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Home My WebLink About11-5189UDREN 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 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 DANIEL S. SIEDMAN, ESQUIRE - ID #306534 HEATHER RILOFF, ESQUIRE - ID #309906 SHERNESE V. WOODBINE, ESQUIRE - ID#91209 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Pleadings(a udren.com The Bank of New York Mellon, as Indenture Trustee for American Home Mortgage Investment Trust 2004-4 C/O American Home Mortgage Servicing, Inc. 1525 S. Beltline Rd. Coppell, TX 75019 Plaintiff V. MICHAEL P. RUELL 403 DEERFILED ROAD CAMP HILL, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF C rn Co _ --r In r Zi? n, ri N Q C' s -TJ xa Zx cam- i?5 C) ? COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. 11-,51 7C'( I V1 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 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. SO s 9a.ao f? a -946 Pe?, 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 I. 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 American Home Mortgage Acceptance, Inc. Assignee: The Bank of New York Mellon, as Indenture Trustee for American Home Mortgage Investment Trust 20044 Date of Assignment: Recorded Date: Book/Instrument #: Page: 2. Upon information and belief Defendant(s): Michael P. Ruell (hereinafter 'Defendants"), are the owners of property located at 403 Deerfield Road, Camp Hill, PA 17011, by virtue of Deed dated 11/08/2004 and recorded 11/29/2004 in Official Records Book 266 at Page 2234 of the Public Records of Cumberland County, Pennsylvania (hereinafter the 'Property"). 3. On 11/08/2004, Defendant(s): MICHAEL P. RUELL promised to pay to the order of American Home Mortgage Acceptance, Inc, the principal sum of $114,100.00 payable with interest thereon provided in the Note. 4. By Mortgage dated 11/08/2004, Defendant(s): MICHAEL P. RUELL to secure the Note, mortgaged to Mortgage Electronic Registration Systems, Inc as nominee for American Home Mortgage Acceptance, Inc., the Property which is the subject of this action. The Mortgage was recorded on 11/29/2004 in Official Records Book 1889 at Page 1954. 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 02/01/2011, 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 $109,569.58 Accumulated Interest $1,454.84 Accumulated Late Charges $57.08 Title Report $325.00 Attorney Fees- Estimated $1,300.00 NSF Charges $20.00 Recoverable Balance $119.20 Grand Total $112,845.70 The above figures are calculated as of 06/03/2011: 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 3.12500 %. The per diem interest accruing on this debt is $9.38 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 $14.27. 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 $112,845.70 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged premises. UDREN LAW-f3>~1:'ICES -P-. BY: _- -- - Alan M. Minato, Esquire PA ID 75860 Exhibit A Legal Description ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of Lower Allen in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the northeasterly line of Deerfield Road, a 50 foot wide right-of-way which said point of the beginning is located at the intersection of the northeasterly line of Deerfield Road and the dividing line between Lots No.7 and 8 on the Resubdivision Plan of Allendale, Section 9, recorded in Cumberland County Plan Book "25, Page 133; thence, from said point of beginning along the north easterly line of Deerfield Road, north 24 degrees 58 minutes 10 seconds west, a distance of 100.00 feet to a point on the dividing line between Lots Nos. 6 and 7; thence from said point along the dividing line between Lots Nos. 6 and 7 north 65 degrees I minute 50 seconds east, a distance of 170.03 feet to a point; thence from said point, south 24 degrees 58 minutes 10 seconds east, a distance of 100.00 feet to a point on the dividing line between Lots Nos. 7 and 8; thence from said point along the dividing line between Lots No. 7 and 8, south 65 degrees 1 minutes 50 seconds west, a distance of 170.03 feet to a point, the point and place of beginning. Being Lot No. 7 on the Resubdivision Plan of Allendale, Section 9, recorded in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, in Plan Book "25", page 1.33. Tax 1D No: 13-24-0809-010 For information purpose only -- property is also known as: 403 Deerfield Road Camphill, PA 17011-8439 Report Date 06/10P2011 Zum0] 0.,11.rv1? ^I?I?I?wIW?lllll 7104 5400 :100 399E 0391 1Michael P Ruell 403 Deerfield Rd Camp Hill, PA 17011 (Rev. 9/2008) Date: April 11, 2011 A T 91 NO ICE TO VE YOUR HUME F'ROON FOWiLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE FOUR The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) maybe able to help to save your home This notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 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 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 to 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 SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIO'N OBTENGA UNA TRADUCCIO'N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRE'STAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDUWR SU HIPOTECA. HOMEOWNER'S NAME(S): Michael P Ruell PROPERTY ADDRESS: 403 Deerfield Rd Camp Hill, PA 17011 LOAN ACCT. NO.: 0030321400 ORIGINAL LENDER: AMERICAN HOME MORTGAGE ACCEPTANCE, INC CURRENT SERVICER: American Home Mortgage Servicing, Inc. CURRENT LENDER: The Bank of New York Mellon Corporation, as Indenture Trustee for American Home Mortgage Investment Trust 20044 EXHIBIT A Page two 0030321400 HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAYBE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP IODATE . THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies 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). 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. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCYACTION - 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 YOUARE CURRENTLYPROTECTED BY THE FILING OFA PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLYAND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) Page three HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date): NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 403 Deerfield Rd, Camp Hill, PA 17011 IS SERIOUSLY IN DEFAULT because: 0030321400 A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payments from 02/01/2011: (b) Late charge(s): (c) Other charge(s): NSF and Advances (d) Less: Credit Balance (e) Total amount required as of 04/11/2011: $1,458.66 $28.54 $120.00 $0.00 $1,607.20 HOW TO CURE THE DEFAULT - You may cure this default within THIRTY (30) DAYS from the date of this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $1,607.20, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check, or money order made payable and sent to: American Home Mortggage Servicing, Inc. 1525 S. Beltline Rd. COppell, TX 7,5019 IF YOU DO NOT CURE THE DEFAULT - 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 immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs.Ifyou cure the default within the THIRTY (30) DA Yperiod, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO 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 attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff s Sale of the mortgaged property could be held would be approximately five (5) 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 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 lender. Page four HOW TO CONTACT THE LENDER 0030321400 Name of Lender: American Home Mortgage Servicing, Inc. Address: 1525 S. Beltline Rd. Coppell, TX 75019 Telephone Number: 1-877-304-3100 Fax Number: 1-866497-1263 Contact Person: Brandon Wirth, Michael Heath E-mail Address: brandon.wirth@ahmsi3.com, michael.heath@ahmsi3.com EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff s 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 not 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. YOUMAYALSO HAVE 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 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 AGENCIES SERVING YOUR COUNTY ARE LISTED ON THE ATTACHED PAGES. American Home Mortgage Servicing, Inc. is attempting to collect a debt, and any information obtained will be used for that purpose. Unless you notify us within 30 days after receiving 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 any 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 Servicing, 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 Pittsburgh, PA 15219 800.792.2801 412.281.2102 Allegheny, Beaver, Butler, Fayette, Greene, Washington, Westmoreland Advocates for Financial Independence -Philadelphia 1628 IFK Blvd-8 Penn Co,, STE 2210 Philadelphia, PA 19103 215.218.4342 Philadelphia Advocates for Financial Independence -Philadelphia 1503 Wadsworth Ave. Philadelphia, 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 Dehnorr Ave Morrisville, PA 19067 215.295.7195 Bucks, Montgomery American Credit Counseling Agency 6800 Market St., 1st Floor, Upper Darby, PA 19130 888.2116741 Delaware, Philadelphia American Credit Counseling Institute 100 Porter Road Suite 108 Pottstown. PA 19464 888.212.6741 Berks,Bucks, Chester, Lehigh, Montgomery American Credit Counseling Institute 212 Berwick-Hamlton Hwy Nescopeck, PA 18635 888.468.8847 Carbon, Columbia, Lackawanna, Lehigh, Luzeme, Monroe, Skhulkill American Credit Counseling Institute 526-528 Dekalb Street Norristown, PA 19401 610.971.2210 868.212.6741 Delaware, Montgomery American Credit Counseling Institute 229 E Chestnut Street 1st Floor Coatesville, PA 19320 888.212.6741 Chester, Lancaster American Credit Counseling Institute American Financial Counseling Services Inc. 586 West Street Road Warminster, PA 18974 215.444.9429 888.212.6741 Bucks, Montgomery, Philadelphia American Credit Counseling Institute 21 South Cburch Street West Chester, PA 19380 888.212.6741 Chester American Credit Counseling Services Inc. 827 N 19th Street Allentown, PA 18104 888.468.8847 Bucks, Carbon, Lehigh, Mourne, Northhampton, Skhuylkill American Financial Counseling Services Inc. 175 Strafford Avenue Suite One Wayne, PA 19087 267.228.7903 800.490.3039 Berks, Bucks, Chester, Delaware, Montgomery, Philadelphia American Financial Counseling Services Inc. 906 Penn Avenue Wyomissing, PA 19610 267.228.7903 800.490.3039 Berks American Financial Counseling Services Inc. 2880 Bergey Road Suite H Hatfield, PA 19440 267.228.7903 800.490.3039 Barks, Chester, Montgomery American Financial Counseling Services Inc. 111 Buck Road Huntingdon Valley, PA 19006 267.228.7903 Bucks, Montgomery, Philadelphia American Financial Counseling Services Inc. 259 Veterans Lane Suite 101 Doylestown, PA 18901 267.228.7903 800.490.3039 Bucks, Montgomery American Financial Counseling Services Inc. 404 Executive Drive Langhorne, PA 19047 267.228.7903 800.490.3039 Bucks, Montgomery American Financial Counseling Services Inc. 1080 N. Delaware Avenue Suite 200 Philadelphia, PA 19125 267.228.7903 800.490.3039 Bucks, Delaware, Montgomery American Financial Counseling Services Inc. 3008 Hamilton East Suite 2 Stroudsburg, PA 18360 267.228.7903 Carbon, Monroe American Financial Counseling Services Inc. 405 West Germantown Pike Norristown, PA 19403 267.228.7903 800.490.3039 Delaware, Montgomery American Red Cross - Hanover Chapter 529 Carlisle Street Hanover, 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 Philadelphia, PA ] 9122 215.235.6070 267.953.4615 Delaware, Philadelphia, Chester BASE, Incorporated 447 S. Prince St Lancaster, 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, PO 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; STE 17 Wrightstown, PA 18940 866.866.0280 Bucks Bucks County Housing Group 349 Durham Road Penndel, PA 19047 866.866.0280 Bucks Bucks County Housing Group 200 West Bridge Street Morrisville, PA 19067 866.866.0280 Bucks Bucks County Housing Group 470 Old Dublin Pike Doylestown, 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, PA 19601 610.375.7866 Barks, Schuylkill, Chester Carroll Park Community Council, Inc. 5218 Master St Philadelphia, PA 19131 215.877.1157 Chester, Delaware, Philadelphia Catholic Social Services Diocese of Scranton 516 Fig Street Scranton, PA 185051 570.207.2283 Lackawanna, Monroe, Wayne, Wyoming CCCS of Delaware Valley 1717 Swede Road Suite 110 Blue Bell, PA 19422 215.563.5665 Montgomery CCCS of Delaware Valley 1230 New Rodgers Road Suite FI Bristol, PA 19007 215.563.5665 Bucks CCCS of Delaware Valley One Cherry Hill Suite 215 Cherry Hill, PA 08002 215.563.5665 Philadelphia CCCS of Delaware Valley - Center City Philadelphia 1608 Walnut St; 10th FL Philadelphia, PA 19103 215.563.5665 Bucks, Delaware, Montgomery, Philadelphia CCCS of Delaware Valley - Coatesville 1003 East Lincoln Hwy; Suite 102 Coatesville, PA 19320 215.563.5665 Bucks, Chester, Delaware, Montgomery, Philadelphia Retrieved December 6, 2010 from http://www.phfa.org/forms/cornrscling_agencies/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 190 West Chester, PA 19382 215.563.5665 Chester, Delaware Catholic Social Services Building 7340 Jackson St 800.989.2227 CCCS of Delaware Valley -Philadelphia Philadelphia, Bucks Philadel hi PA 19136 215.563.5665 800.989.2227 CCCS of Delaware Valley -Philadelphia 4400 North Reese St Philadelphia, PA 19140 Bucks, Chester, Delaware, Montgomery, Philadelphia 215.563.5665 CCCS of Delaware Valley (Community Action 113 East Main Street 2nd Floor Norristown, PA 19401 215.563.5665 Bucks, Chester, Delaware, Montgomery, Philadelphia Development Comm- CADCO 610.585.9518 CCCS of Lehigh Valley - Quakertown 127 S. 5th S4 STE 155 Quakertown, PA 18951 Bucks 888.845.5669 CCCS of Lehigh Valley Division of Money 610.821.4011 3671 Crescent Court E Whitehall, PA ] 8052 Carbon, Lancaster,Lehigh, Schuylkill, Northampton, Berks, Bucks Management International 800.837.9815 814.238.3668 CCCS of Northeastern PA 129 Rolling Ridge Drive State College, PA 16801 Blair, Centre, Clearfield, Clinton, Huntingdon, Juniata, Mifflin 800.922.9537 570.323.6627 CCCS of Nortneastem PA 201 Basin Street Suite 6 Williamsport PA 17701 Centre, Clinton, Lycoming, Northumberland, Union 800.922.9537 CCCS of Northeastern PA - Pittston 401 Laurel St Pittston, PA 18640 800.922.9537 Bradford, Carbon, Luzeme, Clinton, Columbia,Lackawanna, Lycoming, 570.602.2227 Mifflin Monroe Montour Northumberland Pike Sullivan Tioga, Union CCCS of Norlheastem PA - Stroudsburg 411 Main St; STE 104 Stroudsburg, PA 18360 800.922.9537 Bradford, Carbon, Monim, Pike, Wayne 570.420.8980 The Franklin Center 524 Franklin Avenue CCCS of Wester PA 888.511.2227 Cameron PA 15001 Aliquippa, CCCS of Westen PA 41 E. Chestnut Street Meadville, PA 15301 888.511.2227 Washington CCCS of Westen PA 312 Chestnut Street Suite 227 Meadville, PA 16335 888.511.2227 Lawrence Royal Rem- Plaza 917A Logan Blvd; Royal Rem- Plaza 800.511.2227 Armstrong, Bedford, Blair, Cambria, Centre, Clearfield, Huntingdon, Juniata, CCCS of Wester PA - Altoona Altoona PA 16602 570.602.2227 Mifflin, Union Butler County Career Link Pullman Commerce Center CCCS of Wester PA -Butler 888.511.2227 Butler, Clarion, Jefferson, Meurer, Venango 112 Hollywood Dr' Butler PA 16001 CCCS of Westm PA -Erie 4402 Peach St; Lower Level Erie, PA 16509 888.511.2227.108 Crawford, Erie, Warren 1 N Gate Square; #2 Garden Center Drive CCCS of Westin PA -Greensburg 888.5] 1.2227 Indiana, Westmoreland, Fayette, Greene, Somerset, Washington Greensburg, PA 15601 CCCS of Westen PA 2000 Linglestown Rd; Harrisburg, PA 17110 888.511.2227 Dauphin,Perry, York, Snyder, Adams, Cumberland, Franklin 2403 Sidney St; STE 400 River Park Commons CCCS of Westm PA - Pittsburgh 888 511.2227 Allegheny Pittsb h PA 15203 CCCS of Westen PA -York 55 Clover Hill Road Dallastown, PA 17313 888.511.2227 Franklin,Lancaster, York, Fulton Center for Family Services, Inc. 213 Center St Meadville, PA 16335 814.337.8450 Crawford, Venango Center in the Park 5818 Germantown Ave Philadelphia, PA 19144 215.848.7222 Philadelphia Central Pennsylvania Community Action. Inc. PO Box 792; 207 East Cherry Street, Clearfield, PA 16830 814.765.1551 Centre, Clearfield Chester Community Improvement Project. 412 Ave of the States, Chester, PA 19016 610.876.8663 Chester, Delaware, Montgomery, Philadelphia Comm. On. Econ Opportunity of Luzeme County 163 Amber Lane, Wilkes-Barre, PA 18702 570.826.0510 Carbon, Luzeme, Potter, Wyoming Community Action Commission - Capital Region 1514 Derry St Harrisburg, PA 17104 717.2319757 Cumberland, Dauphin, Franklin, Perry, Snyder Community Action Committee of the Lehigh Valley 1337 E Fifth St Bethlehem, PA 18015 610.691.5620 Berks, Carbon, Lehigh, Mourne, Northampton Community Action Southwest 150 W Be" St; STE 304 Washington, PA 15301 724.225.9550 Washington Community Action Southwest 58 E Greene St Waynesburg, PA 15370 724.852.2893 Allegheny, Fayette, Greene, Washington, Westmoreland CONGRESO 216 W Somerset St Philadelphia, PA 19133 215.763.8870 Philadelphia Council of Spanish Speaking Organization 705-09 N Franklin St Philadelphia, PA 19123 215.627.3100 Philadelphia Credit Counseling Center 932 2nd St Pike Richboro, PA 18954 215.348.8003 Bucks Credit Counseling Center 60 North Main Street Lower Level Doylestowa, PA 18901 215/348-8003 Bucks Credit Counseling Center 8150 Route 13, Levittown, PA, 19057 215348.8003 Bucks, Montgomery, Philadelphia Deliverance Community Development Corp, Inc 2001 W Lehigh Ave. Philadelphia, PA 19145 215.226.7600 Philadelphia Diversified Community Services Dixson House 1920 S. 20th St. Philadelphia, PA 19145 215.336.3511 Bucks, Chester. Delaware, Philadelphia Espe anza 4261 North 5th St. Philadelphia, PA 19140 215.324.0746 Philadelphia Fair Housing Partnership of Greater Pittsburg, Inc. 2840 Liberty Ave.; STE 205, Pittsburg, PA 15222 412.391.2535 Allegheny Fayette Co. Community Action Agency, Inc. 140 N Beeson Blvd Uniontown, PA 15401 800.427.1NFO Fayette, Somerset 724.437.6050 FOB CDC 1201 West Olney Avenue Philadelphia, PA 19141 215.549.8755 Bucks, Chester, Delaware, Philadelphia, Garfield Jubilee Associates 5138 Penn Ave Pittsburgh, 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 Philadelphia, PA 19124 215.535.3885 Philadelphia Retrieved December 6, 2010 from bttp://www.phfa.org/forms/counseling_agencies/hemap_agencies/hemap.pdf Greater Erie Community Action Committee 18 West 9th St. Erie, PA 16501 814.459.4581 Crawford, Venango, Erie, Warren Greater Philadelphia Asian Social Service Center 4943 North 5th St. Philadelphia, PA 19120 215.456.1662 Philadelphia HACE 167 W. Allegheny Ave. 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 17401 717.854.1541 York Housing Association of Delaware Valley 658 North Watts Street Philadelphia, PA 19123 215. 978.0224 York Housing Association of Delaware Valley 658 North Watts Street Philadelphia, PA 19123 215.978.0224 York Housing Association of Delaware Valley 1500 Walnut St. STE 601 Philadelphia 19140 215.545.6010 Philadelphia Housing Authority of Butler County 114 Woody Dr Butler, PA 16001 724.287.6797 Butler Housing Opportunities of Beaver County 282 East End Ave Unit 1 Beaver, PA 15009 724.728.7511 Beaver, Lawrence Housing Partnership of Chester County 41 W Lancaster Ave Downingtown, PA 19335 610.518.1522 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. Philadelphia, PA 19128 215.487.0914 Philadelphia Intercultural Family Services, Inc. 4225 Chestnut St Philadelphia, PA 19104 215.386.1298 Philadelphia Korean Community Development Services Center 6055 N 5th St Philadelphia, PA 19120 215.276.8830 Philadelphia Lawrence County Social Services, Inc. PO Box 189, 241 W Grant 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 Mammatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 Adams, Cumberland, Franklin, Fulton, Perry Media Fellowship House 4302 S Jackson St Media, 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. STE 200 Philadelphia, PA 19119 215.844.6021 Philadelphia Nazareth Housing Services 301 Bellevue Road Pittsburgh, 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 Scranton, PA 18509 570.558.2490 Lackawanna,Luzetne, Wayne, Wyoming NeighborWorks of Westem 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 Philadelphia, PA 19125 215.427.0350 Philadelphia NID-Housing Counseling-Philadelphia 1518 West Susquehanna Avenue Philadelphia, PA 19150 267.385.7624 Philadelphia Norris Square Civic Association 149 West Susquehanna Avenue Philadelphia, PA 19122 215.426.8723 Philadelphia Northern Tier Community Action Corp. 135 West 4th Street PO Box 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.Northeast 22 Willow Road Hamburg, PA 19526 610.562.2288 Berks, Lebanon, Lehigh, Schuylkill Pennsylvania Housing Finance Agency 2275 Swallow Hill Rd, Bldg 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 Harrisburg, PA 17110 717.780.3940 800.342.2397 Cumberland, Dauphin Philadelphia Council for Community Advancement 1617 JFK Blvd; STE 1550 Philadelphia, PA 19103 215.567.7803 800.930.4663 Chester, Delawarc,Montgomery, Philadelphia Philadelphia Senior Center 509 South Broad Street Philadelphia, PA 19147 215.546.5879 Philadelphia RHD-American Angel Housing Counseling 102 Pickering Way Suite 200 Exton, PA 19341 610.768.2811 Chester RHD-American Angel Housing Counseling 1060 First Avenue Suite 400 King of Prussia, PA 19406 610.733.2985 Montgomery RHD-American Angel Housing Counseling 600 West Germantown Pike Suite 400 Plymouth Meeting, PA 19462 610.768.2811 Montgomery RHD-American Angel Housing Counseling Two Bala Plaza Suite 300 Bala Cynwyd, PA 19004 610.768.2811 Montgomery RHD-American Angel Housing Counseling Two Penn Center Plaza Suite 200 Philadelphia, PA 19102 610.768.2811 Philadelphia RHD-American Angel Housing Counseling 150 North Radnor Chester Road Suite F200 Radnor PA 19087 610.768.2811 Delaware Schuylkill Community Action 225 N Centre St Pottsville, PA 17901 570.622.1995 Berks, Carbon, Lebanon, Lehigh, Luzeme, Northumberland, Schuylkill Shenango Valley Urban League, Inc 601 Indiana Ave Farrell, PA 19121 724.981.5310 Crawford, Lawrence, Mercer South Philadelphia HOMES, Inc. 1444 Point Breeze Ave Philadelphia, PA 19146 215334.4430 Philadelphia Southwest Community Development Corporation 6328 Paschall Ave Philadelphia, PA 19142 215.729.0800 Philadelphia Retrieved December 6, 2010 from http:/Ywww.phfa.org/forms/counscling_agencies/hemap_agencies/hcmap.pdf Southwestern PA Legal Services 45 E Main St STE 200 Uniontown, PA 15401 724.439.3591 Fayette Southwestern PA Legal Services 63 S Washington St Waynesburg, PA 15370 724.627.3127 Greene Southwestern PA Legal Services -Somerset County 218 West Kimberly Avenue Suite 101 Somerset, PA 15501 814.443.4615 Somerset Southwestern PA Legal Services Inc. 10 W Cherry Av. Washington, PA 15301 724.225.6170 Washington St. Martin Center 1701 Parade St Erie, PA 16503 814.452.6113 Crawford, Erie, Venango, Warren Lycoming-Clinton Counties Commission for 2138 Lincoln St P.O.Box 3568 Williamsport, PA 17701 570.326.0587 Centre, Clinton, Lycoming, Union Community Action 800.452.0148 Tableland Services Inc. 535 E Main St Somerset, PA 15501 Bedford, Cambria, Fayette, Somerset, Westmoreland 814.445.%28 800.788.5062 TABOR Community Services, Inc. 308 E King St Ste. 1, Lancaster, PA 17608 Chester, Lancaster, Lebanon 717.397.5182 The Partnership CDC 4020 Market St; STE 100 Philadelphia, PA 19104 215.662.1612 Philadelphia The Pittsburgh Community Reinvestment Group 1901 Centre Avenue; STE 200 Pittsburgh, PA 15219 412.391.6732 Allegheny 570.928.9668 The Trehab Curter o(Northeastem PA Gartner[ Street, P.O. Box 389, Dushore, PA 18614 Sullivan 800.982.4045 800.9824045 The Trehab Center of Norteastetn PA 10 Public Ave PO Box 366 Montrose, PA 18801 Susquehanna, Wyoming 570.2783338 570.265.6179 The Trehab Center of Norteastem PA 147 Oak Ridge Drive Towanda, PA 18848 Bradford 800.982.4045 8011.982.4045 The Trehab Center of Norteastem PA 52 Plaza Ln Wellsboro, PA 16901 Tioga 570.724.5252 United Communities Southeast Philadelphia 2029 S 8th St Philadelphia, PA 19148 215.467.8700 Philadelphia United Neighborhood Centers of Nonheastem PA 425 Alder Street Scranton, PA 18505 570.346.0759 Lackawanna, Luzeme, Wayne, Wyoming Universal Companies 800 S 15th St Philadelphia, PA 19146 215.732.6518 Philadelphia Urban League of Philadelphia 121 S Broad St; 9th FL Philadelphia, PA 19107 215.985.3220 Bucks, Chester, Delaware, Philadelphia Urban League of Pittsburgh 610 Wood Street Pittsburgh, PA 15222 412.227.4802 Allegheny Voices for Independence 1107 Payne Ave Erie, PA 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 OC 16365 814.726.2400 Forest, Warren West Oak Lane Community Development Corporation 7300 Ogontz Avenue Philadelphia, PA 19138 215.224.0880 Philadelphia CDC Retrieved December 6, 2010 from http://www.phfa.org/forms/counseling_agencies/hemap_agencies/hemap.pdf 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 LAV DUFFI , r? r Alan M. Minato, Esquire PA ID 75860 t' ILED-OFRCE = T H PROTHONOTARY UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF 2011 JUN 22 AM 10: 04 BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 CUMBERLAND COUNTY LORRAINE DOYLE, ESQUIRE - ID #34576 PENNSYLVANIA ALAN M. MINATO, ESQUIRE - ID #75860 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 DANIEL S. SIEDMAN, ESQUIRE - ID #306534 HEATHER RILOFF, ESQUIRE - ID #309906 SHERNESE V. WOODBINE, ESQUIRE - ID#91209 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadines(a)udren.com The Bank of New York Mellon, as Indenture Trustee for American Home Mortgage Investment Trust 2004-4 1525 S. Beltline Rd. Coppell, TX 75019 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County n\ NO. U V. MICHAEL P. RUELL 403 DEERFILED ROAD CAMP HILL, PA 17011 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; Marguerite L. Thomas, Esquire; Daniel S. Siedman, Esquire; Heather Riloff, Esquire, Shernese V. Woodbine, Esquire on behalf of the Plaintiff, in the above-captioned matter. UDREN LAW OFFICES, P.C. --- BY4 Alan M. Minato, PA ID 75860 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff FILED-OFFICE Jody S Smith Chief Deputy Richard W Stewart 2011 JUL -7 PM 2: G 3 Solicitor CUMBERLAW COUN ;' PENNSYLVAINi The Bank of New York Mellon vs. Case Number Michael Ruell 2011-5189 SHERIFF'S RETURN OF SERVICE 07/01/2011 08:25 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on July 1, 2011 at 2025 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Michael Ruell, by making known unto himself per nally, at 403 Deerfield Road, Camp Hill, Cumberland County, Pennsylvania 17011 its content"nd at a same time handing to him personally the said true and correct copy of the same. / /!1 C, SHERIFF COST: $43.00 July 05, 2011 SFfAWN HXRFTI-SON, DEPUTY SO ANSWERS, 6Z' RON R ANDERSON, SHERIFF UDREN LAW OFFICES, P.C. C' C T `ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENT, C. 111 WOODCREST ROAD, SUITE 20 F L9pj 1+ CHERRY HILL, NJ 08003-3620 cUMBEPLAND COUNTY 856-669-5400 PENNSYLVANIA pleadingsgudren.com The Bank of New York Mellon, as Indenture Trustee for American Home Mortgage Investment Trust 2004-4 Plaintiff V. MICHAEL P. RUELL 403 DEERFIELD ROAD CAMP HILL, PA 17011 Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 11-5189 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: February 24, 2012 UDREN LAW OFFICES, P.C. BY: e_?? Attorney for Plaintiff KASSIA FIALKOFF, ESQUIRE PA ID 310530 MJU#: 11060078 CASE#: 11060078-1 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 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 DANIEL S. SIEDMAN, ESQUIRE - ID #306534 HEATHER RILOFF, ESQUIRE - ID #309906 SHERNESE V. WOODBINE, ESQUIRE - ID#91209 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsnudren.com The Bank of New York Mellon, as Indenture Trustee for American Home Mortgage Investment Trust 20044 Plaintiff v MICHAEL P. RUE LL 403 DEERFILED ROAD CAMP HILL, 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 unworn falsification to authorities. Date: u2v ma 11 ? ff- - Nance: "''q! , a Edwards Title: V e President Company: American ome Mortgage Servicing, Inc. As servicer on behalf of The Bank of New York Mellon, as Indenture Trustee for American Home Mortgage Investment Loan 2004-4 MJU #: 11060078 CASE #: 11060078-1 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 2010 -' CHERRY HILL, NJ 08003-3620'' H O INO Tt? t 856-669-5400 2/ b!.7 FEE 29 fpIC.: u3 pleadings@udren.com The Bank of New York Mellon as CUM3ERL6(N]DiZ1)W kTgOMMON PLEAS Indenture Trustee for American Home PENN MWISION Mortgage Investment Trust 2004-4 Cumberland County 1525 S. Beltline Rd. Coppell, TX 75019 Plaintiff V. MICHAEL P. RUELL 403 DEERFIELD ROAD CAMP HILL, PA 17011 Defendant(s) MORTGAGE FORECLOSURE NO. 11-5189 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s), MICHAEL P. RUELL; for 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: FROM Unpaid Principal Balance Interest Per Complaint Additional Interest 06/04/2011 Late Charges Per Complaint Additional Late Charges 06/04/2011 Title Report Attorney Fees- Estimated NSF Charges Recoverable Balance Grand Total TO $109,569.58 $1,454.84 02/24/2012 $2,495.08 $57.08 02/24/2012 $128.43 $325.00 $1,300.00 $20.00 $119.20 $115,469.21 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. UDREN LAW OFFICES, P.C. BY: Attorney for Plaintiff 3KSI1A LKOFF QUIRE DAMAGES ARE HEREBY ASSESSED AS INDICATED PA 10 DATE: PR MJU#: 11060078 CASE#: 11060078-1 -,, W. SO 0 Q_J C k.+? a L(S So _ 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 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 DANIEL S. STEDMAN, ESQUIRE - ID #306534 HEATHER RILOFF, ESQUIRE - ID #309906 SHERNESE V. WOODBINE, ESQUIRE - ID#91209 WOODCREST CORPORATE CENTER 111. WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings ibudren.com The Bank of New York Mellon, as Indenture Trustee for American Home Mortgage Investment Trust 2004-4 C/O American Home Mortgage Servicing, Inc. 1525 S. Beltline Rd. Coppell, TX 75019 Plaintiff V. MICHAEL P. RUELL 403 DEERFILED ROAD CAMP HILL, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF. CE, " czar r. f? ?-n C' COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. 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 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. _ 1166,,Z-7E- f SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor fE,a??ttit?? a4 t?utr?3+?rt,?r? t 0477'M OF THE SI&M- PF The Bank of New York Mellon vs. Michael Ruell Case Number 2011-5189 SHERtFF`S-RETURN-OF SERVICE 07101/2011 08:25 PM - Shawn Harrison, Deputy Sheriff, who being duly swom according to law, states that on July 1, 2011 at 2025 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Michael Ruell, by making known unto himself pe nally, at 403 Deerfield Road, Camp Hill, Cumberland County, Pennsylvania 17011 its content nd at e same time handing to him personally the said true and correct copy of the same. (JO G WN H%KISON, DEPUTY SHERIFF COST: $43.00 July 05, 2011 SO A NSWERS, 6 L RON R ANDERSON, SHERIFF ci Cexns}S!?te Shenff. 'fe{aoso?, Itx. UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 The Bank of New York Mellon, as Indenture Trustee for American Home Mortgage Investment Trust 2004-4 Plaintiff V. MICHAEL P. RUELL, ET AL Defendant(s) TO:MICHAEL P. RUELL 403 DEERFIELD ROAD CAMP HILL, PA 17011 Date of Notice: July 22, 2011 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 11-5189 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 Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTIFICACION IMPORTANTE LISTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO I-IABER 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 O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCI . EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIA.TAMENTE SI USTED NO TIENTE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O 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 Countv Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. UDREN LAW OFFICES, PC. Woodcrest Corporate Center 1 I 1 Wooderest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Feb-24-2012 11:36:33 < Last First/Middle Begin Date Active Duty Status Active Duty End Date Service Name Agency RUELL MICHAEL Based on the information you have furnished, the DMDC does not possess any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). y6t 14 4A4-fly?? Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https://www.dmde-osd.mil/appj/scra/popreport.do 2/24/2012 Request for Military Status Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:QPHP5390QD https://www.dmdc.osd.mil/appj/scra/popreport.do 2/24/2012 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Rleadings@udren.com The Bank of New York Mellon, as Indenture Trustee for American Home Mortgage Investment Trust 2004-4 Plaintiff V. Michael P. Ruell COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE; NO. 11-5189 Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE UNDER Pa.R.C.P 76 THE UNDERSIGNED states based upon a search of the Department of Defense Manpower Data Center for the Defendant(s), that the Defendant(s), MICHAEL P. RUELL, who/each of whom is over 18 years of age is/are not in active military service as defined in the Servicemembers' Civil Relief Act. The Military Status Report(s) is/are attached hereto as Exhibit "A". The Affiant lacks sufficient information to be able to determine whether any other Defendants in this action are in active military service because Plaintiff cannot provide date(s) of birth and/or Social Security number(s) for said Defendant(s) to enable a search. This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Attorney for Plaintiff KASSIA FIALKOFF, ESQUIRE PA ID 310530 MJU#: 11060078 CASE#: 11060078-1 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-5189 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due THE BANK OF NEW YORK MELLON, AS INDENTURE TRUSTEE FOR AMERICAN HOME MORTGAGE INVESTMENT TRUST 2004-4 Plaintiff (s) From MICHAEL P. RUELL (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: $115,469.21 L.L.1 . SC7 Interest from 2/25/12 to Date of Sale June 6, 2012 on going per diem of $9.38 to actual date of sale including if sale is held at a later date - $966.14 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $182.50 Other Costs: Plaintiff Paid: Date: 2/29/12 -11-1 lad" (Seal) David D. Buell, Prothonotary Deputy REQUESTfNG PARTY: Name: KASSIA FIALKOFF, ESQUIRE Address: UDREN LAW OFFICES, P.C. 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 310530 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings(audren.com The Bank of New York Mellon, as COURT OF COMMON PLEAS Indenture Trustee for American Home CIVIL DIVISION Mortgage Investment Trust 2004-4 Cumberland County Plaintiff V. MORTGAGE FORECLOSURE Michael P. Ruell Defendant(s) NO. 11-5189 PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due $.115,469.21 Interest From 2/25/2012 $ 966.14 to Date of Sale June 6, 2012 Ongoing Per Diem of $9.38 to actual date of sale including if sale is held at a later date (Costs to be added) $ ?. -17 Ern r- ,. kn _ C C3 ? - > c7 ca . - ! -f c , UDREN LAW OFFICES, P.C. BY: Attorn rfor? Plaintiff KASSIA FIALKOFF, ESQUIRE PA ID 310530 ^MJU#: 11060078 CASE#: 11060078-1 LI3. c)o C1Qr- C(a.M t% 1( tt it a tj 9 ;-- 4 av? S,; ?U-pa?a $ Q. '.? S due. d I . so L4- CIA fL* a -71-7? i. Il?r;t?g e??ss?l UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 "I adings a*udren.com The Bank of New York Mellon, as Indenture Trustee for American Home Mortgage Investment Trust 2004-4 Plaintiff V. ATTORNEY FOR PLAINTIFF ern M -` r COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County an , CD ., c MORTGAGE FORECLOSURE Michael P. Ruell Defendant(s) NO. 11-5189 CERTIFICATE OF ACT 91 I hereby state that as the attorney for the Plaintiff in the above-captioned matter: M Act 91 procedures have been fulfilled F1 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. Attorney for Plaintiff .ASSIA FIALKOFF, ESQUIRE PA ID 310530 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 -0a 856-669-5400 M CU M pleadings(&udren.com The Bank of New York Mellon, as COURT OF COMMON PLEAS ;-- --?t---. Indenture Trustee for American Home CIVIL DIVISION ° Mortgage Investment Trust 2004-4 Cumberland County 5 C7 ? Plaintiff , ;;> V. MORTGAGE FORECLOSURE '' '. Michael P. Ruell NO. 11-5189 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 The Bank of New York Mellon, as Indenture Trustee for American Home Mortgage Investment Trust 2004-4, 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: 403 Deerfield Road, Camp Hill, PA 17011 1. Name and address of Owner(s) or reputed Owner(s): Michael P. Ruell 403 Deerfield Road Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: Michael P. Ruell 403 Deerfield Road Camp Hill, 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: The Bank of New York Mellon, as Indenture Trustee for American Home Mortgage Investment Trust 2004-4 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 403 Deerfield Road Camp Hill, 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: 19- 1 Z UDREN LAW OFFICES, P.C. Attorney for Plaintiff KASSIA FIALKOFF, ESQUIRE PA ID 310530 MJU#: 11060078 CASE#: 11060078-1 UDREN LAW OFFICES, P.C. J` r t IN.3QRNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER t l2 FGB 2g Ail 10: 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 CUMBERLAND COUN'TY' 856-669-5400 PENNSYLVANIA pleadings (a ,udren.com The Bank of New York Mellon, as COURT OF COMMON PLEAS Indenture Trustee for American Home Mortgage Investment Trust 2004-4 Plaintiff V. MICHAEL P. RUELL Defendant(s) CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 11-5189 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Michael P. Ruell 403 Deerfield Road Camp Hill, PA 17011 Your house (real estate) at 403 Deerfield Road, Camp Hill, 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 $115,469.21, 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. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I . 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 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor The Bank of New York Mellon vs. Michael P. Ruell Case Number 2011-5189 SHERIFF'S RETURN OF SERVICE 03/21/2012 02:24 PM - Deputy Tim Black, 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 403 Deerfield Road, Lower Allen Township, Camp Hill, PA 17011, Cumberland County 03/28/2012 08:41 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Michael P. Ruell at 403 Deerfield Road, Lower Allen Township, Camp Hill, PA 17011, Cumberland County. 05/18/2012 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: $626.76 SO ANSWERS, May 25, 2012 RON R ANDERSON, SHERIFF i U S i air ,? 29 P{ 1~ ' . g ?! l PE:NNSYIVA??!1 „M ??5?&?. UDREN .LAW OFFICES, P.C. VWOODCREST CORPORATE CENTER III WOODCR-tST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings(a, dren.com The Bank of New York Mellon, as Indenture Trustee for American Home Mortgage Investment Trust 2004-4 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County V. MORTGAGE FORECLOSURE Michael P. Ruell Defendant(s) NO. 11-5189 AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 The Bank of New York Mellon, as Indenture Trustee for American Home Mortgage Investment Trust 20044, 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: 403 Deerfield Road, Camp Hill, PA 17011 1. Name and address of Owner(s) or reputed Owner(s): Michael P. Ruell 403 Deerfield Road Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: Michael P. Ruell 403 Deerfield Road Camp Hill, 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: The Bank of New York Mellon, as Indenture Trustee for American Home Mortgage Investment Trust 2004-4 1525 S. Beltline Rd. Coppell, TX 75019 Sr Mortgagee Holders - None Jr Mortgage Holders - None A 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 403 Deerfield Road Camp Hill, 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/Hotieowners 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. f DATED: ! f- UDREN LAW OFFICES. P.C. Attorney for Plaintiff KASSIA FIALKOFF, ESQUIRE PA ID 310530 MJU#: 110640078 CASE#: 11060078-1 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 The Bank of New York Mellon, as Indenture Trustee for American Home Mortgage Investment Trust 2004-4 Plaintiff V. MICHAEL P. RUELL Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 11-5189 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Michael P. Ruell 403 'Deerfield Road Camp Hill, PA 17011 Your house (real estate) at 403 Deerfield Road, Camp Hill, PA 17011 is scheduled to be sold at the Sheriff s 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 $115.462.21, 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 hove to obtain an attorney.) OU MA IGHTS VE 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. t 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. WOODCRLST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 ATTORNEY FOR PLAINTIFF The Bank of New York Mellon, as I COURT OF COMMON PLEAS Indenture Trustee for American Home CIVIL DIVISION Mortgage Investment Trust 2004-4 Cumberland County Plaintiff v. -- - .-I -MORTGAGE FORECLOSURE MICHAEL P. RUELL 1 NO. 11-5189 Defendant(s) SHORT DESCRIPTION FOR ADVERTISING ALL THAT CERTAIN LOT OF LAND SITUATE IN TOWNSHIP OF LOWER ALLEN, CUMBERLAND COUNTY, PENNSYLVANIA: BEING KNOWN AS 403 Deerfield Road, Camp Hill, PA 17011 PARCEL NUMBER: 13-24-0809-010 IMPROVEMENTS: Residential Property UDREN LAW OFFICES, P.C. Attorney for Plaintiff KASSIA FIALKOFc ESQUIRE PA ID 310530 ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES, SITUATE, LYING AND BEING IN THE TOWNSHIP OF LOWER ALLEN IN THE COUNTY OF CUMBERLAND AND COMMON-WEALTH OF PENNSYLVANIA, MORE PARTICULARLY DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE NORTHEASTERLY LINE OF DEERFIELD ROAD, A 50 FOOT WIDE RIGHT-OF-WAY, WHICH SAID POINT OF THE BEGINNING IS LOCATED AT THE INTERSECTION OF THE NORTHEASTERLY LINE OF DEERFIELD ROAD AND THE DIVIDING LINE BETWEEN LOTS NO.7 AND 8 ON THE RESUBDIVISION PLAN OF ALLENDALE, SECTION 9, RECORDED IN CUMBERLAND COUNTY PLAN BOOK "25", PAGE 133; THENCE, FROM SAID POINT OF BEGINNING ALONG THE NORTH EASTERLY LINE OF DEERFIELD ROAD, NORTH 24 DEGREES 58 MINUTES 110 SECONDS WEST, A DISTANCE OF 100.00 FEET TO A POINT ON THE DIVIDING LINE BETWEEN LOTS NOS. 6 AND 7; THENCE FROM SAID POINT ALONG THE DIVIDING LINE BETWEEN LOTS NOS. 6 AND 7 NORTH 65 DEGREES 1 MINUTE 50 SECONDS EAST, A DISTANCE OF 170.03 FEET TO A POINT; THENCE FROM SAID POINT, SOUTH 24 DEGREES 58 MINUTES 10 SECONDS EAST, A DISTANCE OF 100.00 FEET TO A POINT ON THE DIVIDING LINE BETWEEN LOTS NOS. 7 AND 8; THENCE -FROM SAE) PDINT_ALONja-THE DIVIDING LINE BETWEEN LOTS NO. 7 AND 8, SOUTH 65 DEGREES 1 MINUTES 50 SECONDS WEST, A DISTANCE OF 170.03 FEET TO - -- A POINT, THE POINT AND PLACE OF BEGINNING. BEING LOT NO. 7 ON THE RESUBDIVISION PLAN OF ALLENDALE, SECTION 9, RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS OF CUMBERLAND COUNTY, PENNSYLVANIA, IN PLAN BOOK "25", PAGE 133. BEING KNOWN AS: 403 DEERFIELD ROAD, CAMP HILL, PA 17011 PROPERTY ID NO.: 13-24-0809-010 TITLE TO SAID PREMISES IS VESTED IN MICHAEL P. RUELL, SINGLE INDIVIDUAL BY DEED FROM MICHAEL H. RUELL AND CAROL RUELL DATED 11/08/2004 RECORDED 11/29/2004 IN DEED BOOK 266 PAGE 2234. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-5189 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due THE BANK OF NEW YORK MELLON, AS INDENTURE TRUSTEE FOR AMERICAN HOME MORTGAGE INVESTMENT TRUST 2004-4 Plaintiff (s) From MICHAEL P. RUELL (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. v Amount Due: $115,469.21 L. L.: Interest from 2/25/12 to Date of Sale June 6, 2012 on going per diem of $9.38 to actual date of sale including if sale is held at a later date - $966.14 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $182.50 Other Costs: Plaintiff Paid: Date: 2/29/12 David D. B 11, Prothono ry (Seal) Deputy REQUESTING PARTY: Name: KASSIA FIALKOFF, ESQUIRE Address: UDREN LAW OFFICES, P.C. 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 310530 TRUE COPY FROM RECORD In Testimony whereof, i here unto set my hand and the seal of said Cou at Carlisle2,OPa- This _aY of '12 112 Proth otary ?,? CL V?kc'&' 1? On March 14, 2012 the Sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA, known and numbered 403 Deerfield Road, Camp Hill, PA 17011 more fully described on Exhibit"A" filed with this writ and by this reference incorporated herein. Date: March 14, 2012 By: For Claudia Brewbaker, Real Estate Coordinator (C- Writ No. 2011-5189 Civil Term The Bank of New York Mellon, as Indenture Trustee for American Home Mortgage Investment Trust 2004-4 VS. Michael P. Ruell Atty.: Mark Udren BEING KNOWN AS 403 Deerfield Road. Camp Hill, PA 17011. PARCEL NUMBER: 13-24-0809- 010. IMPROVEMENTS: Residential Property. KASSIA FIALKOFF, ESQUIRE PA ID 310530 UDREN LAW OFFICES; P.C. Attorneys for Plaintiff PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA . ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 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 subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. isa arie Coyne, Editor SWORN TO AND SUBSCRIBED before me this 1 da of Ma 2012 Notary NOTARIAL AL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 I fit' r'd Ltl(ul.-IVCY9? 4-IR 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFF ICE CUMBERLAND COUNTY COURT HOUSE ?1' !?I': '??111 t U.0 Now 0"")u kno,?t CARLISLE Pr; 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication irder Act No 587. Approved May 16, 1S29 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn accord-ng to law. deposes and says That she is a Staff Accountant of True Patriot News Co.. a corporation organi; ed and existing under th ? laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in :he Township of Hampden, County of Cumberlard, State of Pennsylvania, owner and publisher of The Patriot-Nevis and The Sunda\, Patriot-News newspapers of general circulation, printed and published at 1900 Patrio: Drive, in the City, Count/ and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1944 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 regu!a daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor sa d Company is interested in the subject matter cat said printed notice or advertising, and that all of the allegations :)f this state-nen? a 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 of 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 reco,ded in the office for the Recordincl o- Deeds n and for said County of Dauphin in Miscella°ieous Book -M Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: (14/:27/12 12011-5189 Civil Term The nk 0" New York Mellon, as Indehture Trust" for American Home Mortgage Investment Trust 2004-4 VS Michael P. Ruell Atty: Mark Udren JCE . G KNOWN AS 403 Deerfield Road. Mill, PA 17011 P EL NUMBER: 13-24-0809-010 OVEMENTS: Residential Property NLAW OFFICES; PC. Attorney for plaintiff KASSIA FIALKOFF, ESQUIRE PA ID 310530 (15/04/12 (15/11/12 r .. ?_? a_............ . ll1 Swc.rn to and subscribed befeSre me this 22 iiay of May, 2012 A D. Notary Public _ C®fNMONWEkLT_ OF PENNSYLVANNa Notarial -Sea, Si er. i ; ns, N,ra Y Public _ower Pax o,i fju?hin t°{y Comm ssiv i ?xgires d?,v ?b, 2015 .M MBEP,, PF A'NSYI VAI\,R SS( r Zi-)h ()F N() 5iaFE ' ? UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com The Bank of New York Mellon, as Indenture Trustee for American Home Mortgage Investment' Trust 2004-4 Plaintiff V. Michael P. Ruell Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 11-5189 PRAECIPE TO WITHDRAW JUDGMENT TO THE PROTHONOTARY: cri? i~u Kindly withdraw the Judgment entered on 02/29/2012 upon, Michael P. Ruell , in the amount of $ 115,469.21 DATED: l? #q.50 PO Arry at 0 1139 &&16019 MN#: 11060078 CASE#: 11060078-1 PA 10 309356 ..