o CL O m O A r -1 cr - C? -? A -+ W _? N -+ O O co V O tT A W N -+ ?Dz Co a° m CL to - z c ' ? a w N N ? O . Ma ? m ? Nm pD mm z m -?0 n c m DC) ?m''$M, m 1 P 1" w Am Co a 2r ? tm ^? o ?? Z ca O n-yn0 Z.40-n 0 O m C my m ii c m c -n m A v ? 0 D 5 m te- A R C1 r in o m co 3 c D 4° o cm V ? ° X ° m a ,y \ , < W ??? t V O V ? 7 m 3 ? 1 1 r.it?i-42r;5t'='21b o ? ^' ° 0 1 Y ??f? ` 02. 100 ;DD , A C.f 21312 1 ` 1 Mailed groin 08nQ3 T j US POSTAGE _ ?. _ 1 ?..? m m F ??;00 a So Rz. Q Q ? 5 0 $ 25 c m R .3 o n ORL 3 o l O $ -n ;D .3 _ a G gi O u S O S A p l TN a l ?. -n U) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ati??titin at 4aran?rr?i?l Jody S Smith Chief Deputy 1. Richard W Stewart Solicitor OFFirE OF rh= s "EPAFF Deutsche Bank National Trust Company vs. Case Number Chad Miller 2011-4730 SHERIFF'S RETURN OF SERVICE 02/09/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Chad Miller, but was unable to locate the Defendant in his bailiwick. He therefore deputized the Sheriff of Franklin County to serve the within Real Estate Writ, Notice and Description, in the above titled action, according to law. 03/07/2012 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff of Franklin, County upon Chad Miller, personally, at 8832 Nyesville Road, Chambersburg, PA 17202. So Answers: Dane M. Anthony, Sheriff. 03/28/2012 02:50 PM - Deputy Gerald Worthington, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action upon the property located at 21-23 North Washington Street, Shippensburg, PA 17257, Cumberland County. SHERIFF COST: $919.20 April 13, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF EXHIBIT B ;(') CrnmtySuite Shenk 7eleosoft Inc SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff - y ,~~~•~ts, r~ ~~ 4 : ~ Jody S Smith " ~ ~~~~° Chief Deputy .. }.~_~" ~ ~ ~„~ Richard W Stewart ,~, ; •,,.• ~-. .- . , ; , Solicitor _ ~ : ; , ~ _ ~ .. _ a t _, _.. , Deutsche Bank National Trust Company Case Number) vs. Chad Miller 2011-4730 ', ---- SHERIFF'S RETURN OF SERVICE 02/09/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search a~d inquiry for the within named Defendant, to wit: Chad Miller, but was unable to locate the Defendant in is bailiwick. He therefore deputized the Sheriff of Franklin County to serve the within Real Estate Writ, Notice and Description, in the above titled action, according to law. 03/07/2012 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheri of Franklin County upon Chad Miller, personally, at 8832 Nyesville Road, Chambersburg, PA 17202. S~~ Answers: Dane M. Anthony, Sheriff. 03/28/2012 02:50 PM -Deputy Gerald Worthington, being duly sworn according to law, states service was perform~d by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled ', action, upon the property located at'.?1-23 North Washington Street, Shippensburg, PA 17257, ', Cumberland County. 06/06/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice h d been given according to law, he exposed the within described premises at public venue or outcry at th . Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania on June 06, 2012 at 10: 0 AM. He sold the same for the sum of $1.00 to Attorney Mark Udren, on behalf of Deutsche Bank Natio al Trust Company, et. al., being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $758.80 SO ANSWERS, ~f August 10, 2012 RON R ANDERSON, SHERIFF r UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadin~s~ udren.com Deutsche Bank National Trust Company, As Trustee For The Pooling And Servicing Agreement Dated As Of January 1, 2007 Securitized Asset Backed Receivables LLC Trust 2007-NC1 Plaintiff v. Chad Miller Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSt1RE NO. 11-4730 AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 Deutsche Bank National Trust Company, As Trustee For The Pooling And Servicing ', Agreement Dated As Of January 1, 2007 Securitized Asset Backed Receivables LLC Trust 2007-NC1, 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 Vv rit of Execution) was filed, the following information concerning the real property located at: ', 21-23 North Washington Street, Shippensburg, PA 17257 1. Name and address of Owner(s) or reputed Owner(s): Chad Miller 8832 Nyesville Road Chambersburg, PA 17202 Chad Miller 21-23 Washington Street Shippensburg, PA 17257 Chad Miller P. O Box 633 Shippensburg, PA 17257-0633 ?. Name and address of Defendant(s) in the judgment: Chad Miller 8832 Nvesville Road Chambersburg, PA 17202 Chad Miller 21-23 Washington Street Shippensburg, PA 17257 Chad Miller P. O Box 6 33 Shippensburg, PA 17257-0633 3. Name and address of every judgment creditor ~~hose 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 The Pooling And Servicing Agreement Dated As Of January 1, 2007 Securitized Asset Backed Receivables LLC Trust 2007-NC1 1661. Worthington Road #100 West Palm Beach, FL 33409 Sr Mortgage Holders -None MERS, Inc., as Nominee for Mercantile Mortgage Co. PO Box 2026 Flint, MI 48501-2026 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 whole 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 21-23 North Washington Street Shippensburg, PA 17257 ~- 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which maybe effected by the sale: Federal Tai: Lien Holders -None Condo/Homeowners Association -None I verify that the statements made in this affidavit are true and correct to the best cif 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: UDRE LAW OFFICES. P.C. BY: ~; Attorn v for Pla tiff Sherri J. Braunstein, Esquire MJU#: 11020323 CASE#: 11020323-i PA ID 90675 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings~.udren.com Deutsche Bank National Trust Company, As Trustee For The Pooling And Servicing Agreement Dated As Of January 1, 2007 Securitized Asset Backed Receivables LLC Trust 2007-NCl Plaintiff v. CHAD MILLER Defendant(s) ATTORNEY FOR PLAINTIp'F COURT OF COMMON PLEAS CIVIL DNISION Cumberland County MORTGAGE FORECLOSURE NO. 11-4730 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Chad Miller 8832 Nyesville Road Chambersburg, PA 17202 Your house (real estate) at 21-23 North Washington Street, Shippensburg, PA 17257 is ~~~ scheduled to be sold at the Sheriffs Sale on June 6, 2012 at 10:00am at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $135,527.64, obtained by Plaintiff above (the mortgagee] against I, 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: l . The sale will be cancelled if you pay to the mortgagee the back payment, late charges. costs and reasonable attornev,'s fees. To find out how much you must pay. you may call: (856) 669-5400. You maybe 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 «ood cause. I'ou may also be able to stop the sale through other legal proceedings. You may need an attorney to assert }your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find's out the price bid by calling 856-669-5400. ~, ?. 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 fiull amount due in the sale. To find out if this has happened, you may call 856-669-1400. 4. If the amount due from the Buyer is not paid to the Sheriff. ,you will remain fhe owner of the ', propem~ 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 th~, Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. I 6. ~r'ou maybe entitled to a share of the money which was paid for your house. A schedule of I' 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. "Che 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 ~i Schedule of Distribution is filed. ?. You may also have other rights and defenses.. or ways of getting vour home back if you act immediately after the sale. YOU SHOULll TAKE THIS PAPER TO YOUR LAWI'ER AT ONCE. IF YOU DO NOT HAVE A ~', LAR1'ER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTF,D 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 lot of ground situate on North Washington Street, in the Borough of Shippensburg, Cumberland County, Pennsylvania, having thereon enacted a two story brink double dwelling house and other improvements known as 21-23 N Washington Street, bounded and limited as follows: ON the West by North Washington Street; on the North by lot now or formerly of O.S. Creamer and Florence E. Cramer, his wife; on the East by an alley known as Maple Avenue; and on the South by land now or formerly of Harold Mell. Said Iot having a frontage on North Washington Street Forty (40j feet, more or less, and extending in depth two hundred fifty-seven (257) feet to an alley. BEING the same premises which John A Bonitz by Deed dated 1/17!03 and n3corded 1121/03 in Cumberland County Deed Book 255 Page 2120 granted and conveyed unto Francis X. Casey and Paula A. Casey, Grantors herein. BEING the same premises which Francis X. Casey and Paula A. Casey by Deed dated and recorded even date herewith in the Offioe of the Recorder of Deeds in and for Cumberland County, PA, granted and conveyed unto Chad Miller. BEING KNOWN AS: 21-23 NORTH WASHINGTON STREET, SHIPPENSBLIRG, PA 172x7 PROPERTY ID NO.: 32-33-1867-065 TITLE TO SAID PREMISES IS VESTED INT CHAD MILLER, SINGLE MAN BY DEED FROM FRANCIS X. CASEI' AND PAULA A. CASEY, HUSBAND AND WIFE DATED (17/24/2006 RECORDED 08/10/2006 IN DEED BOOK 276 PAGE 614. ' WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 11-4730 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 THE POOLING AND SERVICING AGREEMENT DATED AS OF JANUARY 1, 2007 SECURITIZED ASSET BACKED RECEIVABLES LLC TRUST 2007-NCI Plaintiff (s) From CHAD MILLER (I) 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; (i j 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: $135,527.64 L.L.: $.50 Interest FROM aj~~-/~« TO DATE OF SALE JUNE 6, 2012 -ONGOING PER DIEM OF $29.77 TO ACTUAL, DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $8,871.46 Atty's Comm: % Due Prothy: $2.25 Atty Paid: 5253.00 Other Costs: ~~ Plaintiff Paid: Date: 2/7/12 ~' . ~~ ''', David D. Buell, Prothonotary ', (Seal) I, Deputy REQUESTING PARTY: Name: SHERRI J. BRAUNSTEIN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 11 I WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 90675 TRUE COPY FROM RECORD In Testimony ~~hereot, I here unto set my h~nd and tine seai of said Court at arlisle, Pa~ This _ ~daY of -------~r20 ~nr~tarv On February 9, 2012 the Sheriff levied upon the defendant's interest in the real property situated in the Borough of Shippensburg, Cumberland County, PA, known and numbered 21-23 North Washington Street, Shippensburg, PA 17257 more fully described on Exhibit"A" filed with this writ and by this reference incorporated herein. Date: February 9, 2012 v~ For Claudia Brewbaker, Real Estate Coordinator Writ No. 2011-4730 Civll Term Deutsche Bank National Trust Company, As Trustee for the Pooling and Servicing Agreement Dated as of January 1, 2007 Securitized Asset Backed Receivables LLC Trust 2007-NC1 vs. Chad Miller Atty.: Sherri J. Braunstein ALL THAT CERTAIN lot of land situate in Borough of Shippensburg, Cumberland County, Pennsylvania: BEING KNOWN AS 21-23 North Washington Street, Shippensburg, PA 17257. PARCEL NUMBER: 32-33-1867- 065. 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 an~ State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland La ~ Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesa~d, 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 regularl~~ issued weekly in the said County, and that the printed notice or publication attached hereto is j exactly the same as was printed in the regular 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 Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subjec~ matter of the aforesaid notice or advertisement, and that all allegations in the foregoing ~, statements as to time, place and character of publication are true. r, ,` ~,~~' . Li arie Coyne, Editor SWORN TO AND SUBSCRIBED before me this 11 day of Ma. ~i~' '~ ~ G~ _ Notary / -~ NOTARIAL SEAL DE90RAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify t~1at the Sheriffs Deed in which T C Trust 2007-NC ~ is the grantee the same having been sold to said grantee on the 6 day of June A.D., 2012, under and bjy virtue of a writ Execution issued on the '7 day of February, A.D., 2012, out of the Court of Commo~l Pleas of said County as of Civil Term, 2011 Number 4730, at the suit of Deutsche Bank National 'rust 201224351. IN TESTIMONY WHEREOF, I have hereunto set my~ hand and seal of said office this da of ~,_ /1 , ~ ~, ,~.~ ' , Recorder of eeds d CumberMrM CaaNy, PA My Corruri' Fires the Frst Monday of .2014 Backed Receivables LLC Trust 2007-NC1 against Chad Miller is duly recorded as Instrument Nurr~ber i- _ _, - ---- --. __... _ The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE c~be~latriot News Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication. Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 04/27/12 48'11~+1T~9 ,~ 7tast ~~!a4Y end ~, ~» s> ~: ~-Li,'~T ~7AW IAT OF I.ANI) STl'(IATL IN BORO[JGti OF HI~ENSBURG, CUNT ,1'>~iSYLXAMA: KNOWN A$ 21-23 NaEth • Shr~ PA17157 PAROEI, N~yg • 333-1 -065 ... .; 3 ,~ Sworn to anc~swbscribe~befor e t s dayof May, 2012 A.D. _., ~ _ ~ , :, ~ ; r ~ ~~ ~ ~ ,~` ~ / ~. Notary Public ~~ COMMONWEALTH OF PENNSYLVANIA NoWrlal Seal 5herri~ L Owens, Notary Public Lower Paxton Twp., Dauphin County My Commission Expires Nov. 26, 2015 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES 05/04/12 05/11/12