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HomeMy WebLinkAbout12-0728FILED-OFFICE. O WE P, OTHOWOTAR k? 1o• 08 Cij4BMSY?DA? p" FEIN 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 PAIGE M. BELLING, ESQUIRE - ID#309091 HARRY B. REESE, ESQUIRE - ID#310501 AMY GLASS, ESQUIRE - ID#308367 KASSIA FIALKOFF, ESQUIRE - ID#310530 DONNA L. SKILTON, ESQUIRE - ID#206551 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 WOODCREST CORPORATE CENTER ATTORNEY FOR PLAINTIFF 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,-NJ 08003-3620 856-669-5400 pleadingsa)udren.com U.S. Bank, N.A. as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC1 C/O Ocwen Loan Servicing, LLC 1661 Worthington Road #100 West Palm Beach, FL 33409 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. abl a_?o?? ?l1/1? V. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT TITLE OR INTEREST FROM OR UNDER PATRICIA M. SOBOTOR, DECEASED 19 HOLLY ESTATES DRIVE GARDNERS, PA 17324 MICHAEL P. SOBOTOR 19 HOLLY ESTATES DRIVE GARDNERS, PA 17324 PATRICIA M. SOBOTOR, DECEASED 19 HOLLY ESTATES DRIVE GARDNERS, PA 17324 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE O?Ik? ? 10? 7s ?d ct tfy C,k.t? a ? 3?Y f a3oaa 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. 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 provisioner 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: Ameriquest Mortgage Company Assignee: Lehman Capital, A division of Lehman Brothers Holdings, Inc. Date of Assignment: 07/25/2006 Recorded Date: 09/13/2006 Book/Instrument #: 730 Page: 1657 Assignor: Lehman Capital, A division of Lehman Brothers Holdings, Inc Assignee: U.S. Bank, N.A. as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC1 Date of Assignment: Recorded Date: Book/Instrument #: Page: 2. Upon information and belief Defendant(s) and/or their predecessor: (Estate of) Patricia M. Sobotor & Michael P. Sobotor (hereinafter "Defendants"), are the owners of property located at 19 Holly Estates Drive, Gardners, PA 17324, by virtue of Deed dated 09/08/1999 and recorded 09/14/1999 in Official Records Book 207 at Page 735 of the Public Records of Cumberland County, Pennsylvania (hereinafter the "Property"). 3. On 09/08/1999, Defendant(s) and/or their predecessor: (ESTATE OF) PATRICIA M. SOBOTOR & MICHAEL P. SOBOTOR promised to pay to the order of Ameriquest Mortgage Company, the principal sum of $ 84,000.00 payable with interest thereon provided in the Note. 4. By Mortgage dated 09/08/1999, Defendant(s) and/or their predecessor: (ESTATE OF) PATRICIA M. SOBOTOR & MICHAEL P. SOBOTOR to secure the Note, mortgaged to Ameriquest Mortgage Company, the Property which is the subject of this action. The Mortgage was recorded on 09/14/1999 in Official Records Book 1570 at Page 401 . 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. 6 Said mortgage is in default in that the payment due 09/01/2011, 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. 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 $59,915.69 Accumulated Interest $1,232.78 Accumulated Late Charges $276.54 Escrow Deficit/(Reserve) $389.61 Title Search $300.00 Attorney fee $1,300.00 Property Inspection $21.00 Property Valuation $292.00 Grand Total $63,727.62 The above figures are calculated as of 12/28/2011: 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 5.12500 %. The per diem interest accruing on this debt is $8.24 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 $46.09. 7. Breach letters have been sent to Defendant(s) in accordance with the requirements of the subject mortgage and/or The Pennsylvania Act 6 of 1974 of the Commonwealth of Pennsylvania and, if applicable, 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 563,727.62 plus ongoing inte4PA ' eys fees and for sale of the Mortgaged premises. CES, P.C. g, Esquire 5362 VERIFICATION The undersigne d 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: III ?., MJU #: 11121056 CASE #: 1.11.21056-1 ,i0q, I 94,__ Nancy (9r Title: Company: OCwenLoa? n? Servicing, LLC as servicer on behalf of U.S. Bank, N.A. as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC1 ALL =41 CERTAIN tv"t at Sand etth lyroreteate fs thereon aituat0 to Dtesiosen Touaakif. tvmbeslaed aaanay. ponnsyluansa, beunded.and described in assoldeaoe alth Nat4 subdivistoa plan for bails sotskea propered by ? Rasaaiatas, 3urvaf4.d, dated November 29, 1177. 0600146 (1) pass, a easy of vhfak is retarded to Cumberland Rook $3, fast lei on laptambor 20,?MTWI, and inoorpora " by votersaoe as follows, to sit: IMMINiND at a palAt ea the uasta6r41y 1140 of 19 1 Arius {SO East aide cisht of ray) as tbo southeast' Ma. io an a certain subdivistoa for Risberd R. Andar6aRi in plan Reek 24. ?ass 1SS) thanes br Cho eaatwsdly 1s seid Notiv =stases hive, south 17 *"we" 1o also" If. vest.'Dta test to a point being the oaetkeast aosdh at an rten of Kelly cstetea as atorassid) tbasea by tbq as y vooth 72 dasrose 30 minutes 32 aoesbds test, 226.14 t point at line of lamda Rea at fovmglrr et Jobm Delp) said lands too or tormacly at Jake Delp, Narth 11 dogr W mittwtea is seconds cast, 14631 feet to a point bsly southwest carnor of Let do. 9 an the sukdivlaien tar` ladeasan ee asoeao4d2 tkonas by Let so. a amd IAt so. aubdivietao ter atanard t. aneeieee. sewak 73 4a906e9 32 ascends coat 291.14 test to s point. Cho pleas of a .. 46N112NTNG 1.6264 doves. more or toes. s? .j? . ? s J'• Q?a, -x'11 5 #AIU3Z' 60 1 ,LLEGt6LE OMINAL l t.E??BLE OWGINAL a6ad=rvc ,A07 I Ociren Loan Servicing, LLC 1'. 0. Box 24737 i7 _ ............... I1'es1 Palm Beach, f lorida 33416-4737 O G W E N (Do not send correspondence or payments to the above address.) WAN,` k1'.OC i" EN.COM October 29. 2011 VIA First Class Mail VIA Certified Mail (return receipt requested) Certified Number: 71069017515145509981 Reference Code: 1109 Estate of Patricia M. Sobotor 19 Holly Estates Drive Gardners. PA 17324 Loan Number: 30395008 Property Address: 19 Hollv Estates Drive , Gardners, PA 17324-0000 PLEASE SEE THE ENCLOSED DOCUMENT EXHIBIT A . r- uu-munieuccvrt rs.from a aeot 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 constilzrte an attempt to collect a debt NML S # 1852 Ocwen Loan Servicing, L LC P.O. Boa- 24737 - --....._':- 1t'est Palm Beach. Florida 33416-4737 O O W E N (Do not send correspondence or payments to the above address.) October 29. 2011 APPENDIX A ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default and the lender intends to foreclose. pecific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be 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 THIRTY (30) DAY 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 Countyare listed at the end of this Notice If you have any questions,youu may call the Pennsvlvania Housing Finance Agency toll free at 1800) 342-2397 (Persons with impaired hearing can call (717) 780-1869). Thia 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 la , er 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: Estate of Patricia M. Sobotor 19 Holly Estates Drive Gardners, PA 17324-0000 LOAN ACCT. NO.: 30395008 ORIGINAL LENDER: AMRIQUEST MORTGAGE COMPANY CURRENT LENDER/SERVICER: OCWEN DACT91.21 This communication is f -om 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 bankruptgy this communication is not intended as and does not constitute an attempt to collect a debt t'W".0CA N.COM NMLS # 1852 b Ocltien Loan Servicing, LLC n P.O. Box 24,'3? N.J ll est Palm Beach, lorida 33416-4737 O C W E N (Do not send correspondence or payments to the above address.) "INN?\? .OC?NIEN.CQM HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF A'OI' 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 FORECLOSU RE --Under the Act you are entitle d to a temporary stay of foreclos ure on. your mortgage for thir ty (30) days from t he date of this Notice During that ti me you must arrange and attend a "face- to-face" meeting with one of the consum er credit counseling agencies listed at the end of this Notice THIS MEE TING MUST OCCUR WIT HIN THE NEXT (30) DAYS IF YOU DO NOT APP LY FOR EMERGENCY MORT GAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE THE PART OF THIS NO TICE- CALLED"HOW TO C URE YOUR MO RTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORT GAGE 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 rile 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 MIST 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 riled bankruptcy you can still apply for Emergency Mortgage Assistance). HOW TO CURE YOUR MORTGAGE DEFAULT tBring it up to date). DACT91.21 This communication is from a debt collector attempting to collect a debt; any information obtained ivill be used.for that purpose. Holvever, if the debt is in active bankruptcy, or has been discharged through bankruplev, this communication is not intended as and does not constitute an attempt to collect a debt NML S # 1852 Ociven Loan Servicing. LLC P.O. Box 24737 -Pest Palm Beach. Florida 33416-473 O G W E N (Do not send correspondence orpayments to the above address.) www.OCbVEN.Cum NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender on your property located at: 19 Holly Estates Drive , Gardners, PA 17324-0000 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 $ 966.91 from September 01. 2011 through October 29, 2011 DETAIL SUMMARY : Principal and Interest ................................. interest Arrearage..................................... Escrow .................................................. Late Charges ........................................... Insufficient Funds Charges ........................... Fees Expenses ........................................ Suspense Balance (CREDIT) ........................ Interest Reserve Balance (CREDIT) ................ TOTAL DUE .......................................... $ 1,536.18 $ 0.00 $ 397.64 $ 230.45 $ 0.00 $ 302.50 $ 0.00 $ 0.00 $ 2,466.77 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 $2,466.77, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pavments must be made either by Monty Gram, Cashier's Check Certified Check or Money Order made. payable and sent to: OCWEN P.O. BOX 6440 CAROL STREAM, IL 60197-6440 IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose 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. If you cure the default within the THIRTY (30) DAY period. you will not be required to pay attorney's fees. OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. T 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 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. DACT91.21 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 NML S # 1852 Ociven Loan Servicing, LLC P.O. Box 24737 It est Palm Beach, Florida 33416-4737 O C W E N (Do not send correspondence or payments to the above address.) EARLIEST POSSIBLE SHERIFF'S A DATE -- It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the 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 servieer. HOW TO CONTACT THE SERVICER: Name of Servicer: OCWEN Address: P.O. BOX 24737 WEST PALM BEACH, FL 33416-4737 Phone Number: 800-310-9229 Fax Number: 407-737-6300 Contact: Early Intervention Dept EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property, and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may or 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 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 CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY DACT91.21 This communication is from a debt collector attempting to collect a debt; any, information obtained ivill be used for that paapose. Hrnvever, 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 Wk1'".0cwEN.C m NMLS # 1852 Ociven Loan Servicing. LLC 0' P. 0. Box 24737 West Palm Beach Florida 33416-41-37 OCW EN (Do not send correspondence or pgvments to the above address.) October 29. 2011 VIA First Class Mail VIA Certified Mail (return receipt requested) Certified Number: 71069017515145509974 Reference Code: 1109 Michael P. Sobotor 19 Holly Estates Drive Gardners. PA 17324-0000 Loan Number: 30395008 Property Address: 19 Holly Estates Drive . Gardners, PA 17324-0000 PLEASE SEE THE ENCLOSED DOCUMENT This communication is from a debt collector attempting to collect a debt; any information obtained will be used for than Z1- propose. However, it 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 'X W.QC.WEN.C'OM NMLS # 1852 Ociven Loan Servicing. L LC 1'. 0. Boy 24737 0 C W E N 11'est Yulm Beach. Morida 33416-4737 O (Do not send correspondence or payments to the above address.) October 1-9. 2011 APPENDIX A ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default and the lender intends to foreclo a 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 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 THIRTY (301 DAY OF TH 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 our 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 (717) 780-1869). This Notice contains important legal information If you have any Q estions representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney n your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION, OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO A ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. 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): Michael P. Sobotor PROPERTY ADDRESS: 19 Holly Estates Drive Gardners, PA 17324-0000 LOAN ACCT. NO.: 30395008 ORIGINAL LENDER: AMRIQUEST MORTGAGE COMPANY CURRENT LENDER/SERVICER: OCWEN This communication is from a debt collector attempting to collect a debt; any information obtained oACT91.21 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 W4N lk'.OCWEN.COI1 NML S # 1852 Octven Loan Servicing. LLC P.O. Boa 24737 fi'est Palm Beach, hlorida 33.116-4%3? O C W E N (Do not send correspondence or payments to the above address.) V+'N \N'.OC VYEN. C ON1 HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BV 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 FORECLOS URE --Under the Act, y ou are entitled to a temporary stay of foreclosu re on, your mortgage for thirt y (30) days from the date of this Notice Durin g that time you must arran ge and attend a "face- to-face" meeting with o ne of the consu mer credit counseling age ncies listed at the end of this No tice THIS MEE TING MUST OCCUR WITH IN THE NEXT (30)_DAYS. IF YOU D O N OT APPLY FOR EMERG ENCY MORTG AGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE THE PART OF THIS NO TICE- CALLED"HOW TO C URE YOUR M ORTGAGE DEFAU T" . EX PLAINS HOW TO BRING YOUR MORTG AGE 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 YOUR MORTGAGE DEFAULT (Bring it up to date). DACT91.21 This communication is,f'orn a debt collector attempting to collect a debt; any information obtained hill be used for that purpose. Holvever, 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 NML S # 1852 Qcwen Loan Servicing. L LC '.O. Box 24737 °°._._.? Pest Palm Beach. Florida 33416-4737 O C W E N (Do not send correspondence or payments to the above address.) 1'W W .0CGV'EN.COI\1 NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender on your property located at: 19 Holly Estates Drive , Gardners, PA 17324-0000 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 $ 966.91 from September 01. 2011 through October 29, 2011 DETAIL SUMMARY : Principal and Interest ................................. Interest Arrearage..................................... Escrow .................................................. Late Charges ........................................... Insufficient Funds Charges ........................... Fees Expenses ........................................ Suspense Balance (CREDIT) ........................ Interest Reserve Balance (CREDIT) ................ TOTAL DUE .......................................... $ 1.536.18 $ 0.00 $ 397.64 $ 230.45 $ 0.00 $ 302.50 $ 0.00 $ 0.00 $ 2,466.77 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 $2,466.77, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pavments must be made either by Monev Gram, Cashier's Check, Certified Check or Money Order made, able and sent to OCWEN P.O. BOX 6440 CAROL STREAM, IL 60197-6440 IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose 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. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO 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 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. DACT91.21 This communication is f rom 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 bankrupte1;, this communication is not intended as and does not constitute an attempt to collect a debt NML S # 1852 Ocwen Loan Servicing. LLC P.O. Box 24737 O C W E N f1"est Palm Beach, Florida 33416-4737 (Do not send correspondence or payments to the above address.) ?? 'N`.?CY1 E eOy1 EARLIEST POSSIBLE H RIFF' AL 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 will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the servicer. HOW TO CONTACT THE SERVICER: Name of Servicer: OCWEN Address: P.O. BOX 24737 WEST PALM BEACH, FL 33416-4737 Phone Number: 800-310-9229 Fax Number: 407-737-6300 Contact: Early Intervention Dept EFFECT OF SHERIFF' 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 She, iffs 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 AL O 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 (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 AGENCIES SERVING YOUR COUNTY DACT91.21 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 NMLS # 1852 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 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 PAIGE M. BELLINO, ESQUIRE - ID#309091 HARRY B. REESE, ESQUIRE - ID#310501 AMY GLASS, ESQUIRE - ID#308367 KASSIA FIALKOFF, ESQUIRE - ID#310530 DONNA L. SKILTON, ESQUIRE - ID#206551 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadini!s(&udren.com U S Bank N A T .Iff PROTNONOTAi? ? 7012 FEB -`1 AM 10' 01 Gu PENNSYLVCOUNTY • . as rustee for the Registered Holders of i COURT OF COMMON Structured Asset Securities Corporation Mortgage Pass- PLEAS Through Certificates, Series 2007-TC1 CIVIL DIVISION 1661 Worthington Road #100, West Palm Beach, FL 33409 CUMBERLAND County Plaintiff V. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT TITLE OR INTEREST FROM OR UNDER PATRICIA M. SOBOTOR, DECEASED 19 HOLLY ESTATES DRIVE GARDNERS, PA 17324 MICHAEL P. SOBOTOR 19 HOLLY ESTATES DRIVE GARDNERS, PA 17324 PATRICIA M. SOBOTOR, DECEASED 19 HOLLY ESTATES DRIVE GARDNERS, PA 17324 Defendant(s) ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the following counsel NO. ) 2 --); eivi ( Mark J. Udren, Esquire; Stuart Winneg, Esquire; Lorraine Doyle, Esquire; Alan M. Minato, Esquire, Sherri J. Braunstein, Esquire; Paige M. Bellino, Esquire; Harry B. Reese, Esquire; Amy Glass, Esquire; Kassia Fialkoff, Esquire; Donna L. Skilton, Esquire; Elizabeth L. Wassall, Esquire; on behalf of the Plaintiff, in the above-captio d matter. UDREN L FFI BY: ctllartWinneg, Esquire PA ID 45362 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson f i r Sheriff Jody S Smith ' - ca Chief Deputy Richard W Stewart au?? Solicitor `ABERL•rt "4 US Bank NA vs. Michael P. Sobotor Case Number 2012-728 SHERIFF'S RETURN OF SERVICE 02/13/2012 03:10 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on February 13, 2012 at 1510 hours, she served a true copy of the within Complaint in Mortgage Foreclosure upon the within named defendant, to wit: Michael P. Sobotor, by making known unto himself personally, at The Cumberland County Sheriffs Office, 1 Courthouse Square, Room 303, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. AMA DA COBAUGH, DEPUTY SHERIFF COST: $39.00 February 14, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF y , a TA, 1:' ?1 ?: C; ,rt v :J JE i nLAN ?) JNi IS y 3 COUNTY UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com U.S. Bank, N.A. as Trustee for the Registered € Holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC 1 Plaintiff V. Michael P. Sobotor Patricia M. Sobotor, Deceased Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right Title or Interest From or Under Patricia € M. Sobotor, Deceased Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. 2012-728 Civil PLAINTIFF'S MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, moves this Honorable Court for an Order directing service of the Complaint In Mortgage Foreclosure by publication in accordance with Pennsylvania Rule of Civil Procedure (Pa.R.C.P.) 430(b)(1); and service of all subsequent pleadings, including, inter alia, the Notice of Sheriffs sale, that requires personal service upon Defendants, Patricia M. Sobotor, Deceased, and Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right Title or Interest From or Under Patricia M. Sobotor, Deceased, by posting only, of the subject premises located at 19 Holly Estates Drive, Gardners, PA 17324, in accordance with Pa.R.C.P. 430; and in support thereof avers the following: 1. Plaintiff filed a Complaint in Mortgage Foreclosure against the above captioned Defendants. 2. Plaintiff has learned that Defendant Patricia M. Sobotor may be deceased. 3. Plaintiffinquired with the Social Security Death Index and found an entry for Patricia M. Sobotor. A true and correct copy is attached hereto as Exhibit "A". 4. The Plaintiff inquired with the Cumberland County Register of Wills Office and was advised that the County has no record of an Estate having been raised. A true and correct copy of Plaintiffs Good Faith Investigation is attached hereto as Exhibit "B". 5. It is therefore believed, averred and suggested that Defendant Patricia M. Sobotor is deceased. 6. Plaintiff has made a good faith effort to locate all known heirs so as to name them as parry defendants pursuant to Pa.R.C.P. 1144(a)(2) as evidenced by the attached Exhibits. 7. Although specific heirs may have been located, it is believed that there may be other "unknown heirs", who remain unidentified. WHEREFORE, so as to properly satisfy the Pennsylvania Rules of Court, particularly Pa.R.C.P. 1144(a)(2), (a)(3), where the Plaintiff is required to name as party defendants in an action in mortgage foreclosure the heirs of a deceased mortgagor(s), if known, and those of a deceased real owner, the Plaintiff moves this Honorable Court, and hereby requests an Order, pursuant to Pa.R.C.P. 430 et seq., directing service of the Complaint In Mortgage Foreclosure by publication upon the Defendants, Patricia M. Sobotor, Deceased; and Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right Title or Interest From or Under Patricia M. Sobotor, Deceased; and service of any and all subsequent pleadings including, inter alia, the Notice of Sheriff s Sale, that require personal service by posting only, of the subject premises located at 19 Holly Estates Drive, Gardners, PA 17324. UDREN LAW OFFICES, P.C. BY<_ Al mato, Esquire Pa. ID 75860 Attorneys for Plaintiff UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com U.S. Bank, N.A. as Trustee for the Registered € Holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC 1 Plaintiff V. Michael P. Sobotor Patricia M. Sobotor, Deceased Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right Title or Interest From or Under Patricia M. Sobotor, Deceased Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. 2012-728 Civil MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, U.S. Bank, N.A. as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC1, having filed its Motion for Service Pursuant to Special Order of Court, submits this Memorandum of Law in support hereof. Pennsylvania Rule of Civil Procedure 430(a) specifically provides, in part, that "(a) If service cannot be made under the applicable rule, the plaintiff may move the court for a special order directing the method of service." The purpose of the Motion is to seek special service of the Complaint In Mortgage Foreclosure on Patricia M. Sobotor, Deceased; and Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right Title or Interest From or Under Patricia M. Sobotor, Deceased. It is believed that there may be heirs of the deceased Defendant, yet they are unknown to the Plaintiff. Therefore, because the heirs are "unknown", and thus unidentifiable and unable to be located, service cannot be made under the applicable rule. Pennsylvania Rule of Civil Procedure 1144(a) (2) requires the Plaintiff to name as party defendants in an action in mortgage foreclosure the heirs of a deceased mortgagor. Pa.R.C.P. 1144(a)(3) is silent with regard to the heirs of a deceased real owner. As stated in the attached Motion, Defendant Patricia M. Sobotor, is deceased. So as to properly satisfy Pa.R.C.P. 1144(a)(2), (a)(3), a good faith effort to discover the whereabouts of any and all heirs has been made in accordance with Pa.R.C.P. 430(a), as evidenced by the good faith Affidavit of Investigation and Exhibits attached hereto. Known heirs may have been identified herein. However, so as to properly serve Patricia M. Sobotor, Deceased and any surviving heirs who are unknown to the Plaintiff, but who may have an interest in the mortgaged premises, the Plaintiff seeks service by publication with regard to the Complaint in Mortgage Foreclosure, and posting only, of the mortgaged premises with regard to all subsequent pleadings that require personal service, including, inter alia, the Notice of Sheriffs Sale. Pa.R.C.P. 430(6)(1) provides for service by publication. Further, Pa.R.C.P. 430(b)(2) provides for service by publication on unknown heirs: When service is made by publication upon the heirs and assigns of a named former owner(s) or party in interest, the court may permit publication against the heirs or assigns generally if it is set forth in the complaint or an affidavit that they are unknown. In conformity with Pa.R.C.P. 430(b)(2), the Plaintiff sets forth, as verified in the within Motion, that there may be unknown heirs. In order to complete service on the Defendant, Patricia M. Sobotor, Deceased; by and through surviving "unknown heirs", so as to move this foreclosure action forward to ultimate disposition, the Plaintiff respectfully requests that this Honorable Court, pursuant to Pa.R.C.P. 430 et seq., and for all of the reasons hereinbefore stated, and in the attached Motion, grant a Special Order directing service of the Complaint In Mortgage Foreclosure by publication on Defendants, Patricia M. Sobotor, Deceased; and Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right Title or Interest From or Under Patricia M. Sobotor, Deceased; and service of all subsequent pleadings including that require personal service, inter alia, the Notice of Sheriffs Sale, by posting only, of the subject premises located at 19 Holly Estates Drive, Gardners, PA 17324. Respectfully submitted, UDREN LAW OFFICES, P.C. Alan M. inato, Esquire Pa. ID 75860 Attorneys for Plaintiff Ancestry.com - Social Security Death Index Page 1 of 1 p4` ancestry?. Social Securih, Death Index Name: Patricia M. Sobotor Born: 1 Feb 1954__ . Died: 31 Oct 2007 State (Year) SSN Maryland (1968) issued: Source Citation: Issue State: Maryland; Issue Date: 1968. Source Information: Ancestn,.com. Social Security Death Index [database on-line]. Provo. U `L USA: Ancestmeom Operations Inc. 2011. Original data: Social Security= Administration. Social Security Death Index. Aluster File. Social Security Administration. Description: The. Social Securitv Administration Death Master File contains information on millions of deceased individuals with United States social security numbers whose deaths were reported to the Social Security Administration. Birth ' years for the individuals listed range from tS-5 to last year. Information in these records includes name, birth date, death date; and last known residence. © 2o11, The Generations Network, Inc. EXHIBIT A http://search.ancestry.com/cgi-bin/sse.dl]?MS AdvCB=1&db=ssdi&rank=l&new=1&MSAV=2... 12/21/2011 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadinesCa,udren.com U.S. Bank, N.A. as Trustee for the Registered '_. COURT OF COMMON PLEAS Holders of Structured Asset Securities :CIVIL DIVISION Corporation Mortgage Pass-Through CUMBERLAND County Certificates, Series 2007-TC1 Plaintiff V. Michael P. Sobotor Patricia M. Sobotor, Deceased Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right Title or Interest From or Under Patricia M. Sobotor, Deceased Defendant(s) NO. 2012-728 Civil AFFIDAVIT OF GOOD FAITH INVESTIGATION The undersigned is the attorney for the Plaintiff in this action, that he is authorized to make this Affidavit. The undersigned caused to conduct a good faith investigation of the existence of and whereabouts of any surviving heirs of the deceased Defendant mortgagor and real owner, Patricia Sobotor, by inquiring with the CUMBERLAND County Register of Wills whether an Estate was raised by the granting of the Letters Testamentary and/or Letters of Administration. The Register of Wills advised the undersigned that no decedent's Estate was raised of record, and Letters were not granted. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification of authorities. Dated: June l Q. , 2012 UDREN LAW OFFICES, P.C. Zan M. Minato, Esquire Pa. ID 75860 ?` Attorneys for Plaintiff EXHIBIT B 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( udren.com U.S. Bank, N.A. as Trustee for the Registered € COURT OF COMMON PLEAS Holders of Structured Asset Securities € CIVIL DIVISION Corporation Mortgage Pass-Through CUMBERLAND County Certificates, Series 2007-TC 1 Plaintiff V. Michael P. Sobotor Patricia M. Sobotor, Deceased Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right Title or Interest From or Under Patricia M. Sobotor, Deceased Defendant(s) ' NO. 2012-728 Civil CERTIFICATE OF SERVICE I certify that true and correct copies of the Motion For Service Pursuant to Special Order of Court was sent to the following person(s) named herein at their last known address or their attorney of record by: Regular First Class Mail Date Served: June (Z , 2012 TO: Michael P. Sobotor Patricia M. Sobotor 19 Holly Estates Drive 19 Holly Estates Drive Gardners, PA 17324 Gardners, PA 17324 Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right Title or Interest From or Under Patricia M. Sobotor, Deceased 19 Holly Estates Drive Gardners, PA 17324 UDREN LAW OFFICES, P.C. BY: Al inato, Esquire Pa. ID 75860 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION U.S. Bank, N.A. as Trustee for the Registered € Holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC1 Plaintiff V. Michael P. Sobotor Patricia M. Sobotor, Deceased Unknown Heirs, Successors, Assigns and All 1 NO. 2012-728 Civil Persons, Firms or Associations Claiming Right Title or Interest From or Under Patricia 1 M. Sobotor, Deceased Defendant(s) ORDER t ?? AND NOW, this 18 Day of 71) K L , 2012, upon consideration of Plaintiff s Motion For Service Pursuant To Special Order Of Court, and any response thereto, it is hereby ORDERED AND DECREED that Service of the Complaint In Mortgage Foreclosure on Patricia M. Sobotor, Deceased, and Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right Title or Interest From or Under Patricia M. Sobotor, Deceased shall be complete when Plaintiff or its counsel or agent has published in accordance with Pa.R.C.P. 430(b)(1) a Notice of the action once in the local legal publication and once in a newspaper of general circulation within the County; and, pursuant to Pa.R.C.P. 430, service of all subsequent pleadings, including, inter alia, the Notice of Sheriffs Sale that requires personal service, shall be complete when the Sheriff, competent adult, constable, or other appropriate party has posted only, a copy of said subsequent pleadings and/or Notice on the most public part of the property located at: 19 Holly Estates Drive, Gardners, PA 17324, which is the subject matter of this action in mortgage foreclosure. 1W / UdPen 11 AMP* l l ? /0 .5-6- -2 BY THE COURT: UDREN LAW OFFICES, P.C. I` ILED-OFFICrATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTEIC THE PROTMONOTAR t 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 2012 JUL - 5 AM 10: 21 856-669-5400 _ ------C jP ]ER .ANU COUNTY U.S. Bank, N.A. as Trustee for the P Wft? /COMMON PLEAS Registered Holders of Structured Asset CIVIL DIVISION Securities Corporation Mortgage Pass- Cumberland County Through Certificates, Series 2007-TC1 Plaintiff V. MICHAEL P. SOBOTOR; PATRICIA M. SOBOTOR, DECEASED; et al NO. 2012-728 Defendant(s) PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate /the Complaint on the above-captioned matter. DATE: ? /,-)-8 l UDREN LAW OFFICES, P.C. BY: _ Attorneys for Plaintiff KASSIA FIALKOF F, flQUIRg PA ID 310530 ak+ =i?.-7sp aN? CT-14 ?/Yoo? ,e-If,2-ns ,.Q WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 12-728 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due U.S. BANK N. A. AS TRUSTEE, FOR THE REGISTERED HOLDERS OF STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-TCl Plaintiff (s) From UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT TITLE OR INTEREST FROM OR UNDER PATRICIA M. SOBOTOR, DECEASED MICHAEL P. SOBOTOR, PATRICIA M. SOBOTOR, DECEASED (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: $66,106.90 L.L.: $.50 Interest FROM 8/29/2012 TO DATE OF SALE DECEMBER 5, 2012 -ONGOING PER DIEM OF $8.24 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $815.76 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $202.00 Other Costs: Plaintiff Paid: Date: ~ I ~ f adI a ' David D. Buell, Prot notary (Seal) By: Deputy REQUESTING PARTY: Name: }~~IfRy ,Q. IeE~s E ,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. $) ~ SOI UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 U.S. Bank, N.A. as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass- Through Certificates, Series 2007-TCl Plaintiff v. Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right Title or Interest from or Under Patricia M. Sobotor, Deceased Michael P. Sobotor Patricia M. Sobotor, Deceased Defendant(s) ATTORNEY FOR COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE N0.2012-728 PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due Interest From 8/29/2012 to Date of Sale Deceme er 5 2012 Ongoing Per Diem of 8.24 to actual date of sale including if sale is held at a later date (Costs to be added) C~./ ~~, so ~ a Q~~ ~~. ~ ~ (V ..~• ~ 11 u ( ~. (I_ ~ ul1 -- ~•s~-K'r~, 1 G~ D~ /~" MJLT#: 11121056 CASE: 11121056-1 $ 66.106.90 $ 815.76 ~..~ c ~ -: p.. ..,., ,,~ ~, ,, ter- ~o a 3~ c'> ~, ~ - _, .. x- - ~ ~' -,C ~.~_ _., ~~. r..~ ~-, r'~"Y ~ ~ ~,~ "'r1 ~ %L1 -U "Cs f"' f'." ~r '~' ~ E...: ~~ ~ n c ° G? ~-, -i c3 :. -~;: cs, - UDREN LAW OFFICES, P.C. BY: ~~!- V `' Attorney for ainti HARRY B. REESE, ESQUIKC PA ID 310501 ~~. a s l~,e ~. ~-. SD L ~. ~ 3So~ ~. a ~a o ~~ (),)~;~ of ~~'Iss~d r _ _ _ UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 U.S. Bank, N.A. as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass- Through Certificates, Series 2007-TC1 Plaintiff v. Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right Title or Interest from or Under Patricia M. Sobotor, Deceased Michael P. Sobotor Patricia M. Sobotor, Deceased Defendants} ATTORNEY FOR COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE N0.2012-728 w, ~~ ' v .~ 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 [] Premises is not subject to the provisions of Act 91 as this is an FHA insured mortgage This statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. BY:(~ I ~ l i1 i1 i1; ~--~ AttdTb~P "latritlff - HARRY B. REESE, t54,;,~;;. PA ID 3105G1 ~ ~ c~ ~ ;.. --~ ~, ~. UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 U.S. Bank, N.A. as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TCl Plaintiff v. Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right Title or Interest from or Under Patricia M. Sobotor, Deceased Michael P. Sobotor Patricia M. Sobotor, Deceased Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION -- Cumberland County ~- MORTGAGE NO.2012-728 _<~' r~ c.~ v,c z AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 ~' ~, ~ ' `:~' n~ r --+c rv ~' U.S. Bank, N.A. as Trustee for the Registered Holders of Structured Asset Securities Corporatii Mortgage Pass-Through Certificates, Series 2007-TC1, Plaintiff in the above action, by its undersi attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe Writ of Execution was filed, the following information concerning the real property located at: 19 Holly Estates Drive, Gardners, PA 17324 1. Name and address of Owner(s) or reputed Owner(s): Michael P. Sobotor 19 Holly Estates Drive Gardners, PA 17324 Patricia M. Sobotor, Deceased 19 Holly Estates Drive Gardners, PA 17324 2. Name and address of Defendant(s) in the judgment: Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right Interest from or Under Patricia M. Sobotor, Deceased 19 Holly Estates Drive Gardners, PA 17324 Michael P. Sobotor 19 Holly Estates Drive Gardners, PA 17324 Patricia M. Sobotor, Deceased 19 Holly Estates Drive Gardners, PA 17324 3. Name and address of every judgment creditor whose judgment is a record lien on the real property the or be sold: Jr Lien Holders -None 4. Name and address of the last recorded holder of every mortgage of record: w U.S. Bank, N.A. as Trustee for the Registered Holders of Structured Asset Securities Corporation' Mortgage Pass-Through Certificates, Series 2007-TC1 i 1661 Worthington Road #100 West Palm Beach, FL 33409 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 inter st may be affected by the sale: Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Cumberland County Real Estate Tag Department 1 Courthouse Square Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Bog 281230 Harrisburg, PA 17128-1230 Tenants/Occupants 19 Holly Estates Drive Gardners, PA 17324 7. Name and address of every other person of whom the plaintiffhas knowledge who has any interest ' the property which maybe affected by the sale: Federal Tag 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 informa on and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 49 4 relating to unsworn falsification to authorities. .~ DATED: ~ MJU#: 11121056 CASE#: 11121056-1 UDREN LAW OFFICES, P.C. B A o B QUI E PA ID 310501 ti UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 U.S. Bank, N.A. as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass- Through Certificates, Series 2007-TC1 Plaintiff v. ATTORNEY FOR ;~ c COURT OF COMMON PLEAS CIVIL DIVISION ."'~v Cumberland County~,~~ vn MORTGAGE FORECLOSURE y. ~t. PATRICIA M. SOBOTOR, DECEASED, MICHAEL P. SOBOTOR UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT TITLE OR INTEREST FROM OR UNDER PATRICIA M. SOBOTOR, DECEASED Defendant(s) N0.2012-728 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Patricia M. Sobotor, Deceased 19 Holly Estates Drive Gardners, PA 17324 zr... ~.;.q N ~ «.e. ~~~µ -~r~. X.J --r ~:> ~.~, ~ -~-, - c~ <.~. .c ~" ru Your house (real estate) at 19 Holly Estates Drive, Gardners, PA 17324 is scheduled to be at the Sheriffs Sale on December 5, 2012 at 10:00am at the Cumberland County Courthc Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judge of $66.106.90, obtained by Plaintiff above (the mortgagee) against you. If the sale is postpo: 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: 3. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and 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.) _._ _ _ _ __ ~_ - _- ti 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 fins 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 fm 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 tt Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You maybe entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedi 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 rUDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 U.S. Bank, N.A. as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass- Through Certificates, Series 2007-TC1 1661 Worthington Road #100 West Palm Beach, FL 33409 Plaintiff v. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FHtMS OR ASSOCIATIONS CLAIMING RIGHT TITLE OR INTEREST FROM OR UNDER PATRICIA M. SOBOTOR, DECEASED 19 HOLLY ESTATES DRIVE GARDNERS, PA 17324 MICHAEL P. SOBOTOR 19 HOLLY ESTATES DRIVE GARDNERS, PA 17324 PATRICIA M. SOBOTOR, DECEASED 19 HOLLY ESTATES DRIVE GARDNERS, PA 17324 Defendant(s) ATTORNEY FOR PLAINTIFF ~-, ~.~ ~~' COURT OF COMMON PLEA, 'rn c~_-. CIVIL DIVISION ~ _~-- Cumberland County ~ ~ MORTGAGE FORECLOSURE~c~ ~, .. N0.2012-728 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: ~ ~.~ -,t _" - -~,: ~~_ ~' c-~ . -~ ~.a ~ -~. E~1"~~ :;~ ~., ~~~ :~, ~~ ~: `~ r-a ~ 'x +'g ..''+. I"...7 ~"~ 7 -^~ r~~ ~ ~ ~ ~' -~ --+ -=~- ~') ~,~ R CJ i :} ~~~ " .~ { -~ ~ ~-, +. Y ~a .. Kindly enter judgment in favor of the Plaintiff and against the Defendant(s), MICHAEL P. SOBOTOR; PATRICIA M. SOBOTOR, DECEASED; 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 fee Property Inspection Property Valuation Grand Total FROM TO $59,915.69 $1,232.78 12/29/2011 08/28/2012 $2,010.56 $276.54 12/29/2011 08/28/2012 $368.72 $389.61 $300.00 $1,300.00 $21.00 $292.00 $66,106.90 ~`~ . s~ a~ a~.+ ~,~as~~ ~ (V ofi~e f 1~~~ ,, I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. UD DT LA OFFICES, P.C. B RRY B. REESE, ESQUIRE A rn PA ID 31Q5~J1 DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE: PRO O ~ MJU#: 11121056 CASE#: 11121056-1 FiLEt3-aFFiCE ~ t~F THE PR•OTNGNOTAR , 2~l2fEB -Z !~M i~l~ 0~ Gt! ~gN~5YLYANiATY UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. [TOKEN, ESQUIRE - ID #84302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MIlVATO, ESQUIRE - ID #75860 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 PAIGE M. BELLING, ESQUIRE - ID#309091 HARRY B. REESE, ESQUIRE - ID#310501 AMY GLASS, ESQUIRE - IDIf388367 KASSIA FiALKOFF, ESQUIRE - IIR#310530 DONNA L. SKQ.TON, ESQUIRE - ID#206551 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 wOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,'NJ 08003-3620 856-669-5400 pk~d~sar?a.udrea.cam U.S. Bank, N.A. as Traatee for the Registered Holders ~ COURT OF COMMON PLEAS of Struetured Asset Securities Carporatian Mortgage ; CIVII. DIVISJON Pass-T'hrongh CerHHcites, Series 2007 TCl CUMBERi,A,ND County CIO Ocwen Lose Servicing, LLC 1661 Word~ington Road #100 We t P l B FL h ~1. ` ~ ~ ~' ~ s a m eac , 33409 ~-RI 1 i " o NO. ~ 0 l p ~ Plaintiff v, UNKNOWN HEIItS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRbfS OR ASSOCIATIONS CLAIMING RIGHT TITLE OR INTEREST FROM OR UNDER PATRICIA M. SOBOTOR, DECEASED I9 HOLLY ESTATES DRIVE GARDNERS, PA 17324 MICHAEL P. SOBOTOR 19 HOLLY ESTATES DRIVE GARDNERS, PA 17324 PATRICIA M. SOBOTOR, DECEASED 19 HOLLY ESTATES DRIVE GARDNERS, PA 17324 Defendants} COMPLAINT IN MORTGAGE FORECLOSURE O~~t ~ i057spd a~ al3tY ~a~en/~ IN THE COURT OF' COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION U.S. Bank, N.A. as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TCl .,-, <~ Plaintiff -~~ ~--, ~.~ .1 dim ~J ~~ V. ',r,r., .r .%""" Michael P. Sobotor °= ==~ ~ , .t~'' ~ 5 Patricia M. Sobotor, Deceased -- ~...: `T' ~`"~' =' Unknown Heirs, Successors, Assigns and All N0.2012-728 Civil Persons, Firms or Associations Claiming Right Title or Interest From or Under Patricia M. Sobotor, Deceased Defendant(s) ~~ t _ ....1... "' i~t ~_ 4JL ~~~ ~'"^r e -~ ~.w, ORDER AND NOW, this ~ $ Day of , 2012, upon consideration of Plaintiff's Motion Far Service Pursuant To Special Order Of Court, and any response thereto, it is hereby ORDERED AND DECREED that Service of the Complaint In Mortgage Foreclosure on Patricia M. Sobotor, Deceased, and T.Unknown Heirs, Successors, Assigns and AlI Persons, Firms or Associations Claiming Right Title or Interest From or Under Patricia M. Sobotor, Deceased shall be complete when Plaintiff or its counsel or agent has published in accordance with Pa.R.C.P. 430(b)(1} a Notice of the action once in the local Legal publication and once in a newspaper of general circulation within the County; and, pursuant to Pa.R.C.P. 430, service of all subsequent pleadings, including, inter olio, the Notice of Sheriff's Sale that requires personal service, shall be complete when the Sheriff, competent adult; constable, or other appropriate party has posted only, a copy of said subsequent pleadings and/or Notice on the most public part of the property located at: 19 Holly Estates Drive, Gardners, PA 17324, which is the subject matter of this action in mortgage foreclosure. BY THE COURT: SHERIFF`S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~ ~ ~~rr Jody S Smith Chief De u ~``4 ~"~` ~ ~,-, ~ p ty , .. .. ,~-; ~: Richard W Stewart ""`'= "~='~°~~ Solicitor ~~+c~ of ~E s~n=~F~ US Bank NA Case Number vs. 2012-728 Michael P. Sobotor SHERIFF'S RETURN OF SERVICE 02/13/2012 03:10 PM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on February 13, 2012 at 1510 hours, she served a true copy of the within Complaint in Mortgage Foreclosure upon the within named defendant, to wit: Michael P. Sobotor, by making known unto himself personally, at The Cumberland County Sheriff's Office, 1 Courthouse Square, Room 303, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. ~~~' ~ AMA DA COBAUGH, DEPUTY SHERIFF COST: $39.00 SO ANSWERS, ~~~""~-~ February 14, 2012 RON R ANDERSON, SHERIFF icj COunh~SuiiS SherNf. 7eleoscfl; try. UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 U.S. Bank, N.A. as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass- Through Certificates, Series 2007-TCl Plaintiff v. PATRICIA M. SOBOTOR, DECEASED, MICHAEL P. SOBOTOR UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT TITLE OR INTEREST FROM OR UNDER PATRICIA M. SOBOTOR, DECEASED Defendant{s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE N0.2012-728 TO: PATRICIA M. SOBOTOR, DECEASED 19 HOLLY ESTATES DRIVE GARDNERS, PA 17324 Date of Notice: August 17, 2012 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 HIl21NG 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 HABER TOMADO LA ACCION REQUIltIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMING DE DIEZ (10) DIAS DE ESTA NOTiFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPAR.ARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, LISTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICiNA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL Cumberland County 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. BY: ~~ f PI ntiff HARRY B. REESE, ESQUIRE Woodcrest Corporate Center 1 I 1 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 MJU#: 11121056 CASE#: 11121056-1 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY IIII.L, NJ 08003-3620 856-669-5400 U.S. Bank, N.A. as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass- Through Certificates, Series 2007-TCl Plaintiff v. PATRICIA M. SOBOTOR, DECEASED, MICHAEL P. SOBOTOR UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT TITLE OR INTEREST FROM OR UNDER PATR.ICIA M. SOBOTOR, DECEASED Defendants} TO: MICHAEL P. SOBOTOR 19 HOLLY ESTATES DRIVE GARDNERS, PA 17324 Date of Notice: August 17, 2012 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE N0.2012-728 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 MAYBE 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 USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIltIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMING DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPAR.ARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA. EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IlviPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIA.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, CUYA DIRECCION SE ENCUENTRA ESCRTTA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIIt ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL Cumberland Connty 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 THI5 IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. UDREN LAW OFFICES, PC. r BY: t f P ff HARRY B. REESE, ESQUIRE Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 MJU#: 11121056 CASE#: 11121056-1 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY BILL, NJ 08003-3620 856-669-5400 U.S. Sank, N.A. as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass- Through Certificates, Series 2007-TC1 Plaintiff v. PATRICIA M. SOBOTOR, DECEASED, MICHAEL P. SOBOTOR UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT TITLE OR INTEREST FROM OR UNDER PATRICIA M. SOBOTOR, DECEASED Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE N0.2012-728 TO: UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT TITLE OR INTEREST FROM OR UNDER PATRICIA M. SOSOTOR DECEASED. 19 HOLLY ESTATES DRIVE GARDNERS, PA 17324 Date of Notice: August 14, 2012 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 USTED SE ENCUENTRA EN ESTADO DE REBELDIA PORNO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMING DE DIEZ (10) DIA.S DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL Cumberland County 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`. ,\ 1 BY: ~ Att rney or Plaintiff HARRY B. REESf, ESQUIRE Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 MJU#: 11121056 CASE#: 11121056-1 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 U.S. Bank, N.A. as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TCl Plaintiff v. Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right Title or Interest from or Under Patricia M. Sobotor, Deceased Michael P. Sobotor Patricia M. Sobotor, Deceased Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE N0.2012-728 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. SOBOTOR, PATRICIA M. SOBOTOR, DECEASED, 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 Ezhibit "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. ~ , --- Att rn 1 ' '€f~-~ RRY B. REEF, ~c,~~ PA Tn MJU#: 11121056 CASE#: 11121056-1 Department of Defense Manpower Data Center PU3"SU~11~ #~ ~Ci'R-CCfY1C[!1 IVIl ~.C~!Cf 1~t Last Name: SOBOTOR First Name: MICHAEL Middle Name: Active Duty Status As Of: Auq-28-2012 Results as of :Aug-26-2012 t 1:45:54 SCRA 2.3 or, Acthre.'t>,rty on AcC+e Duly stews Date Atlive Duty Start Dare Adivn Duty End Dale Status Service Comparent NA NA No NA This response reflacta the hMividueis' actlve duy slaws based on fire Actlve Duty Status Date Lett AdNe Duty YVMd41387 Days d AdYVe Duty 3femu:Data Adhe Duly Start Date Active Duty End Date 9fr~us - ServtaeCamporrent NA NA No - NA This response reflects Wtlere the individual IeR active dutyetatue within 367 days pnacedhg the Active Duty Status Date TheMember or HieMx Lhdt Wes Nottked of a Fuluro CaµLp tp AdN6Duty on Aothre Duty Status DaM Order Noffiflca8on StartOa~ Order NoBraatlon End Date ~Nus Sorvice'Cort~onent NA NA No NA This response reflects whether Cre kdividud a hieTher unit has received early notificatiorr to report for alive duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or hislher unit receiving notification of future orders to report for Active Duty. ~~ ~,-~-. Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) 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 Servicemembers 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 only 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 was on active duty for the active duty status date, 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:llwww.defenselink.miVfaq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date 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). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or hislher unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1 ). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense 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 Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (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). 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. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of alive 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 eMend 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 noY actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could 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 last name, SSNldate of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 75JP881AMB Department of Defense Manpower Data Center a7~iM.1 ~~~. Puur~s.~eat to S~cen~mb~rs ivyl ~telef t~.ct Last Name: SOBOTOR First Name: PATRICIA Middle Name: Active Duty Status As Of: Aug-28-2012 Results as of :Aug-2&2012 11:45:21 SCRA 2.3 On Ac4ve ~' fln Actlve Griy 31awe Date gctlya Duty.Slart Date Atdlve.Dury End Date Status SeMce'Crnspor>tnt NA NA Ho NA This response reflects the individuals' alive awry sows baaed on the Actlve ~ stews Dace Lett Amve Duty Within 367 Days of Actlve Duty Stows Date Actlve Duty Start ~b Active Duty End Gate Statue 9ervkx.Crxrt{wnsnt NA NA No NA This response reflects wharathe individual left active duty status widtfn 367 days preceding the Active Duly Stews Date The KAetabar or HiaJFler l)ntl Wes Nottflad or a Future Cak-Up to Active Duly on AcINe Dury Stekrs Date rJrder-Jatlfl~atbaStaRDaos `CkderNoflflotion End Date Status ServkeCompenenT NA NA No NA This response reflects whether fire hdividuei a his/her unit has received eerty notlfica4gr to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Canter, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) 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 Servicemembers 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 only 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 was on active duty for the active duty status date, 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 was on active duty for the active duty status date 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). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency deGared 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 Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (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). 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. SCRA protections are for Title 10 and Titre 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). 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 osiers 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 the SCRA extend beyond the last dates of active duty. Those who could 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 last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: CVT2CLSDVK UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 U.S. Bank, N.A. as Trustee for the COURT OF COMMON PLEAS ,..~; Registered Holders of Structured Asset I CIVIL DIVISION ~ `~~ Securities Corporation Mortgage Pass- Cumberland County ~ .,~~ ~ "~ Through Certificates, Series 2007-TC1 ~~ as r~",., -v ~-=~' -c~ ~ Plaintiff NO. 2012-728 ~ rte, . ~ ~-., c ~'` --t s -~-: MICHAEL P. SOBOTOR• =° x' ~ n`~'' PATRICIA M. SOBOTOR, DECEASED; ? ~- :~ et al -~ , ~ -' Defendant(s) PRAECIPE TO FILE PROOF OF PUBLICATION TO THE PROTHONOTARY: Kindly file the attached Proofs of Publication with regard to the captioned matter. Date: ~ 3 ~ ~ ~ ~~ ~~~ ~ W OFFICES, P.C. for AGNES MOMBRUN, ESQUIRE PA ID 3093 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland ackie Ccl~ Sales Director, of The Sentinel, of the County and State aforesaid, being duly s~~~orn, deposes and says that THE SENTINEL, a newspaper of general circulatiE:m in the Boroilgh of Carlisle, County and State aforesaid, was established December 1:3t1i, 188"l, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed. and published in the regular editions and issues of THE SENTINEL on the following day(s): Lul~l8 __012 COPY OF NOTICE OF PUBLICATION IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW N0.20S2-728 Civi{ pOSE'S that 11e~ She LS 110t NOTICE OF ACTION IN MORTGAGE FORECLOSURE U.S. Bank, N.A., as 7rusiee for the Registered Holders of Structured Asset Securities Corporation Mortgage Ub1eCt matteI' Of t1Ae Pass-Through Certificates, Series 2007-TC1, c/o Ocwen Loan Servicing, LLC, Plaintiff vs. Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right TNie or Interest From or-Under Pairtcia r adVertlsemen f;, and that M. Sobotor, Deceased, Michael P. Sobotor and Patricia M. Sobotor, Deceased, Defendar><s To: Patricia M. Sobotor, Deceased, and Any and All Unknown Heirs, Successors, Assigns and AU Persons; Finwe or he fOYegOing Statement as Associations Claiming Right, Title, or Interest from or Under Patricia M. Sobotor, Deceased, Defendant(s), whose last known address is 19 Holly Estates Drive, Gardners, PA 17324. ChaYaCteY Of pllhllcdtlOn COMPLAINT ~ MORTGAGE. ~QRECLOSURE You are hereby notified that Plaintiff, U.S. Bank, N,A., as Trustee for the Registered Holr~rs of Stuuctured Asset ~ Securities Corporation Mdrtgage Pass-Through Certificates, Series 2007-TC1, c/o Ot;vren Loan 5ervicMg,tL6, has " 1 _ A` " ` " fled a Mortgage Foreclosure Complaintendorsedwith aNotice to Defend, against you inthe Court of Common Pleas of Cumberland County, Pennsylv~rtia, docketed to N0.2012-728 Civil, wherein Plaintiff seeks to foreclose on the ~ ~ ~,/ ,- / ," 19 Holly Estates Drive Gardners mortgage secured on your property located PA 17324 whereupon your property ~'~- ~ -~, t (. '~'` `•-- , , , , would be sold by the Sheriff of Cumberland County. -''-'~ - _ ~ _ -`- TIC YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth inane notice above, you must take action within twenty (20) days attar this Complaint and Notice era served, by ~nte~ a WrtittMl_a~9Ara,JUU7e personally or by attomeyand fiflng ih writing with the Court your defenses or objectionstp #i1e clairAa s~ttfrtii $~ainst you: You are warned that ff you faN to do so the case may proceed without you and a judgment may tai entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim O<relief , requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TARE _ THIS RAPER TOYOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHOt~iE THE OFFICE SET'FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH THE INFORMATION ABOUT.HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLtx TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO EL1Git3LE PERSONS.AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Assoc. 2 Liberty Ave., Carlisle, PA 17013 800-x.90.9108 Mark J. Udren, Stuart Winneg, Lorraine Doyle, Alan M. Mhato, Sherri J. Braunstein, Paige Iirt:Beltino, Harry 8. Reese, Amy Glass, Kassia Fialkoff, Donna L. Skillton 8, ElizabetY L. Wassail, Attys. for Plaintiff Udren Law Offices, P.C., 111 Woodcrest Rd., Suite 200 Cfierry Hill, NJ 08003 856-669-5400 My commission expires: .~. G~ t~ _. ,. ;. ... , ~ v , ~ ~~,) ;i'1't ~ GAH ~ ~ ~ v~ il~, ,, r': .:. ... ,. ., Notary Ptlhht a PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. 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 an the following dates, v;~ IIOTJ<C>c ~_~~ ~ ~ to NO.2012-728 civil, wherein Plain- 1[OIRT(}}At1>E 1!"QQ1tE -tiff seeks to foreclose on the mortgage secured on your property In the Court of Common Pleas of -19 Holly Estates Drive, Gardners, PA 17324, whereupon your property Cumberland County, Pennsylvania -would be sold by the Sheriff of Cum- Civil Action-Law - berland County. NO. 2012-728 Civil NOTICE LAWYERS REFERRAL SERVICE Cumberland County Bar Assoc. 32 S. Bedford St. Cazlisle, PA 17013 (800) 990-9108 MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE U.S. Bank, N.A., as Trustee for the 2 YOU HAVE BEEN SUED IN t0 Verlfy th1S Statement by the LORRAINE DOYLE, ESQUIRE Registered Holders of Structured COURT. if you wish to defend against n and that he is not interested ALAN M• MINATO, ESQUIRE Asset Securities Corporation the claims set forth in the notice ~ SHERRI J. BRAUNSTEIN, Mortgage Pass-Through lj above, you must take action within that all allegations in the forel ESQUIRE Certificates, Series 2007-TC1, c/o ~,~~, (20) days after this Complaint PAIGE M. BELLING, ESQUIRE Ocwen Loan Servicing, LLC, C and Notice are served, by entering a ltlOn are true. H~gy B, REESE, ESQUIRE ~~~ 'tten a eazance personally or by AMY GLASS vs. Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Patricia M. Sobotor, Deceased, Michael P. Sobotor and Patricia M. Sobotor, Deceased, Defendants COMPLAINT IN MORTGAGE FORECLOSURE To: Patricia M. Sobotor, Deceased, and Any and All Unlmown Heirs, Successors, Assigns, and All Persons, Firms or Associations Claiming Right, Title, or Interest fi om or Under Patricia M. Sobotor, Deceased, Defendant(s), whose last known address is 19 Holly Es- tates Drive, Gazdners, PA 17324. You are hereby notified that Plaintiff, U.S. Bank, N.A., as Trustee for the Registered Holders of Struc- tured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC1, c/o Ocwen Loan Servicing, LLC, has filed a Mortgage Foreclosure Complaint endorsed with a Notice to Defend, against you in the Court of Common Pleas of Cumber- wrl PP attorney and filing in writing v~th the ,ESQUIRE KASSIA FIALKOFF, ESQUIRE Court your defenses or objections to DONNA L. SKILLTON, ESQUIRE the claims set forth against you. You ELIZABETH L. WASSALL aze warned that if you fail to do so the ~ , ESQUIRE /G case may proceed without you and ~ UDREN LAW OFFICES, P.C. '^'_ a judgment may be entered against Attorneys for Plaintiff you by the Court without further di 111 Woodcrest Rd. tor notice for any money claimed in the isa Marie Coyne, Ste. 200 Complaint or for any other claim Cherry Hill, NJ 08003 or relief requested by the Plaintiff. N TO AND SUBSCRIBED b (856) 669-5400 You may lose money or property or other rights important to you. YOU ~f Jul. July 27 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 THE INFORMA- TION ABOUT HIRING A LAWYER. Notary IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES NOTARIAL SEAL THAT MAY OFFER LEGAL SERVICES DEBORAH A COLLINS TO ELIGIBLE PERSONS AT A RE- Notary Public DUCED FEE OR NO FEE. CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 " (610)254-9980 Fax: (610)254-9982 Email: orders@mansfieldads.com Udren Law Offices, P.C. Attn: Courtney Myers Woodcrest Corporate Center 1 I 1 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 WJM William J. Mansfield, Inc. Legal Advertising Suite 1209 998 Old Eagle School Road ~~'a3'ne, PIS 19087-1805 Your choice fot legal adver[ising Since 1935 In Re: Mortgage Foreclosure U.S. BANK vs. SOBOTOR (NO. 2012-728) (MJU#11121056-1) Service Charge: 20.00 Publications: The Carlisle Sentinel; Carlisle, PA 17013 311.40 Published: 7/18/2012 Cumberland Law Journal; Carlisle, PA 17013 329.00 Published: 7/27/2012 Total Due: $660.40 INVOICE PAYMENT NOT CONTINGENT ON CLIENT REIMBURSEMENT. AI.L INVOICES ARE NET 30 DAYS UDRENN Invoice#:2012070080 Date: 7/30/2012 Note: Customer copy This copy is for your records. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson Sheriff soxu ofiimrr :4 i t Jody S Smith d.° 1013 APR _ t �. Chief Deputy 20 Richard w Stewart PENNSYLVANIA CUMBERLAt@ Y � Solicitor F)M�T"E sKR(RF US Bank NA Case Number vs. 2012-728 Patricia M Sobotor-Deceased (et al.) SHERIFF'S RETURN OF SERVICE 09/27/2012 07:25 PM-Deputy Ryan Burgett, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 19 Holly Estates Drive, Dickinson Township, Gardners, PA 17324, Cumberland County. 09/27/2012 07:25 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 MICHAEL SOBOTOR-HUSBAND,who accepted as"Adult Person in Charge"for Patricia M Sobotor-Deceased at 19 Holly Estates Drive, Dickinson Township, Gardners, PA 17324, Cumberland County. 09/27/2012 07:25 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 Sobotor at 19 Holly Estates Drive, Dickinson Twp., Gardners, PA 17324, Cumberland County. 11/28/2012 As directed by Harry B. Reese,Attorney for the Plaintiff, Sheriffs Sale Continued to 2/6/2013 02/04/2013 As directed by Harry B. Reese,Attorney for the Plaintiff, Sheriffs Sale Continued to 4/3/2013 03/28/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned"stayed", per letter of instruction from Attorney. SHERIFF COST: $1,297.25 SO ANSWERS, (;" ���X�--..,_„ April 01, 2013 RbN01 R ANDERSON, SHERIFF (c)CountySuite Sheriff,7eleosoft,Inc. UDREN LAW QFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 leadio s udren.com U.S.Bank,N.A. as Trustee for the Registered Holders COURT OF COMMON PLEAS of Structured Asset Securities Corporation Mortgage CIVIL DIVISION Pass-Through Certificates,Series 2007-TCI Cumberland County Plaintiff V. MORTGAGE FORECLOSURE Unknown Heirs,Successors,Assigns and All Persons, Firms or Associations Claiming Right Title or Interest from or Under Patricia M.Sobotor,Deceased NO. 2012-728 Michael P. Sobotor Patricia M. Sobotor,Deceased Defendants) AFFIDAVIT PANT 10 RULE 3129.1 AND RULE 76 U.S. Bank,N.A.as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC1,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: 19 Holly Estates Drive, Gardners,PA 17324 1.Name and address of Owner(s)or reputed Owner(s): Michael P. Sobotor 19 Holly Estates Drive Gardners,PA 17324 Patricia M.Sobotor,Deceased 19 Holly Estates Drive Gardners,PA 17324 2. Name and address of Defendant(s)in the judgment: Unknown Heirs,Successors,Assigns and All Persons,Firms or Associations Claiming Right Title or Interest from or Under Patricia M. Sobotor,Deceased 19 Holly Estates Drive Gardners, PA 17324 Michael P. Sobotor 19 Holly Estates Drive Gardners, PA 17324 Patricia M.Sobotor,Deceased 19 Holly Estates Drive Gardners, PA 17324 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 r 4.Name and address of the last recorded holder of every mortgage of record: U.S.Bank,N.A.as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates,Series 2047-TC1 1661 Worthington Road#100 West Palm Beach,FL 33409 Sr Mortgage Holders-None Jr Mortgage Holders-None S.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 Domestic Relations Section 13 North Hanover Street Carlisle,PA 17013 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle,PA 17013 Commonwealth of PA,Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg,PA 17128-1230 Tenants/Occupants 19 Holly Estates Drive Gardners, PA 17324 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. i DATED: LAW OFFICES, P.C. B A B .,�Qut MJU#: 11121056 CASE#: 11121056-1 PA ID 310501 4 ' UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 09003-3620 956-669-5400 U.S.Bank,N.A. as Trustee for the COURT OF COMMON PLEAS Registered Holders of Structured Asset CIVIL DIVISION Securities Corporation Mortgage Pass- Cumberland County Through Certificates,Series 2007-TC1 Plaintiff MORTGAGE FORECLOSURE V. PATRICIA M.SOBOTOR,DECEASED, NO. 2012-728 MICHAEL P.SOBOTOR UNKNOWN HEIRS,SUCCESSORS,ASSIGNS AND ALL PERSONS,FIRMS OR ASSOCIATIONS CLAIMING RIGHT TITLE OR INTEREST FROM OR UNDER PATR14CIA M. SOBOTOR, DECEASED Defendant(s) NOTICE OF SHERI'FF'S SALE OF REAL PROPERTY TO: Michael P. Sobotor 19 Holly Estates Drive Gardners, PA 17324 Your house(real estate) at 19 Holly Estates Drive,Gardners,PA 17324 is scheduled to be sold at the Sheriffs Sale on December 5,2012 at 10:00am at the Cumberland County Courthouse, Commissioners Hearing Room,2nd Floor,Carlisle,PA 17013,to enforce the court judgment of$_ 106.90_,obtained by Plaintiff above(the mortgagee)against you. If the We 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 sction: 1. The sale will be cancelled if you pay to the mortgagee the back payment,late charges,costs and reasonable attorney's fees. To find out how much you must pay,you may call:(856,)669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) TO SAVE XQURLRQLUnAM yQU HAyE O HER GH' EVEN IF SIRRIFF'S SALE DDS TAKE PLACE d. 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 Asoeiation 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. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 p4eadinss0 g&M—com U.S.Bank,N.A. as Trustee for the ( COURT OF COMMON PLEAS Registered Holders of Structured Asset CIVIL DIVISION Securities Corporation Mortgage Pass- Cumberland County Through Certificates,Series 2007-TC1 Plaintiff MORTGAGE FORECLOSURE V. PATRICIA M.SOBOTOR,DECEASED, NO. 2012-728 MICHAEL P.SOBOTOR UNKNOWN HEIRS,SUCCESSORS,ASSIGNS AND ALL PERSONS,FIRMS OR ASSOCIATIONS CLAIMING RIGHT TITLE OR INTEREST FROM OR UNDER PATRICIA M. SOBOTOR, DECEASED Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Unknown Heirs,Successors,Assigns and All Persons,Firms or Associations Claiming Right Title or Interest from or Under Patricia M.Sobotor,Deceased 19 Holly Estates Drive Gardners,PA 17324 Your house(real estate) at 19 Holly Estates Drive,Gardners,PA 17324 is scheduled to be sold at the Sheriffs Sale on December 5,2012 at 10:00am at the Cumberland County Courthouse,Commissioners Hearing Roomy 2nd Floor,Carlisle,PA 17013,to enforce the court judgment of$„ ft,",obtained by Plaintiff above(the mortgagee) against you. If the sale is postponed,the property will be relisted for the Next Available Sale. Ng_M OF OWNER'S " YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale,you must take immedhtte action: 1. The We 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)669-5.400. 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. I 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 Ma ST"ARE„ARE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHE + '"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 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 PIECE OR PARCEL OF LAND, SITUATE, LYING AND BEING IN DICKINSON TOWNSHIP,CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED IN ACCORDANCE WITH A CERTAIN FINAL SUBDIVISION PLAN FOR HOLLY ESTATES PREPARED BY THOMAS AND ASSOCIATES, SURVEYORS, DATED NOVEMBER 29, 1977, CONSISTING OF 1 PAGE,A COPY OF WHICH IS RECORDED IN CUMBERLAND COUNTY PLAN BOOK 33, PAGE 136 ON SEPTEMBER 20, 1978, AND INCORPORATED HEREIN BY REFERENCE AS FOLLOWS; BEGINNING AT A POINT ON THE WESTWARDLY LINE OF HOLLY ESTATES DRIVE(rO FEET WIDE RIGHT OF WAY)AT THE SOUTHEAST CORNER OF LOT NO. 10 ON A CERTAIN SUBDIVISION FOR RICHARD B.ANDERSON RECORDED IN PLAN BOOK 28, PAGE 135;THENCE BY THE ESTWARDLY LINE OF THE SAID HOLLY ESTATE DRIVE, SOUTH 17 DEGREES 29 MINUTES 28 SECONDS WEST 150 FEET TO A POINT BEING THE NORTHEAST CORNER OF LOT NO.8 ON PLAN OF HOLLY ESTATES;THENCE BY LOT NO. 8 NORTH 72 DEGREES 30 MINUTES 32 SECONDS WEST 299.14 FEET TO A POINT ON LINE OF LANDS NOW OR FORMERLY OF JOHN DELP; THENCE BY LANDS OF DELP,NORTH 17 DEGREES 10 MINUTES 56 SECONDS EAST 149.15 FEET TO A POINT BEING THE SOUTHWEST CORNER OF LOT NO, 9 ON SUBDIVISION FOR RICHARD E.ANDERSON; THENCE BY LOT NO.9 AND LOT NO. 10 ON SUBDIVISION FOR RICHARD E.ANDEI'#SON, SOUTH 72 DEGREES 40 MINUTES 32 SECONDS EAST 299.94 FEET TO A POINT,THE PLACE OF BEGINNING.CONTAINING 1.0256 ACRES, MORE OR LESS. BEING ALL OF LOT NO.7 ON PLAN OF HOLLY ESTATES, AND KNOWN AND NUMBERED AS 19 HOLLY ESTATES DRIVE, GARDNERS, PA 17324. BEING KNOWN AS: 19 HOLLY ESTATES DRIVE,GARDNERS,PA 17324 PROPERTY ID NO.: 08-16-0210-094 TITLE TO SAID PREMISES IS VESTED IN PATRICIA M.SOBOTOR AND,MICHAEL P. SOBOTOR,HUSBAND AND WIFE BY DEED FROM PATRICIA M.KNUDSON,NOW BY MARRIAGE KNOWN AS PATRICIA M SOBOTOR DATED 09/08/199 RECORDED 09/14/1999 IN DEED BOOK 207 PAGE 735. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 12-728 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due U.S.BANK N.A. AS TRUSTEE,FOR THE REGISTERED HOLDERS OF STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE PASS-THROUGH CERTIFICATES,SERIES 2007-TC1 Plaintiff(s) From UNKNOWN HEIRS,SUCCESSORS,ASSIGNS AND ALL PERSONS,FIRMS OR ASSOCIATIONS CLAIMING RIGHT TITLE OR INTEREST FROM OR UNDER PATRICIA M. SOBOTOR,DECEASED MICHAEL P.SOBOTOR,PATRICIA M.SOBOTOR,DECEASED (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: $66,106.90 L.L.: $.50 Interest FROM 8/29/2012 TO DATE OF SALE DECEMBER 5,2012-ONGOING PER DIEM OF $8.24 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE- $815.76 Atty's Comm: % Due Prothy:$2.25 Atty Paid: $202.00 Other Costs: Plaintiff Paid: Date: ql qj g2o1a David D. 11,Proth otary (Seal) By: Deputy REQUESTING PARTY: Name: g,4ARY 6- 4Gf E.s, ESQUIRE Address: UDREN LAW OFFICES,P.C. WOODCREST CORPORATE CENTER, 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 Attorney for:PLAINTIFF TRUE COPY FROM RECORD In TeftWW r whws4 l hW Wft Nt my hand MW ZM yW of� e On Sopter", bw 5129K 2-th 04 4 lop cef t a Dick P. } r� l fu Exim _ this referemwe in Date: Septomr Wr 5, M2 y►. Cl r .r T -1 - 63; zlot f i CUMBERLAND LAW JOURNAL Writ No. 9019-798 Civil Tartu Containing 1.0256 acres, more or less. US BANK NA BEING all of Lot No.7 on plan VS. of Holly Estates, and known and PATRICIA M SOBOTOR- numbered as 19 Holly Estates Drive, DECEASED,Unknown Heirs, Gardners,PA 17324. Successors,Assigns and All BEING KNOWN AS: 19 Holly Persons,Firms or Associations Estates Drive,Gardners,PA 17324. Claiming Right Title or Interest PPrropet �o.: PREMISES S From or Under Patricia M. Sobotor, TITLE 1 T Michael P Sobotor VESTED IN Patricia M.Sobotor and Atty.:Mark J.Udren Michael P.Sobotor,husband and wife by deed from Patricia M.Knudson, ALL THAT CERTAIN piece or par- cel of lend, situate, lying and being now by marriage known 9/0 as Patricia re- in Dickinson Township,Cumberland M corded dated 09in Deed Book County, Pennsylvania, bounded corded in Deed Book and described in accordance with 207 Page 735. a certain final subdivision plan for Holly Estates prepared by Thomas and Associates, Surveyors, dated Ngvember29, 1977, consistingof i page,a copy of which is recorded in Cumberland County Plan Book 33, Page 136 on September 20, 1978, and incorporated herein by reference as follows; BEGINNING at a point on the westwardly line of Holly Estates Drive (50 feet wide right of way) at the southeast corner of Lot No. 10 on a certain subdivision for Richard B. Anderson recorded in Plan Book 28, Page 135; Thence by the estwardly line of the said Holly Estate Drive, South 17 degrees 29 minutes 28 sec- onds West 150 feet to a point being the northeast canner of Lot No.8 on plan of Holly Estates;thence by Lot No.8 North 72 degrees 30 minutes 32 seconds West 299.14 feet to a point on line of lands now or formerly of John Delp;thence by lands of Delp, North 17 degrees 10 minutes 56 sec- onds East 149.15 feet to a point being the southwest corner of Lot No,9 on subdivision for Richard E.Anderson; thence by Lot No.9 and Lot No. 10 on subdivision for Richard E.Anderson, South 72 degrees 40 minutes 32 seconds East 299.94 feet to a point, the place of BEGINNING. 87 s 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 ofocial 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: October 26, November 2 and November 9, 2012 Affiiant 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 Marie Co e,Editor SWORN TO AND SUBSCRIBED before me this 9 day of November. 2012 1 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH.CUMBERLAND COUNTY My Commission Expires Apr 28,2414 2012.728 Civil Term US BANK NA vs. / PATRICIA M SOBOTOR-" DECEASED,Unknown Heirs, Successors,Assigns and All Persons,Firms or Associations Claiming Right Title or Interest From or Under Patricia M.Sobotor Michael P Sobotor Atty: Mark J Udren ALL THAT CERTAIN PIECE OR PARCEL OF LAND,SITUATE, LYING AND BEING IN DICKINSON TOWNSHIP,CUMBERLAND COUNTY, PENNSYLVANIA,BOUNDED AND DESCRIBED IN ACCORDANCE WITH A CERTAIN FINAL SUBDIVISION PLAN FOR HOLLY ESTATES PREPARED BY THOMAS AND ,ASSOCIATES,SURVEYORS,DATED, NQVEMBER29,1977,CONSISTIN, OF I PAGE,A COPY OF WHICH IS RECORDED IN CUMBERLAND COUNTY PLAN BOOK 33,PAGE 136 ON SEPTEMBER 20,1978,AND INCORPORATED HEREIN BY REFERENCE AS FOLLOWS; BEGINNING AT A POINT ON THE WESTWARDLY LINE OF HOLLY ESTATES DRIVE(50 FEET WIDE RIGHT OF WAY)AT THE SOUTH EAST CORNER OF LOT NO. 10 ON A CERTAIN SUBDIVISION FOR RICHARD B.ANDERSON RECORDED IN PLAN BOOK 28,RgGE 135;THENCE BY THE ESTWARDLY LINE OF THE SAID HOLLY ESTATE DRIVE.SOUTH 17 DEGREES 29 MINUTES 28 SECONDS WEST 150 FEET TO A POINT BEING THE NORTHEAST CORNER OF LOT NO.8 ON PLAN OF HOLLY ESTAT"S; THENCE BY LOT NO.8 NORTH'i2 DEGREES 30 MINUTES 32 SECONDS WEST 299.14 FEET TO A POINT ON LINE OF LANDS NOW OR FORMERLY OF JOHN DELP;THENCE BY LANDS OF DELP,NORTH 17 DEGREES 10 MINUTES 56 SECONDS EAST 149.15 FEET TO A POINT BEING. THE SOUTHWEST CORNER OF LOT NO,9 ON SUBDIVISION FOR RICHARD E.ANDERSON;THENCE BY LOT NO.h AND LOT NO.10 ON SUBDIVISION FOR RICHARD E. ANDERSON,SOUTH 72 DEGREES 40 MINUTES 32 SECONDS EAST 299.94 FEET TO A POINT,THE PLACE OF BEGINNING.CONTAINING 1.0256 ACRES,MORE OR LESS. BEING ALL OF LOT NO.7 ON PLAN OF HOLLY ESTATES,AND KNOWN AND NUMBERED AS 19 HOLLY ESTATES DRIVE,GARDNERS,PA 17324. BEING KNOWN AS:19 HOLLY ESTATES DRIVE,GARDNERS,PA 17324 PROPERTY ID NO.:08-16-0210- 094 TITLE TO SAID PREMISES IS VESTED IN PATRICIA M.SOBOTOR AND MICHAEL P.SOBOTOR,HUSBAND AND WIFE BY DEED FROM PATRICIA M.KNUDSON,NOW BY MARRIAGE KNOWN AS PATRICIA M SOBOTOR DATED 09/08/1999 RECORDED 09/14/1999 IN DEED BOOK 207 PAGE 735. TThe Patriot-flews Co. -no!2, 0 Tebhnology Pkwy 14t atr1*0tWX(W5 Suite 300 Mechanicsburg, PA 17050 Now you know Inquiries - 717-255~8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587 Approved May 16, 192S Commonwealth of Pennsylvania, County ofDauphin) ne 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 mf The Patriot-News Co. aforesaid bx virtue and pursuant boa resolution unanimously passed and adopted emvena|k/bv the stockholders and board of directors mf the said ��onnpanyand entk/duly recorded in the of�mafor the Recording ' 'Deeds in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317. ^ PUBLICATION COPlf This ad ran on the date(s)shown below: ^ 10126/12 , 11/02/12 11/09112 . . . . . . . . . . . . . .W 2A.D. Nota?y Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L.Owens,Notary Public Lower Paxton Twp.,Dauphin County My Commission Wres Nov.26.2ots ^ ' ° . ="vbtK,PENNSYLVANIA ASSOCIATION orNOTARIES � 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 @udren.com U.S. Bank,N.A. as Trustee for the COURT OF COMMON PLEAS Registered Holders of Structured Asset CIVIL DIVISION Securities Corporation Mortgage Pass- Cumberland County Through Certificates, Series 2007-TC1 Plaintiff MORTGAGE FORECLOSURE v. rn Unknown Heirs, Successors,Assigns and NO. 2012-728 ..-- W yjt�:ni All Persons, Firms or Associations Claiming Right Title or Interes from or Under Patricia M. Sobotor, Deceased sF Michael P. Sobotor r Patricia M. Sobotor,Deceased Defendant(s) PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due $ 66,106.90 Interest From 8/29/2012 $5,314.80 to Date of Sale 6/4/2014 Ongoing Per Diem of$8.24 to actual date of sale including if sale is held at a later date (Costs to be added) $ 00 C6 P UDREN LAW O ICES, P.C. aon .9s ,„l 16g ,- s t: BY 1 t S torney for Plaintiff tt 11 SALVATORE CAROLLO, ESQUIRE Et u PA ID 311050 g I gas .0S MJU#: 11121056 CASE#: 11121056-1 (p/gam [u,,,---/e/J2� UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadin s ' udren.com U.S. Bank,N.A. as Trustee for the COURT OF COMMON PLEAS Registered Holders of Structured Asset CIVIL DIVISION Securities Corporation Mortgage Pass- Cumberland County Through Certificates, Series 2007-TC1 �•.� „ Plaintiff MORTGAGE FORECLOSURE v. crA Unknown Heirs, Successors,Assigns and NO. 2012-728 All Persons, Firms or Associations . t Claiming Right Title or Interes from or Under Patricia M. Sobotor,Deceased 2. Michael P. Sobotor --- Patricia M. Sobotor,Deceased Defendant(s) CERTIFICATE OF ACT 91 I hereby state that as the attorney for the Plaintiff in the above-captioned matter: EL Act 91 procedures have been fulfilled n 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 ICES, P.C. BY: Attorney for Plaintiff SALVATORE CAROLLO, ESQUIRE PA ID 311050 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 leadin•s • udren.com U.S. Bank,N.A. as Trustee for the COURT OF COMMON PLEAS Registered Holders of Structured Asset CIVIL DIVISION Securities Corporation Mortgage Pass- Cumberland County Through Certificates, Series 2007-TC1 Plaintiff MORTGAGE FORECLOSURE V. N C) c.j)� • Unknown Heirs, Successors,Assigns and NO. 2012-728 �` All Persons, Firms or Associations 'n ' o fa a Claiming Right Title or Interes from or Under Patricia M. Sobotor, Deceased _.. Michael P. Sobotor Patricia M. Sobotor,Deceased Defendant(s) AFFIDAVIT OF LAST KNOWN ADDRESS UNDER RULE 76 The Defendant(s)last known address is as follows: UNKNOWN HEIRS, SUCCESSORS,ASSIGNS AND ALL PERSONS,FIRMS OR ASSOCIATIONS CLAIMING RIGHT TITLE OR INTERES FROM OR UNDER PATRICIA M. SOBOTOR,DECEASED 19 HOLLY ESTATES DRIVE GARDNERS,PA 17324 MICHAEL P. SOBOTOR 19 HOLLY ESTATES DRIVE GARDNERS,PA 17324 PATRICIA M. SOBOTOR,DECEASED 19 HOLLY ESTATES DRIVE GARDNERS,PA 17324 This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. UDREN L OFFICES,P.C. t rney for Plaintiff SALVATORE CAROLLO, ESQUIRE PA ID 311050 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 °` leadin•s ' udren.com U.S. Bank,N.A. as Trustee for the COURT OF COMMON PLEAS Registered Holders of Structured Asset CIVIL DIVISION c'> �� Securities Corporation Mortgage Pass- Cumberland County 5" Through Certificates, Series 2007-TC1 rri ;1`). Plaintiff MORTGAGE FORECLOSURE Unknown Heirs, Successors,Assigns and NO. 2012-728 ? All Persons,Firms or Associations G „) Claiming Right Title or Interes from or R - — Under Patricia M. Sobotor,Deceased "l Michael P. Sobotor Patricia M. Sobotor,Deceased Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 U.S. Bank,N.A. as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC1,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: 19 Holly Estates Drive, Gardners, PA 17324 1. Name and address of Owner(s) or reputed Owner(s): Unknown Heirs, Successors,Assigns and All Persons, Firms or Associations Claiming Right Title or Interes from or Under Patricia M. Sobotor,Deceased 19 Holly Estates Drive Gardners, PA 17324 Michael P. Sobotor 19 Holly Estates Drive Gardners, PA 17324 Patricia M. Sobotor, Deceased 19 Holly Estates Drive Gardners, PA 17324 2. Name and address of Defendant(s) in the judgment: Unknown Heirs, Successors,Assigns and All Persons, Firms or Associations Claiming Right Title or Interes from or Under Patricia M. Sobotor,Deceased 19 Holly Estates Drive Gardners, PA 17324 Michael P. Sobotor 19 Holly Estates Drive Gardners, PA 17324 Patricia M. Sobotor, Deceased 19 Holly Estates Drive Gardners, PA 17324 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: U.S.Bank,N.A. as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TC1 1661 Worthington Road Suite 100 West Palm Beach, FL 33409 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 Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Commonwealth of PA,Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Tenants/Occupants 19 Holly Estates Drive Gardners, PA 17324 Commonwealth of PA,Bureau of Individual Tax,Inheritance Tax Division 6th Floor, Strawberry Square,Dept. 280601 Harrisburg,PA 17128 Internal Revenue Service, Pittsburgh Office W.S. Moorhead Federal Building 1000 Liberty Avenue, Room 704 -Advisory Pittsburgh, PA 15222 1✓ v Department of Public Welfare, TPL Casulty Unit,Estate Recovery Program PO BOX 8486,Willow Oak Bldg. Harrisburg, PA 17105-8486 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: Z.11.l UDREN LAW OFFICES, P.C. BY: Atto ey for Plaintiff SALVATORE CAROLLO, ESQUIRE PA ID 311050 MJU#: 11121056 CASE#: 11121056-1 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 leadin•s • udren.com U.S.Bank,N.A. as Trustee for the COURT OF COMMON PLEAS Registered Holders of Structured Asset CIVIL DIVISION Securities Corporation Mortgage Pass- Cumberland County Through Certificates,Series 2007-TC1 Plaintiff MORTGAGE FORECLOSURE v. - r" PATRICIA M. SOBOTOR,DECEASED, NO. 2012-728 ka ; MICHAEL P. SOBOTOR,UNKNOWN Wit' ' HEIRS, SUCCESSORS,ASSIGNS AND -� -4 C; ALL PERSONS, FIRMS OR CD ASSOCIATIONS CLAIMING RIGHT n TITLE OR INTERES FROM OR UNDER • PATRICIA M. SOBOTOR,DECEASED Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Unknown Heirs, Successors,Assigns and All Persons,Firms or Associations Claiming Right Title or Interes from or Under Patricia M. Sobotor,Deceased 19 Holly Estates Drive Gardners, PA 17324 Your house(real estate) at 19 Holly Estates Drive,Gardners, PA 17324 is scheduled to be sold at the Sheriffs Sale on June 4,2014 at 10:00 A.M. at the Cumberland County Courthouse, Commissioners Hearing Room,2nd Floor, Carlisle,PA 17013,to enforce the court judgment of$66,106.90, obtained by Plaintiff above(the mortgagee) against you. If the sale is postponed, -the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale,you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment,late charges,costs and reasonable attorney's fees. To find out how much you must pay,you may call: (856)669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff s Sale is not stopped,your property will be sold to the highest bidder. You may find out the price bid by calling 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. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 leadin l s . udren.com U.S.Bank,N.A. as Trustee for the COURT OF COMMON PLEAS Registered Holders of Structured Asset CIVIL DIVISION Securities Corporation Mortgage Pass- Cumberland County ; _.:; Through Certificates, Series 2007-TC1 Plaintiff MORTGAGE FORECLOSURE r' v. — N p - " PATRICIA M. SOBOTOR,DECEASED, NO. 2012-728 ' - -6,c' MICHAEL P. SOBOTOR,UNKNOWN 57 2, HEIRS, SUCCESSORS,ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT TITLE OR INTERES FROM OR UNDER PATRICIA M. SOBOTOR, DECEASED Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Patricia M. Sobotor, Deceased 19 Holly Estates Drive Gardners, PA 17324 Your house(real estate) at 19 Holly Estates Drive, Gardners, PA 17324 is scheduled to be sold at the Sheriffs Sale on June 4, 2014 at 10:00 A.M. at the Cumberland County Courthouse, Commissioners Hearing Room,2nd Floor, Carlisle, PA 17013, to enforce the court judgment of$66,106.90, 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 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 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.) 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. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 e leadin l s ' udren.com U.S. Bank,N.A. as Trustee for the COURT OF COMMON PLEAS Registered Holders of Structured Asset CIVIL DIVISION Securities Corporation Mortgage Pass- Cumberland County Through Certificates, Series 2007-TC1 Plaintiff MORTGAGE FORECLOSURE (--) v. rn 0-1-7; PATRICIA M. SOBOTOR,DECEASED, NO. 2012-728 MICHAEL P. SOBOTOR, UNKNOWN c.f HEIRS, SUCCESSORS,ASSIGNS AND ALL PERSONS, FIRMS OR mac-) :,: ASSOCIATIONS CLAIMING RIGHT TITLE OR INTERES FROM OR UNDER --- . PATRICIA M. SOBOTOR, DECEASED Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Michael P. Sobotor 19 Holly Estates Drive Gardners, PA 17324 Your house(real estate) at 19 Holly Estates Drive, Gardners, PA 17324 is scheduled to be sold at the Sheriffs Sale on June 4, 2014 at 10:00 A.M. at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle,PA 17013, to enforce the court judgment of$66,106.90, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale,you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment,late charges,costs and reasonable attorney's fees. To find out how much you must pay,you may call: (856)669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) } 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 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 12-728 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due U.S.BANK N.A.,AS TRUSTEE FOR THE REGISTERED HOLDERS OF STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE PASS-THROUGH CERTIFICATES,SERIES 2007-TC1 Plaintiff(s) From UNKNOWN HEIRS,SUCCESSORS,ASSIGNS AND ALL PERSONS,FIRMS OR ASSOCIATIONS CLAIMING RIGHT TITLE OR INTERES FROM OR UNDER PATRICA M. SOBOTOR,DECEASED MICHAEL P.SOBOTOR,PATRICIA M. SOBOTOR,DECEASED (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: $66,106.90 L.L.: Interest FROM 8/29/2012 TO DATE OF SALE 6/4/2014 ONGOING PER DIEM OF$8.24 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE-$5,314.80 Atty's Comm: Due Prothy: $2.25 Atty Paid: $1,525.25 Other Costs: Plaintiff Paid: Date: 2/21/14 • _ • . . David D.Buell,Prothono . (Seal) By: Aj 1i_ _ i/1 Deputy REQUESTING PARTY: Name: SALVATORE CAROLLO,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.311050 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin ' s ' udren.com U.S. Bank, N.A. as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass -Through Certificates, Series 2007-TC1 Plaintiff v. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT TITLE OR INTERES FROM OR UNDER PATRICIA M. SOBOTOR, DECEASED, MICHAEL P. SOBOTOR, PATRICIA M. SOBOTOR, DECEASED, Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 2012-728 AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: G U 7-7 n 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. -13 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. 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: MJU#: 11121056 CASE#: 11121056-1 N AW OFFI BY: Attorne or David Neeren, Esquire PAID 204252 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 a f - . as rustee Registered Holders of Structured Asset Securities Corporation Mortgage Pass - Through Certificates, Series 2007-TC1 Plaintiff v. UNKNOWN HEIRS SUCCESSORS, ASSIGNS AND ALL 'PERSONS FIRMS OR ASSOCIATIONS CLAIMING RIGHT TITLE OR INTERES FROM OR UNDER PATRICIA M. SOBOTOR, DECEASED; MICHAEL P. SOBOTOR; PATRICIA M. SOBOTOR, DECEASED; Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 2012-728 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S): UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT TITLE OR INTERES FROM OR UNDER PATRICIA M. SOBOTOR, DECEASED; MICHAEL P. SOBOTOR; PATRICIA M. SOBOTOR, DECEASED; PROPERTY: 19 Holly Estates Drive, Gardners, PA 17324 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on 06/04/2014 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#: 11121056 CASE#: 11121056-1 Eddin Name and Address of Sender Henrietta Crommarty UDREN LAW OFFICES, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 ❑ Registered ❑ Insured ❑ COD ❑ Certified ❑ Retum Receipt for Merchandise p ❑ Int'l Recorded Del. ❑ Express Mail giMail appropriate block for Registeredcertificate ❑ With Postal Insurance ❑ Without postal Insurance here if issued as Affix stampatsof of mailing or for additional copies of this bill. Postmark and Date of Receipt Line Article Number Name of Addressee, Street, and Post Office Address Postage Fee Due RR. Fee S.D. Fee S.H. Fee Rst. Del. Fee Remarks Handling Charge Act. Value (If Regis.) Ins a1 N0 Sc/ e r 1 Sale date 6/4/2014 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 r- `- r o 2 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 3 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 4 Tenants/Occupants 19 Holly Estates Drive Gardners,PA1 PA 17324 5 Commonwealth of PA, Bureau of Individual Tax, inheritance Tax Division 6th Floor, Strawberry Square, Dept. 280601-1321151911 Harrisburg, PA 17128 IV. Yti. • U.S. POSTAGE) 4_i ra ti ZIP 08003 • y 02 1YY t ti .00013870901 2E2 6 Internal Revenue Service, Pittsburgh Office W.S. Moorhead Federal Building 1000 Liberty Avenue, Room 704 - Advisory Pittsburgh, PA 15222 E F ow 7 Department of Public Welfare, TPL Casulty Unit, Estate Recovery Program PO BOX 8486, Willow Oak Bldg. Harrisburg, PA 17105-8486 F, 8 Unknown Heirs, Successors, Assigns and All Persons, Finns or Associations Claiming Right Title or Interes from or Under Patricia M. Sobotor, Deceased 19 Holly Estates Drive Gardners, PA 17324 Total number of Pieces Listed by Sender 8/ Total Number of Pieces Receiv at Pot Office P.:, tmas r, Per (Name of Receiving Employee) The full declaration of value is required on all domestic and international registered mail. The maximum indemnity payable for the reconstruction of nonnego iable documents under Express Mail document reconstruction insurance is $50,000 per p ece subject to a limit of $500,000 per occurrence. The maximum indemnity payable on Express Mail merchandise is $500. The maximum indemnity payable is $25,000 for registered mail, sent with optional postal insurance. See Domestic Mail Manual R900, S913, and S921 for limitations of coverage on insured and COD mail. See International Mail Manual for limitations of coverage on international mail. Special handling charges apply only to third and forth class parcels. PS Form 3877, February 1994 / Form Must be Completed by Typewriter, Ink or Ball Point Pen Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right Title or Interes from or Under Patricia M. Sobotor, Deceased - MJU# 11121056-1 (Cumberland County) Michael P. Sobotor - MJU# 11121056-1 (Cumberland County) Patricia M. Sobotor, Deceased - MJU# 11121056-1 (Cumberland County) Udren Law Offices, P.C. Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry 11111, NJ 08003-3620 RAC (PA -3129) #11121056-1 • 1111111!!!!! INTERNAL REVENUE SERVICE, PITTSBURGH OFFICE W.S. MOORHEAD FEDERAL BUILDING 1000 LIBERTY AVENUE, ROOM 704 - ADVISORY PITTSBURGH, PA 15222 U.S. POSTAGE >). PITNEY BOWES (lc i;e0II.T. .0•1=2•111 ZIP 08003 $ 005.130 02 1ri 0001387090 APR 30 2014 UNITED STATES • POSTAL SERVICE Date: May 20, 2014 Henni Crommarty: The following is in response to your May 20, 2014 request for delivery information on your Certified Mail TM item number 9171999991703407006919. The delivery record shows that this item was delivered on May 2, 2014 at 12:25 pm in PITTSBURGH, PA 15222. The scanned image of the recipient information is provided below. Signature of Recipient : Address of Recipient : ON _FfAAY - lord �/�: www - _ WV/ %8 ofM l•llwry Of SOO.ASK-USPS (271.1777) �I/ Srr MS Thank you for selecting the Postal Service for your mailing needs. If you require additional assistance, please contact your local Post Office or postal representative. Sincerely, United States Postal Service IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION U.S. Bank, N.A. as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass -Through Certificates, Series 2007-TC1 Plaintiff v. Michael P. Sobotor Patricia M. Sobotor, Deceased Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right Title or Interest From or Under Patricia M. Sobotor, Deceased Defendant(s) NO. 2012-728 Civil ORDER 7 k c57.t AND NOW,this Dayof 1a4 t � , 2012, upon consideration of Plaintiff's Motion For Service Pursuant To Special Order Of Court, and any response thereto, it is hereby ORDERED AND DECREED that Service of the Complaint In Mortgage Foreclosure on Patricia M. Sobotor, Deceased, and Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right Title or Interest From or Under Patricia M. Sobotor, Deceased shall be complete when Plaintiff or its counsel or agent has published in accordance with Pa.R.C.P. 430(b)(1) a Notice of the action once in the local legal publication and once in a newspaper of general circulation within the County; and, pursuant to Pa.R.C.P. 430, service of all subsequent pleadings, including, inter alia, the Notice of Sheriffs Sale that requires personal service, shall be complete when the Sheriff, competent adult, constable, or other appropriate party has posted only, a copy of said subsequent pleadings and/or Notice on the most public part of the property located at: 19 Holly Estates Drive, Gardners, PA 17324, which is the subject matter of this action in mortgage foreclosure. BY THE COURT: SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor OFFICE CE 'r 714E SKEPErs US Bank NA vs. Patricia M Sobotor-Deceased (et al.) Case Number 2012-728 SHERIFF'S RETURN OF SERVICE 03/25/2014 06:07 PM - Deputy Dawn Kell, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 19 Holly Estates Drive, Dickinson - Township, Gardners, PA 17324, Cumberland County. 03/25/2014 06:07 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Patricia M Sobotor-Deceased, pursuant to Order of Court by "Posting" the premises located at 19 Holly Estates Drive, Dickinson Township, Gardners, PA 17324, Cumberland County with a true and correct copy according to law. 03/25/2014 06:07 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Patricia M Sobotor Dec. Unknown Heirs, Successors, Assigns and, pursuant to Order of Court by "Posting" the premises located at 19 Holly Estates Drive, Dickinson Township, Gardners, PA 17324, Cumberland County with a true and correct copy according to law. 03/27/2014 04:01 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 Sobotor at 19 Holly Estates Drive, Dickinson Twp., Gardners, PA 17324, Cumberland County. SHERIFF COST: $1,003.74 SO ANSWERS, April 16, 2014 RONNY R ANDERSON, SHERIFF E d D (c) CountySuite Sheriff, Teleosoft, Inc. UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com U.S. Bank, N.A. as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass - Through Certificates, Series 2007-TC1 Plaintiff v. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT TITLE OR INTERES FROM OR UNDER PATRICIA M. SOBOTOR, DECEASED MICHAEL P. SOBOTOR PATRICIA M. SOBOTOR, DECEASED Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 2012-728 NOTICE OF THE DATE OF CONTINUED SHERIFF'S SALE The Sheriff's Sale scheduled for June 4 2014 at 10:00 AM in the above -captioned matter has been continued until July 2, 2014 at 10:00 AM. Date: It, l L IM MJU#: 11121056 CASE#: 11121056-1 BY: AMA AAe RAVER, ESQUIRE ff PA. I.D. # i rIC 8., UDREN LAW O , 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 (856) 669-5400 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com U.S. Bank, N.A. as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass - Through Certificates, Series 2007-TC1 Plaintiff v. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT TITLE OR INTERES FROM OR UNDER PATRICIA M. SOBOTOR, DECEASED MICHAEL P. SOBOTOR PATRICIA M. SOBOTOR, DECEASED Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 2012-728 NOTICE OF THE DATE OF CONTINUED SHERIFF'S SALE The Sheriffs Sale scheduled for July 2, 2014 at 10:00 AM in the above -captioned matter has been continued until August 6, 2014 at 10:00 AM. Date: n .- l MJU#: 11121056 CASE#: 11121056-1 BY: 4 sa_ Attorney for Plaintiff UDREN LAW OFFICES, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 (856) 669-5400 Nicole L Esq a 1 202194 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY 2514 SEP 17 AM 8:37 CUMBERLAND COUNTY PENNSYLVANIA US Bank NA vs. Patricia M Sobotor-Deceased (et al.) Case Number 2012-728 SHERIFF'S RETURN OF SERVICE 03/25/2014 06:07 PM - Deputy Dawn Kell, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 19 Holly Estates Drive, Dickinson - Township, Gardners, PA 17324, Cumberland County. 03/25/2014 06:07 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Patricia M Sobotor-Deceased, pursuant to Order of Court by "Posting" the premises located at 19 Holly Estates Drive, Dickinson Township, Gardners, PA 17324, Cumberland County with a true and correct copy according to law. 03/25/2014 06:07 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Patricia M Sobotor Dec. Unknown Heirs, Successors, Assigns and, pursuant to Order of Court by "Posting" the premises located at 19 Holly Estates Drive, Dickinson Township, Gardners, PA 17324, Cumberland County with a true and correct copy according to law. 03/27/2014 04:01 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 Sobotor at 19 Holly Estates Drive, Dickinson Twp., Gardners, PA 17324, Cumberland County. 06/04/2014 As directed by Mark Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 7/2/2014 07/01/2014 As directed by Mark Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 8/6/2014 08/06/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA on August 06, 2014 at 10:00 a.m. He sold the same for the sum of $1.00 to Attorney Mark Udren, on behalf of U.S. Bank, N.A., as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass -Through Certificates, Series 2007-TC1, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $927.79 SO ANSWERS, August 26, 2014 RONNY R ANDERSON, SHERIFF (p) Co ntySu: e Sheriff. 7eleosoft. Inc. . OQ PI . ae4. a as pd Co - 4&# 9'2)33 ?31/173 On February 27, 2014 the Sheriff levied upon the defendant's interest in the real property situated in Dickinson Township, Cumberland County, PA, Known and numbered as 19 Holly Estates Drive, Gardners, as Exhibit "A" filed with this writ and by this Reference incorporated herein. Date: February 27, 2014 By: Real Estate Coordinator LXIII 16 CUMBERLAND LAW JOURNAL 04/18/14 Writ No. 2012-728 Civil Term U.S. Bank N.A. vs. Patricia M Sobotor—Deceased Michael P. Sobotor Patricia M. Sobotor Dec. Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest from or Under Atty.: Mark Udren ALL THAT CERTAIN LOT OF LAND SITUATE IN DICKINSON TOWNSHIP, CUMBERLAND COUN- TY, PENNSYLVANIA: BEING KNOWN AS 19 Holly Es- tates Drive, Gardners, PA 17324. PARCEL NUMBER: 08-16-0210- 094. IMPROVEMENTS: Residential Property. 105 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 18, April 25 and May 2, 2014 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. r Lisa Marie Coyne j Editor SWORN TO AND SUBSCRIBED before me this day of May, 2014 / Notary COMMONWEALTH OF PENNSYLVAN!A NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO., CUMBERLAND CNTY My Commission Expires Apr 28. 2018 • The Patriot -News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 he patriot News Now you know CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE 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 Marianne Miller, being duly sworn according to law, deposes and says: That she is the Assistant Controller 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 2012-728 Civil Term US Bank NA - Vs Patricia M Sobotor- Deceased Michael P Sobotor Patricia M Sobotor Dec. Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming. Right, Title or Interest from or Under Atty: Mark Udren ALL THAT CERTAIN LOT OF LAND SITUATE IN DICKINSON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA: BEING KNOWN AS 19 Holly Estates Drive, Gardners, PA 17324 PARCEL NUMBER: 08-16-0210-094 IMPROVEMENTS: Residential Property S or • and subscribed befor ry PtYblic This ad ran on the date(s) shown below: 04/13114 04/20/14 04/27/14 e is 02 day of Ma , 2014 A.D. 1 to COMMONWEALTH OF PENNSYLVANIA 4otarial Seal Holy Lynn t"s!.,ff ;:;,tart' Public ' 3shington Twp., Dauphin County My Cemmissfa, Ex.px Dec. 12 MEMBER, PENNSYLVANIA AS.S.2016 ATTON OF NOTARIES COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Registered Holders of Structured Asset Sec Corp Mtg Pass -Through Cert Series 2007 -TCI is the grantee the same having been sold to said grantee on the 6th day of August A.D., 2014, under and by virtue of a writ Execution issued on the 21st day of February, A.D., 2014, out of the Court of Common Pleas of said County as of Civil Term, 2012 Number 728, at the suit of Registered Holders of Structured Asset Sec Corp Mtg Pass -Through Cert Series 2007-TC1 against Michael P Sobotor & Patricia M, Heirs is duly recorded as Instrument Number 201420907. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of sci)ecorder of Deeds Recorder f Deeds, Cumberland County, Carlisle, PA My Commission Expires the First Monday of Jan. 2018