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HomeMy WebLinkAbout12-2340UDREN 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 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 ATTORNEY FOR PLAINTIFF 856-669-5400 leadings a,udren.com DEUTSCHE BANK NATIONAL TRUST COMPANY As Trustee for the registered holder of Soundview Home Loan Trust 2006-EQ1 Asset-Backed Certificates, Series 2006-EQ1 C/O Ocwen Loan Servicing, LLC 1661 Worthington Road #100 West Palm Beach, FL 33409 Plaintiff V. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER GARY R. WILBUR, DECEASED 27 STONEHEDGE DRIVE CARLISLE, PA 17015 MICHAEL WILBUR, KNOWN HEIR OF GARY R. WILBUR 27 STONEHEDGE DRIVE CARLISLE, PA 17015 CHRISTINE BROWN, KNOWN HEIR OF GARY R. WILBUR 27 STONEHEDGE DRIVE CARLISLE, PA 17015 GARY R. WILBUR, DECEASED 797 SPRAGUE RD. MEMPHIS, NY 13112 LYNDELL D. WILBUR 797 SPRAGUE RD. MEMPHIS, NY 13112 Defendant(s) F i ^. i7? tv? CD',.., - CJ L 1 .a y' COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. lp'a-3YO O(VI/ COMPLAINT IN MORTGAGE FORECLOSURE 9s1'°l ?. a -13'3.2 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 provisions de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the entity designated in the caption on a preceding page. Plaintiff is the legal holder of the Mortgage that is the subject of this Action. Plaintiff is either the current mortgagee of record, is the legal holder of the Mortgage by virtue of being successor in interest to the current mortgagee of record, or is the legal holder of the Mortgage by virtue of Assignment of Mortgage. If Plaintiff is the legal holder of the Mortgage by virtue of Assignment of Mortgage, it is by the following Assignments of Mortgage, all of which have either been recorded or Plaintiff is in the process of formalizing the actual Assignment of Mortgage in Plaintiff s favor: Assignor: Mortgage Electronic Registration Systems, Inc., as nominee for Equifirst Corporation Assignee: DEUTSCHE BANK NATIONAL TRUST COMPANY As Trustee for the registered holder of Soundview Home Loan Trust 2006-EQ1 Asset-Backed Certificates, Series 2006-EQ1 Date of Assignment: 09/01/2011 Recorded Date: 10/10/2011 Book/Instrument #: instrument 201127936 Page: N/A 2. Upon information and belief Defendant(s) and/or their predecessor: Gary R. Wilbur & Lyndell D. Wilbur (hereinafter "Defendants"), are the owners of property located at 27 Stonehedge Drive, Carlisle, PA 17015, by virtue of Deed dated 05/30/2001 and recorded 05/30/2001 in Official Records Book 245 at Page 655 of the Public Records of Cumberland County, Pennsylvania (hereinafter the "Property") 3. On 06/08/2006, Defendant(s) and/or their predecessor: GARY R. WILBUR & LYNDELL D. WILBUR promised to pay to the order of Equifirst Corporation , the principal sum of $142,200.00 payable with interest thereon provided in the Note. 4. By Mortgage dated 06/08/2006, Defendant(s) and/or their predecessor: GARY R. WILBUR & LYNDELL D. WILBUR to secure the Note, mortgaged to Mortgage Electronic Registration Systems, Inc., as nominee for Equifirst Corporation, the Property which is the subject of this action. The Mortgage was recorded on 06/20/2006 in Official Records Book 1955 at Page 1901. Said Mortgage is incorporated herein by referenced in accordance with Pa.R.C.P 1019(g). A legal description of the mortgage premises is attached hereto and made a part hereof 5. Said mortgage is in default in that the payment due 05/01/2011, and all subsequent payments have not been made, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with the other charges authorized by said Mortgage and itemized below, shall be immediately due. 6. After demand, the Defendant(s) continues to fail or refused to comply with the terms of the Mortgage as follows: (a) By failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) By failing or refusing to pay other charges, if any, indicated below. The following amounts are due on the said Mortgage or modification agreement as of the date stated below Unpaid Principal Balance $143,578.82 Accumulated Interest $11,293.80 Accumulated Late Charges $110.48 Escrow Deficit/(Reserve) $588.92 Title Report $300.00 Attorney Fees- Estimated $1,300.00 Property Inspection $92.50 Property Valuation $584.00 Grand Total $157,848.52 The above figures are calculated as of 03/27/2012: The interest rate is subject to adjustment if more fully described as such in the note and mortgage. The interest rate on the subject note is at 8.00000 %. The per diem interest accruing on this debt is $31.53 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 $55.24. 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 $157,848.52 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged premises. UDRE W OFFICES, P.C. BY: BELUNO, ESQUIRE PAA ID 309091 VERIFICATION The undersigned states that he/she is authorized to make this verification on behalf of the Plaintiff, and that the facts set forth in the foregoing pleading are true and correct to the best of the information and belief of the undersigned. The undersigned understands that this statement is "e subject to the, penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to ay oAties. Date: V Name: Title: .Y%AN-u ROOM Company: DEUTSCHE BANK NATIONAL TRUST COMPANY As Trustee for the registered holder of Soundview Home Loan Trust 2006-EQ1 Asset-Backed Certificates, Series 2006-EQ1 by its Attorney in Fact, Saxon Mortgage Services, Inc. MJU #: 11080294 CASE #: 11080294-1 ALL THAT lot or parcel of land situate in South Middleton Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: COhQdENCING at a concrete monument on the northern right-of-way line of Stonehedge Drive, a sixty (60) foot wide right-of-way; thence along said right-of-way line on a curve to the left having a radius of four hundred fifty and zero hundredths (450.00) feet, an arc distance of two hundred twenty-one and thirty-eight hundredths (221.38) feet to a point on the aforesaid right-of-way line also being the southwest corner of Parcel No. 5 of Rockland Village at the POINT of BEGINNIG; thence continuing along the same on a curve to the left having a radius of four hundred fifty and zero hundredths (450.00) feet, an arc distance of thirty-four and eighty-seven hundredths (34.87) feet to a point on said right-of-way line also being the southeast corner of Parcel No. 3 of Rockland Village; thence along the eastern line of Parcel No. 3 and through a common party wall separating Parcel No. 3 from the Parcel described herein, North nineteen degrees nine minutes forty-four seconds East (N 19° 09' 44" E), one hundred twenty-six and thirty-three hundredths (126.33) feet to a point at lands of Garland Court II within the Stonehedge PRD; thence along said lands South sixty-seven degrees forty minutes ten seconds East (S 67° 40' 10" E), a distance of thirty-four and eighty-four hundredths (34.84) feet to a point at the northwest corner of Parcel No. 5; thence along the western line of Parcel No. 5 and through a common party wall separating Parcel No. 5 from the Parcel described herein South nineteen degrees nine minutes forty-four seconds West (S 19° 09' 44" W), one hundred twenty-six and fifty-nine hundredths (126.59) feet to a point on the northern right-of-way line of Stonehedge Drive, the place of BEGINNING. THE above-described parcel is subject to a twenty-foot (20') wide sanitary sewer and water line easement through the southern portion of the parcel, and an irregular sized drainage easement along the northern boundary line of the Parcel. Both of these easements are found on the Final Land Development Plan of Rockland Village recorded in Plan Book 80, Page 13, at the Cumberland County Courthouse in the Recorder of Deeds Office. BEING Parcel No. 4 of the Final Land Development Plan of Rockland Village recorded in Plan Book 80, Page 13 at the Cumberland Count y Courthouse in the Recorder of Deeds Office. HAVING THEREON erected a brick and vinyl townhouse having a mailing address of 27 Stonehedge Drive, Carlisle, Pennsylvania. UNDER AND SUBJECT to a Declaration of Covenants and Restrictions recorded in Cumberland County Miscellaneous Record Book 311, Page 482, Restated Declaration of Covenants and Restrictions recorded in Cumberland County Miscellaneous Record Book 325, Page 992, and Supplemental Declaration of Covenants and Restrictions recorded in Cumberland County Miscellaneous Record Book 624, Page 1082 and further subject to By-laws of the Stonehedge Homeowners Association as recorded in Cumberland County Miscellaneous Book 311, Page 51 L I 9-5 5 PG 191 a BEING THE SAME PREMISES which Ahrens Development, Inc., a Pennsylvania corporation by deed dated and recorded May 30, 2001 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 245, Page 655, granted and conveyed unto Gary R. Wilbur and Lyndell D. Wilbur, husband and wife. I Certify wi, ) be County PA s ? ?• " R?-,,,jrder of Deeds J 5551919 ......................:: Oewen Loan Servicing, LLC P.O. Box 24737 W E N West Palm Beach. Florida 33416-4 73 7 (Do not send correspondence orpayments to the above address. `€ v. June 30. 2011 VIA First Class Mail VIA Certified Mail (return receipt requested) Certified Number: 71069017515142368673 Reference Code: 1106 Estate of Gary Wilbur 27 Stonehedge Dr Carlisle, PA 17013 Loan Number: 71058903 Property Address: 27 Stonehedge Drive ,Carlisle, PA 17015-0000 PLEASE SEE THE ENCLOSED DOCUMENT EXHIBIT A 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 Ocwen Loan Servicing, LLC P.O. Box 24737 ...._._._. West Palm Beach, Florida 3 O C W E N (Do not send correspondence June 30, 2011 3416-4737 nr pavments to the above address.) 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 defa ult and the lende r intends to foreclose Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to 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 COUN SELING A , GENCY WITHIN THIRTY (30) DAYS OF THE DATE OF THIS NOTICE Take this Notice with you when y ou meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counselin g Agencies servin g your Coun _ ty are listed at the end of this Notice If you have any questions, you may call the Pennsyl vania Housing Fin ance 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 qu ). estions represent atives at the Consumer Credit Counseling Agency may be able to help explain it You may also wa nt to contact an at torney in yo , ur area The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION, OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO A ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. USTED PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: Estate of Gary Wilbur 27 Stonehedge Drive Carlisle, PA 17015-0000 71058903 OCWEN 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 0' Ocwen Loan Servicing, LLC P.0. Box 24737 __.._.__ Ifest Palm Beach, Florida 33416-4 73 7 ecwEN (Do not send correspondence or payments to the above address.) 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 BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -Under the Act. you are entitled to a temporary sta3: of foreclosure on. your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face- to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE- CALLED"HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling 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 countyin _which-the urooerty 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 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 0Ocwen Loan Servicing, LLC P.O. Boa 24737 w H 9 est Palm Beach, Florida 33416-4 73 7 o (Do not send correspondence or payments to the above address.) .C;{> k! NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property located at: 27 Stonehedge Drive , Carlisle, PA 17015-0000 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 2 payments in the amount of $ 1.291.78 from May 01, 2011 through June 30, 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 .......................................... $ 2.209.46 S O.00 $ 374.10 S55.24 S O.00 S413.50 S O.00 S O.00 $ 3,052.30 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 $3.052.30, 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 Monev Order made ayable 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 from a debt collector attempting to collect a debt; an), information obtained will be used for that purpose. However, if the debt is in active bankruptcv or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt NMLS # 1852 cwen Loan Servicing, LLC O?i O P.O. Box 24737 West Palm Beach. Florida 33416-47.i7 G C W E N (Do not send correspondence orpavments to the above address.) yx"V. V :)'-\X _-'X C V EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default 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'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 will be used for that purpose. However, if the debt is in active bankruptcv or has been discharged through bankr•uptcv, this communication is not intended as and does not constitute an attempt to collect a debt NMLS # 1852 Ocwen Loan Servicing, LLC P.O. Box 24737 ........... O West Palm Beach, Florida 3 O C W E N (Do not send correspondence June 30, 2011 3416-4737 or payments to the above address. VIA First Class Mail VIA Certified Mail (return receipt requested) Certified Number: 71069017515142368666 Reference Code: 1106 Lyndell D. Wilbur 27 Stonehedge Drive Carlisle, PA 17015-0000 Loan Number: 71058903 Property Address: 27 Stonehedge Drive , Carlisle, PA 17015-0000 PLEASE SEE THE ENCLOSED DOCUMENT 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 bankruptcv or has been discharged through bankruptcy, this communication is not . intended as and does not constitute an attempt to collect a debt NMLS # 1852 ...................... Ocwen Loan Servicing, LLC 0 73 7 June 30, 2011 P.O. Box ?4737 West Palm Beach. Florida 33416- O C W E N (Do not send correspondence or payments to the above address.) <'(? V! APPENDIX A ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an o fficial notice that t he mortgage on your home is in default, and the lender intends to foreclose Specific information The HOME about the nature of the default is provided in the attached pages. OWNER'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 CRE DIT COUNSELING . AGENCY WITHIN THIRTY (3 0) DAYS OF THE DATE OF THIS NOTICE Take this No tice with you when you meet with the Counseling Agency. The name address and phone n umber of Consumer Credit Counseling Agen cies serving your Co _ unty are listed at the end of this N otice If you have a ny questions. you may call the Pennsylvania H ousing Finance Agen cy toll free at (800) 342-23 This Notice 97 (Persons with im contains important paired hearing can call (717) 780-1869). legal information If you have any questions , representatives at t he Consumer Credit Counseling Agency may be abl e to help explain it You may also want to co ntact an attorney in your area The local bar associat ion may be able to h elp you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION, OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO A ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. USTED PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: Lyndell D. Wilbur 27 Stonehedge Drive Carlisle, PA 17015-0000 71058903 OCWEN DACT91.21 This communication is from a debt collector attempting to collect a debt: anv information obtained will be used for that purpose. However, if the debt is in active bankruptcv or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt NMLS # 1852 Ocwen Loan Servicing, LLC P.O. Box 4737 9 est Palm Beach. Florida 33416-47.37 O G W E N (Do not send correspondence or pavments to the above address.) 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 BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -Under the Act you are entitled to a temporary stay of foreclosure on. your mortgage for thirty (30) days from the date of this Notice, During that time you must arrange and attend a "face- to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED"HOR' TO_CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling 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 oronerty is located are set forth at the end of this Notice. It is only necessarv 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). HOVE' TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date), DACT91.21 This communication is froth a debt collector attempting to collect a debt: anv 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 .................... . Ocwen Loan Servicing, LLC O ' P. O. Box 24737 West Palm Beach, Florida 33416-4 73 7 O C W E N (Do not send correspondence or payments to the above address.) NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property located at: 27 Stonehedge Drive , Carlisle, PA 17015-0000 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 2 payments in the amount of $ 1,291.78 from May 01.2011 through June 30, 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 .......................................... $ 2.209.46 S O.00 $ 374.10 $ 55.24 $ 0.00 $ 413.50 S O.00 S 0.00 $ 3,052.30 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 $3,052.30, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. _Payments must be made either by Money Gram Cashier's Check, Certified Check or Money Order 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. 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 ale 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 NMLS # 1852 .................... Ocwen Loan Servicing, LLC P.O. Box 24737 West Palm Beach, Florida 33416-4 73 7 O C W E N (Do not send correspondence orpavments to the above address.) _0 k' Ik ?)=;`\' EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the servicer. HOW TO CONTACT THE SERVICER: Name of Servicer: OCWEN Address: P.O. BOX 24737 WEST PALM BEACH, FL 334164737 Phone Number: 800-310-9229 Fax Number: 407-737-6300 Contact: Early Intervention Dept EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may or ? 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 will be used for that purpose. However, if the debt is in active bankruptcv or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt NMLS # 1852 August 26, 2011 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on vour home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving vour Countv are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUSS AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. ST NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES 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): Garv R. WIlbur Lundell D. Wilbur PROPERTY ADDRESS: 27 Stonehedge Drive _Carlisle, PA 17013___..__._....__..__...-_-----__.__.----_-.-. LOAN ACCT. NO.: 71058903 ORIGINAL LENDER: EquiFirst Coraration CURRENT LENDER: DEUTSCHE BANK NATIONAL TRUST COMPANY As Trustee for the registered holder of Soundview Home Loan Trust 2006-EQ1 Asset- Backed Certificates, Series 2006-KQ1 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: ff YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT'', EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the count-v• in which the propert y 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.) To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE". YOU HAVE THE RIGHT TO FILE A HE MAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS. EVENTUALLY.. APPROVED AT ANY TIME. BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. 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 (Briar it up to date)NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender on your property located at: 27 Stonehedge Drive Carlisle, PA 17013 1S SERIOUSLY 1N DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Mon_-_thiy Payments of $1,291.78 for May 1, 201_1'through August 1, 2011 = $5,167.12 Total Late Charges .= $110.48 ____..__._.____._____...-_--_..__....._....._.........__..._.__....._._-_..- Other charges (explain/itemize): Property Inspection Fee = $21.00 Property Valuation Fee / BPO -- $292.00 TOTAL AMOUNT PAST DUE: _.._......... $5,90.60 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): NIA 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 $5,590.60, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must he made either by cash, cashier's check certified check or money order made payable and sent to: Udren Law Offices. P.C. Woodcrest Corporate Center 111 Woodcrest Road. Suite 200 Cherry Hill, NJ 08003-3620 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.): N/A IF YOU_D.O...N.O.T...CURE ..TAE.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 Sheriff s 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 Sheriff's Sale as specified in writing by the tender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender/Servicer: _Ocwen Loan Servicin ___.._.---_..___._._-----_._._-_..._.__....._....._._..- _ . Address: . _ ._._ 12650 Ingenuity Drive Orlando, FL 32826 Phone Number: 877-596-8580 Fax Number: 407-737-5693 Contact Person: Customer Service E-Mail Address: EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you. and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may not 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. 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 W oodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 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 TIMES R\ 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 Cumberland Counhv 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 TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LA)ATSUIT 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 LAIA'. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY Cumberland County ;KMh CERTIFIE D MAI L ? 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U0o amid 'selgenleA 0 30NbHT18Ni ON 0 e;ou sl Haw pailwoo a d Mewi 10 LeW Pa4Wa . r o° :saapulweht lusuodwl y IU8AilaP 36 P10081 y a iollelyluepl enblun H a ldleoel 6ulllew y a o Md eft PGIII 83 O N i 1? LL r m co 1° co a m- 01 ?Wt4 f?? &A( kw-wa l 1L41 - C0"' - - Plaintiff(s) Defendant(s) FORM 1 IN THE COURT OF COMM ON PLEAS Oil, CUMBERLAND COUNTY PENNSYLV ?hIIAj = _, . t . t t O'? -a 3,10 Civil NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) day's of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court , which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled. you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. -0-5 1 Date Respe fully submitted: 4 [Signature of ounsel or pA= M. BFI.11nt^ ESQUIRA PA IU JUJU91 FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # State: Zip: Yes ? No ? Listing date: Price: $_ Realtor Phone:_ Yes ? No ? BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider Your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: Borrower name(s): Property Address: City: Is the property for sale? Realtor Name: Borrower Occupied? Mailing Address (if different) City: Phone Numbers: Email: # of people in household: State: Zip: Home: Cell: Office: Other: How long? Mailing Address: City: _ Phone Numbers: Home: Cell: Email: # of people in household: First Mortgage Lender: _ Type of Loan: Loan Number: Second Mortgage Lender: Type of Loan: Loan Number: Office: Other: State: Zip: How long? Date You Closed Your Loan: Total Mortgage Payments Amount: $ Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ? No ? Included Taxes & Insurance: If yes, provide names, location of court, case number & attorney: Assets Amount Owed: Value: Home: $ $ Other Real Estate: $ _ $ Retirement Funds: $ _ $ Investments: $ _ $ Checking: S $ Savings: $ $ Other: $ $ Automobile #1: Model: Amount owed: _ Value: Automobile #2: Model: Amount owed: Value: Other transportation (automobiles, boats, motorcycles): Model: Year: Amount owed: Value Year: Year: Monthly Income Name of Employers: 1. Additional Income Description (not wages): 1. monthly amount: 2 monthly amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2" Mortgage Utilities Car Payment(s) Cando/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/re airs _ Other prop. payment Install. Loan Payment Cable TV Child Su ort/Alim. Spending Money Day/Child Care/Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ? No ? If yes, please provide the following information: Counseling Agency: _ Counselor: Phone (Office): Fax:_ Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ? No ? If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ? No ? If yes, please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name).- Servicing Company (Name): Contact: Phone: Phone: I!We, , authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I/we am/are under no obligation to use the services provided by the above named Borrower Signature Date Co-Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: V Proof of income Past 2 bank statements V Proof of any expected income for the last 45 days Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation 1 (hardship letter) V Listing agreement (if property is currently on the market) FORM 3 IN THE COURT OF COMMON PLEAS OF -?u5r (?dn^Qon'? : CUMBERLAND COUNTY.. PENNSYLVANIA Plaintiff(s) vs. Defendant(s) CIVIL REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated .2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; ?. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion .Program" and has taken. all of the steps required in that Notice to be eligible to participate in a court-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Signature of Defendant's Counsel/Appointed Legal Representative Signature of Defendant Signature of Defendant Date Date Date J L. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE - ID #04302 a i'p U v' STUART WINNEG, ESQUIRE - ID #45362 if` f ? v -OUNT`?' LORRAINE DOYLE, ESQUIRE - ID #34576 `I ESA i ALAN M. MINATO, ESQUIRE - ID #75860 PAIGE M. BELLINO, ESQUIRE - ID#309091 HARRY B. REESE, ESQUIRE - ID#310501 AMY GLASS, ESQUIRE - ID#308367 KASSIA FIALKOFF, ESQUIRE - ID#310530 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 yleadings(a-),udren.com DEUTSCHE BANK NATIONAL TRUST COMPANY As COURT OF COMMON Trustee for the registered holder of Soundview Home Loan PLEAS Trust 2006-EQ1 Asset-Backed Certificates, Series 2006-EQ1 CIVIL DIVISION 1661 Worthington Road #100 CUMBERLAND West Palm Beach, FL 33409 County Plaintiff n UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL NO. a PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER GARY R. WILBUR, DECEASED 27 STONEHEDGE DRIVE CARLISLE, PA 17015 MICHAEL WILBUR, KNOWN HEIR OF GARY R. WILBUR 27 STONEHEDGE DRIVE CARLISLE, PA 17015 CHRISTINE BROWN, KNOWN HEIR OF GARY R. WILBUR 27 STONEHEDGE DRIVE CARLISLE, PA 17015 GARY R. WILBUR, DECEASED 797 SPRAGUE RD. MEMPHIS, NY 13112 LYNDELL D. WILBUR 797 SPRAGUE RD. MEMPHIS, NY 13112 Defendant(s) TO THE PROTHONOTARY: ENTRY OF APPEARANCE Kindly enter the appearance of the following counsel: Mark J. Udren, Esquire; Stuart Winneg, Esquire; Lorraine Doyle, Esquire; Alan M. Minato, Esquire, Sherri J. Braunstein, Esquire; Paige M. Bellino, Esquire; Harry B. Reese, Esquire; Amy Glass, Esquire; Kassia Fialkoff, Esquire; Elizabeth L. Wassall, Esquire on behalf of the Plaintiff, in the above-captioned matter. UDR LAW OFFICES, P.C. BY. i PAIGE M. BELLINO, ESQUIRE PA ID 309091 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy ,:)P? - T. - 't;F ' 1, -EL ti I T-, :F '- tA "OTHOIN )TA6Yi Richard W Stewart Solicitor 20i? MAY -3 AM 9: 13 CUM ERLA140 CCM f `s' I'EW4SYLWANIA Deutsche Bank National Trust Company Case Number vs. Michael Wilbur (et al.) 2012-2340 SHERIFF'S RETURN OF SERVICE 04/23/2012 06:45 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on April 23, 2012 at 1845 hours, he served a true copy of the within Complaint in Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program, upon the within named defendant, to wit: Michael Wilbur, by making known unto himself personally, at 27 Stonehedge Drive, Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to him personally the said true and correct copy of the same. 29?4 STEPH N BENDER, DEPUTY 04/26/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Christine Brown, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program as not found as to the defendant Christine Brown. Request for service at 27 Stonehedge Drive, Carlisle, Pennsylvania 17015 the Defendant was not found. Deputies were advised, Christine Brown currently resides at 797 Sprague Road, Memphis, New York 13112 and she is the Power of Attorney for her Mother Lyndell D. Wilbur. 04/26/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on April 26, 2012 at 0840 hours, he was unable to serve a true copy of the within Complaint In Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program, upon the within named defendant, to wit: Lyndell D. Wilbur. Deputies were advised, Lyndell D. Wilbur currently resides at Forest Park Nursing Home. SHERIFF COST: $71.00 April 26, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Deutsche Bank National Trust Company as Trustee for the registered holder of Soundview Home Loan Trust 2006-EQ1 Asset-Backed Certificates, Series 2006-EQ1 Plaintiff V. Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right Title or Interest From or Under Gary R. Wilbur, Deceased Michael Wilbur, Known Heir of Gary. R Wilbur Christine Brown, Known Heir of Gary R. Wilbur Gary R. Wilbur, Deceased Lyndell D. Wilbur Defendant(s) NO. 12-2340 Civil ORDER f' AND NOW, this /'Z Day of J W4, 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 Gary R. Wilbur, Deceased; and Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right Title or Interest From or Under Gary R. Wilbur, 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: 27 Stonehedge Drive, Carlisle, PA 17015, which is the subject matter of this action in Mortgage Foreclosure. BY THE COURT: J. %/ (Areo &uz C}F':ces PC ( Opy A a, ILOW 1-14- MJU#11080294-2 (Wilbur) ( RROTHONOTARY UDREN LAW OFFICES, P.C. 2012 AUG -3 AM 10: 01TTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENT ?l.?kNfl G ?,I,!NTY 111 WOODCREST ROAD, SUIT NNSYl.VANIA CHERRY HILL, NJ 08003-3620 856-669-5400 DEUTSCHE BANK NATIONAL TRUST COMPANY As Trustee for the registered holder of Soundview Home Loan Trust 2006-EQ1 Asset-Backed Certificates, Series 2006-EQ1 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. 12-2340-CIVIL V. LYNDELL D. WILBUR; ET AL Defendant(s) MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, moves this Honorable Court for an Order directing service of Complaint in Mortgage Foreclosure upon Defendant(s): CHRISTINE BROWN, KNOWN HEIR OF GARY R. WILBUR, AND L D. WILBUR, by regular mail and certified mail, and by posting the mortgaged premises and in support avers the following: 1. Process was unable to be served at the then last known address of said Defendant(s) follows: CHRISTINE BROWN, KNOWN HEIR OF GARY R. WILBUR 27 STONEHEGDE DRIVE CARLISLE, PA 17015 LYNDELL D. WILBUR 27 STONEHEGDE DRIVE CARLISLE, PA 17015 A copy of the Return of Service is attached hereto as Exhibit "A". 2. Process was unable to be served at the then last known address of said Defendant(s) follows: CHRISTINE BROWN, KNOWN HEIR OF GARY R. WILBUR 797 SPRAGUE ROAD MEMPHIS, NY 13112 LYNDELL D. WILBUR 797 SPRAGUE ROAD MEMPHIS, NY 13112 A copy of the Return of Service is attached hereto as Exhibit "B". 3. Process was unable to be served at the then last known address of said Defendant(s) follows: CHRISTINE BROWN, KNOWN HEIR OF GARY R. WILBUR 207 BARRINGTON LANE BOURBONNAIS, IL 60914-1673 LYNDELL D. WILBUR 207 BARRINGTON LANE BOURBONNAIS, IL 60914-1673 A copy of the Return of Service is attached hereto as Exhibit "C". 4. Pursuant to Pa.R.C.P. 430, Plaintiff made a Good Faith Investigation, the thereof being attached hereto as Exhibit "D". 5. Said investigation was unable to determine an alternate address for said Defendant(s) 6. The last known address of Defendant(s) is as set forth in the attached Exhibits. WHEREFORE, Plaintiff prays and respectfully requests that this Honorable Court an Order pursuant to Pa.R.C.P. 430 directing service of the Complaint in Foreclosure upon said in paragraph 1, by regular mail and certified mail, and by posting mortgaged premises. UDREN LAW OFFICES, P.C. BY: Attorneys for Plaintiff _ ?lO V-)C? ?3 , -Leh i SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff , tit Gssnbtr,?. ??a}tit4 »4 Jody S Smith r Chief Deputy t `- , » F Richard W Stewart Solicitor OFFICE OF THE $kMERI"F Deutsche Bank National Trust Company vs. Michael Wilbur (et al.) Case Number 2012-2340 SHERIFF'S RETURN OF SERVICE 04/23/2012 06:45 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on April 23, 2012 at 1845 hours, he served a true copy of the within Complaint in Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program, upon the within named defendant, to wit: Michae Wilbur, by making known unto himself personally, at 27 Stonehedge Drive, Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to him personally the said true and correct copy of the same. STEPH N BENDER, DEPUTY 04/26/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Christine Brown, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program as not found as to the defendant Christine Brown. Request for service at 27 Stonehedge Drive, Carlisle, Pennsylvania 17015 the Defendant was not found. Deputies were advised, Christine Brown currently resides at 797 Sprague Road, Memphis, New York 13112 and she is the Power of Attorney for her Mother Lyndell D. Wilbur. 04/26/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on April 26, 2012 at 0840 hours, he was unable to serve a true copy of the within Complaint In Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program, upon the within named defendant, to wit: Lyndell D. Wilbur. Deputies were advised, Lyndell D. Wilbur currently resides at Forest Park Nursing Home. SHERIFF COST: $71.00 SO ANSWERS, April 26, 2012 RON R ANDERSON, SHERIFF ic; GaiMysinte Sheriff, 7eimson. inc. ! P1 P /-V T ,/ Deutsche Bank National Trust Company, as Trustee, et. al., Plaintiff(s) VS. Gary R. Wilbur, Deceased, et. al., Defendant(s) UDREN LAW OFFICES Ms. Courtnev Nivers I I I Woodcrest Rd., Ste. 200 Cherry Hill. NJ 08003-3620 service of rrocess uy APS International, ?td. 1-800-328-71711 APS International Plaza 7800 Glenroy Road Minneapolis, MN 55439-3122 APS File #: 116304-0001 AFFIDAVIT OF DUE AND DILIGENT ATTE T Service of Process on: --Christine rown Court Case No. 11-2340 Customer File: C11080294-1 State of:K42u1 01' _liss. County of: 0y)Q"dL1 Name of Server: fo r r , undersigned, being duly sworn, deposes and say: that at all times mentioned herein, a as of legal age and was not a party to this action: Documents Served: the undersigned attempted to serve the documents described as: Complaint in Mortgage Foreclosure w/ Notice of Residential Mortgage Foreclosure Diversion Proeram Service of Process on: The undersigned attempted to serve the documents on Christine Brown and after due and diligent efforts, was unable to effect service. Attempts: The following is a list of the attempts made to effect service: Dates/lime/Address Attempted: 797 Sprague Road, Memphis NY 13112 Reason for Non-Service: N b one f f•-WQi +hp- wr LL-+ cL to Dates/rime/Address Reason for Is 51(112- c -? q.?41`/l?M. X12{!2 ?i l'S5?M, 5f31(2at(o45PP? (vA,n 51511 X51.11 Dates/Time/Address Attempted: Reason for Non-Service: Based upon the above stated facts. Affiant believes the defendant is avoiding service. Signature of Server: Undersigned declares under penalty of perjury that the foregoing is true and correct. Signature of Server APS International, Ltd. SubsC cjlbed and sworn to before me till., day of 20 Notary Public (Commission Ex ires) Sherman McDoneil Notary Public, State of New York No. 01 MC6247919 Qualified in Onondaga County Commission Expires Sept. 6, 2015 ft EXHIBIT B Service of Process by Deutsche Bank National Trust Company, as Trustee, et. al., Plaintiff(s) VS. Gary R. Wilbur, Deceased, et. al., Defendant(s) UDREN LAW OFFICES Ms. Courtnev Mvers I I I Woodcrest Rd., Ste. 200 Cherry Hill, NJ 08003-3620 APS International, ? td. . QW APS File #: 116304-0001 AFFIDAVIT OF DUE AND DILIGENT ATTEMPT Service of Process on: --Lyndell D. N Court Case No. 1: I Customer File: C1108t1294-1 ----------------- State SS. County of: CjDAnCbqa Name of Server: undersi ned bein dul sworn de oses and sa s TR0) L g g y p y that at all times mentioned herein, *S was of legal age and was not a party to this action; Documents Served the undersigned attempted to serve the documents described as: Complaint in Mortgage Foreclosure w/ Notice of Residential Mortgage Foreclosure Diversion Program Service of Process on: The undersigned attempted to serve the documents on Lyndell D. Wilbur Attempts: Dates/Time/Address Reason for IN and after due and diligent efforts, was unable to effect service. The following is a list of the attempts made to effect service: 797 SDraeue Road, Memphis, NY 13112 Dates/rime/Address Attempted: Reason for Non-Service: ., Dates/Time/Address Attempted: Reason for Non-Service. I] Based upon the above stated facts, Affiant believes the defendant is avoiding service. Signature of Server: Undersigned declares under penalty of perjury Subsc` lbed and sworn to before me this that the foregoing is true and correct. ` `M day of MGV 20 Signature of Server Notary Public (Commission Exl APS International, Ltd. Sherman McDonell Notary Public. State of New York No 01 MC6247919 Qualified in Onondaga County Commission Expires Sept. 6. 2015 1-800-328-7171 APS International Plaza 7800 Glenroy Road Minneapolis, MN 55439-3122 AK. Deutsche Bank National Trust Company, as Trustee, et. al., Plaintiff(s) ,S. Gary R. Wilbur, Deceased, at. al., Defendant(s) UDREN LAW O" ICES Ms. Courtney Myers 111 Woodcrest Rd., Ste, 200 Cherry Hill, NJ 08003-3620 Customer File: 0110802%-1 Service of Process by - ?? APS International, 1-800-329-7171 APS International Plaza 7800 Glearoy Road Minneapolis, MN SW9-3122 APS File N: 117278.0601 AFFIDAVIT OF DUE AND DILIGENT A' Service of Process on: --Lyndell D. Court Case No. 12-23. ------...,..------- -------- ------ --------- - - - State of: Sl l1nD15 ) ss. County of: Lft?a?g ) Name of Se'rvve'r?'?' ,ice G?.•? , undersigned, being duly sworn, deposes and says that at all times ns"oned herein, s/he was of legal age and was not a party to this action; Documents Served: the undersigned attempted to serve the documents described as: Complaint V Mortgage Foreclosure w/ Notice of Residential Mortgage Foreclosure Diversion Program Service of Process one The undersigned attempted to serve the documents on Lyndell D. Wilbur and after due and diligent efforts, was unable to effect service. Attempts: The following is a list of the attempts made to effect service: Dates/l7mdAddress Attempted: 20713arrington Lane, Bourbonnais, IL 60914-1673 - CYO, . Reason for Non-Serriee: Dsteslflme/Addreu Attempted:- p? - • e 1? 1 1 Reason for Non-Service: 1111- 1-k e ST1P? A'% V? &4 `Ti Ll ? Le[1e_ev - J a U i A 7T ?*k i f SL Datesll'ime/Address Attempted: ' , ,t Reason for Non&rvicc: ?O%Z (-.] Based upon the stated facts, Affiant believes the defendant is avoiding service. Signature of Server: ri gne ecl s under penalty urY Subscrib and sworn to before me this /? °?Pert / f going true and correct. y of ?-?- , 20, (Commission MIAL MLyll ?- ?? - EXHIBIT C Service of Process by Deutsche Bank National Trust Company, as TrestM et. al., ``?, APS International, Plaintiff(s) vs. A 1-800-328-7171 Gary R. Wilbur, Deceased, at. al., Defendant(s) APS Datarnational Plaza UDREN LAW ORFTC Ms. Courtney Myers 111 Woodcrat Rd., Ste. 200 Cherry Will, NJ 08003?mx Customer File: C11 94-1 State of. Sil IAlOts Countyof: ©1.20t l Name or Server: 'Q.lAn Lit at all 7800 Glenroy Road Minneepolla, MN 55439-3122 APS File #: 1172784001 AFFIDAVIT OF DUE AND DILIGENT ATTED Service of Process on: --Christine Brown, Known Heir of Gary R. N Court Case No. 12-2341 - - - - - - - - - - - - - - - -- - + , undersigned, being duly sworn, deposes and says Toned herein, s/he was of legal age and was not a party to this action; Documents Served: the undersigned attempted to serve the documents described as: c4plaint in Mortgage Foreclosure wl Notice of Residential Mortgage Fo*losure Diversion Program service of Process on: The undersigned attempted to serve the documents on Christine Brown, Known Heir of Gary It Wilbur an4 after due and diligent efforts, was unable to effect service. Attempts: T following is a list of the attempts made to effect service: Datea/D"use/Addren Artempted: 207 Barrington Lane, Bourbonnais, IL 60914-1673 ? Rewon for Non Serrlcc: l ' }? Dates/Tlme/Addreu Attempted: js A& knew-.7m Yld ST C Ql)d Reason for Non-Service: }. f? y t DatWrimdAddressAnempted k?iASatRI mr?&A.,?.?G11<1t")s nnT 1?' ? Slh+?h u Reason for Non-Service: ?71)5 gr10i. &rd 1S nQj ht ki cd AD d???i 6y upon the above red facts, Affiant believes the defendant is avoiding service. Signature of rver: Und ed deal s raider pen of perjury Subscribed and sworn to before me this at fore o' true and coffee /5-4ay of - wwy1Z 20, tre of Serr? ?''""? N c (Commission Fa International, Ltd. ap" UL CmiaMODUMACAL w?Rl?1'IIAC asyl?lgN IN.11, •f- i IN THE COURT OF COMMON PLEAS OF CUMBERLAND CO., PENNSYLVANIA Docket No. OCWEN LOAN SERVICING, LLC ,Plaintiff(s) - against - CHRISTINE BROWN, KNOWN HEIR OF GARY R. WILBUR, ET AL ,Defendant(s) AFFIDAVIT OF DUE DILIGENT INQUIRY I, THE UNDERSIGNED AM AND WAS ON THE DATES HEREIN MENTIONED, OVER THE AGE OF EIGHTEEN YEARS AND NOT A PARTY TO THE ACTION, ATTEMPTED TO LOCATE THE FOLLOWING FOR SERVICE OF PROCESS: CERT. OF DILIGENT INQUIRY FOR CURRENT ADDRESS. AND THAT AFTER DUE AND DILIGENT SEARCH AND INQUIRY AT THE RESIDENCE: 27 STONEHEDGE DRIVE CARLISLE PA 17015 ALTERNATE ADDRESS: 797 SPRAGUE ROAD MEMPHIS NY I HAVE ATTEMPTED TO LOCATE THE FOLLOWING NAMED: CHRISTINE BROWN, KNOWN HEIR OF GARY R. WILBUR THE FOLLOWING INFORMATION IS CURRENTLY AVAILABLE PER PERMISSIBLE INQUIRY: 06/08/12 CERT. OF DILIGENT INQUIRY BEING PROCESSED. 06/08/12 DILIGENT INQUIRY INDICATES AS FOLLOWS:-- SS#: XXX-XX-X505 NAME: CHRISTINE HEATHER BROWN AKA CHRISTINE WILBUR ADD: 797-799 SPRAGUE ROAD MEMPHIS, NY 13112-9742 ALT. ADD: 207 BARRINGTON LANE BOURBONNAIS, IL 60914-1673 DOB: 03/27/1972 TELE#: 815-933-3670 LISTED TO DAVID WILBUR AT 207 BARRINGTON LANE, BOURBONNAIS, IL. 06/08/12 PER DILIGENT INQUIRY, CHRISTINE H. BROWN WITH DOB 03/27/1972 IS A REGISTERED VOTER AT 797 SPRAGUE ROAD, MEMPHIS, NY 13112 06/06/12 THE ABOVE IS THE MOST CURRENT INFORMATION ON FILE FOR THIS SUBJECT AT THIS TIME. 06/08/12 IF DGR CAN BE OF FURTHER ASSISTANCE IN THIS MATTER, PLEASE ADVISE. DGR - Th 1359 Littleton File # 11080294-1 (973) 4 ed on next page urce for Legal Supp rt Morris Plains, N 707950-3000 X I BIT D! 700 Fax. (973) 403-9222 Work Order # 871 26 IN THE COURT OF COMMON PLEAS OF CUMBERLAND CO., PENNSYLVANIA Docket No. OCWEN LOAN SERVICING, LLC ,Plaintiff(s) - against - CHRISTINE BROWN, KNOWN HEIR OF GARY R. WILBUR, ET AL ,Defendant(s) SEARCHER: ANGELA D. RICHARDSON SWORN AND SUBSCRIBED TO BEFORE ME THIS DAY OF 2 0 LOUIS R. CIFELLI NOTARY PUBLIC OF NEW JERSEY My Commission Expires May 2, 2016 DGR - The Source for Legal Support 1359 Littleton Road, Morris Plains, NJ 07950-3000 File # 11080294-1 (973) 403-1700 Far. (973) 403-9222 Work Order # 87 826 IN THE COURT OF COMMON PLEAS OF CUMBERLAND CO., PENNSYLVANIA Docket No. 1 LOAN SERVICING, LLC ,Plaintiff(s) - against - CHRISTINE BROWN, KNOWN HEIR OF GARY R. WILBUR, ET AL ,Defendant(s) AFFIDAVIT OF DUE DILIGENT INQUIRY I, THE UNDERSIGNED AM AND WAS ON THE DATES HEREIN MENTIONED, OVER THE AGE OF EIGHTEEN YEARS AND NOT A PARTY TO THE ACTION, ATTEMPTED TO LOCATE THE FOLLOWING FOR SERVICE OF PROCESS: CERT. OF DILIGENT INQUIRY FOR CURRENT ADDRESS. AND THAT AFTER DUE AND DILIGENT SEARCH AND INQUIRY AT THE RESIDENCE: 27 STONEHEDGE DRIVE CARLISLE PA 17015 ALTERNATE ADDRESS: 797 SPRAGUE ROAD MEMPHIS NY I HAVE ATTEMPTED TO LOCATE THE FOLLOWING NAMED: LYNDELL D. WILBUR THE FOLLOWING INFORMATION IS CURRENTLY AVAILABLE PER PERMISSIBLE INQUIRY: 06/08/12 06/08/12 SS#: NAME: ADD: ALT. ADD: DOB: TELE#: 06/08/12 06/08/12 06/08/12 e-t-' DGR Y'Th Source for Legal Support Continued on next page 1359 Littli't'bn Road, Morris Plains, NJ 07950-3000 File # 11080294-1 (973) 403-1700 Fax (973) 403-9222 Work Order # CERT. OF DILIGENT INQUIRY BEING PROCESSED. DILIGENT INQUIRY INDICATES AS FOLLOWS:-- XXX-XX-X535 LYNDELL D. WILBUR 797 SPRAGUE ROAD MEMPHIS, NY 13112-9742 27 STONEHEDGE DRIVE CARLISLE, PA 17013-4427 09/13/1943 TELEPHONE DIRECTORY, PHONE DISC AND DIRECTORY ASSISTANCE INDICATES NO LISTINGS FOUND. PER DILIGENT INQUIRY, LYNDELL WILBUR WITH DOB 09/13/1943 IS A REGISTERED VOTER IN CUMBERLAND COUNTY, PA. THE ABOVE IS THE MOST CURRENT INFORMATION ON FILE FOR THIS SUBJECT AT THIS TIME. IF DGR CAN BE OF FURTHER ASSISTANCE IN THIS MATTER, PLEASE ADVISE. "I--- 871828 871828 IN THE COURT OF COMMON PLEAS OF CUMBERLAND CO., PENNSYLVANIA Docket No. OCWEN LOAN SERVICING, LLC ,Plaintiff (s) - against - CHRISTINE BROWN, KNOWN HEIR OF GARY R. WILBUR, ET AL ,Defendant(s) SEARCHER: ANGELA D. RICHARDSON SWORN AND SUBSCRIBEDTO BEFORE ME THIS DAY OF 2 `1 rr' I-Ile L00IS R. CIFELLi NOTARY PUBLIC OF NEW JERSEY toy Commission Expires May 2, 2016 DGR - The Source for.Legal Support 1359 Littleton Road, Morris Plains, NJ 07950-3000 File # 11080294-1 (973) 403-1700 Fax (97.3) 403-9222 Work Order # 87 828 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 DEUTSCHE BANK NATIONAL TRUST COMPANY As Trustee for the registered holder of Soundview Home Loan Trust 2006-EQ1 Asset-Backed Certificates, Series 2006-EQ1 Plaintiff V. LYNDELL D. WILBUR; ET AL Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. 12-2340-CIVIL MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (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 motion shall be accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. NOTE: A sheriffs return of "not found" or the fact that a defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). Notice of intended adoption mailed to last known address requires a "good faith effort" to discover the correct address. Adoption of Walker, 468 Pa. 165, 360 A2d 603 (1976). An illustration of a good faith effort to locate the defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and employers of the defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As set forth in the Return of Service marked Exhibit "A", "B", and "C", the Sheriff Process Server has been unable to serve the following Defendant(s) at their last known a& A good faith effort to discover the whereabouts of the Defendant(s) has been made as evi by the attached Affidavit of Good Faith Investigation marked Exhibit "D". WHEREFORE, Plaintiff prays and respectfully requests service of the Complaint Mortgage Foreclosure upon Defendant(s) by regular mail and certified mail, and by posting mortgaged premises. UDREN LAW OFFICES, P.C. BY: < v e-vw4ayj Attorneys for Plain iff in Q L UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 DEUTSCHE BANK NATIONAL TRUST COMPANY As Trustee for the registered holder of Soundview Home Loan Trust 2006-EQI Asset-Backed Certificates, Series 2006-EQ1 Plaintiff V. LYNDELL D. WILBUR; ET AL Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. 12-2340-CIVIL CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was served by U.S. mail on each of the attached parties or their attorneys this 3( day of July 2012. CHRISTINE BROWN, KNOWN HEIR OF GARY R. WILBUR 797 SPRAGUE ROAD MEMPHIS, NY 13112 LYNDELL D. WILBUR 797 SPRAGUE ROAD MEMPHIS, NY 13112 Udren Law Offices, P.C. Attorney for Plaintiff By: Vrl ID ?9ta -~~ac'~ya ('4vil CHRISTINE BROWN, KNOWN HEIR OF GARY R. WILBUR 797 SPRAGUE ROAD MEMPHIS, NY 13112 LYNDELL D. WILBUR 797 SPRAGUE ROAD MEMPHIS, NY 13112 A copy of the Return of Service is attached hereto as Exhibit "B". 3. Process was unable to be served at the then last known address of said Defendant(s) as follows: --, ..,, ...^ ~ ~ CHRISTINE BROWN, KNOWN HEIR OF GARY R. WILBUR ~ ~ ~. ~ ''- 207 BARRINGTON LANE ~~ cc-~ - BOURBONNAIS, IL 60914-1673 ~:~ .,,,3 c~ , ~ ~~~ -a ~ LYNDELL D. WILBUR ~ ~~.-~ ~ -- ~ 207 BARRINGTON LANE ~ ~°;; ca , ~ ~, , BOURBONNAIS, IL 60914-1673 =-~ A copy of the Return of Service is attached hereto as Exhibit "C". 4. Pursuant to Pa.R.C.P. 430, Plaintiff made a Good Faith Investigation, the report thereof being attached hereto as Exhibit "D". 5. Said investigation was unable to determine an alternate address for said Defendant(s). 6. The last known address of Defendant(s) is as set forth in the attached Exhibits. 7. No other issue has been ruled upon in this same or related matter. 8. Defendants are not represented by counsel and concurrence is not needed. WHEREFORE, Plaintiff prays and respectfully requests that this Honorable Court enter an Order pursuant to Pa.R.C.P. 430 directing service of the Complaint in Mortgage Foreclosure upon said in paragraph 1, by regular mail and certified mail, and by posting the mortgaged premises. UDREN AW OFFICE , P.C. BY: Attorneys for Plaintiff Elena B. FkhfMK, ~i PA ID 209197 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL TRIAL DIVISION DEUTSCHE BANK NATIONAL TRUST COMPANY As Trustee for the registered holder of Soundview Home Loan Trust 2006-EQI Asset-Backed Certificates, Series 2006-EQI Plaintiff LYNDELL D. WILBUR; ET AL Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. 12-2340-CIVIL : 22 ORDER PERMITTING SPECIAL SERVICE AND NOW, this -2/Jday ope?d /` , 2012, upon consideration of Plaintiffs Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage Foreclosure and all subsequent pleadings on Defendant(s), CHRISTINE BROWN, KNOWN HEIR OF GARY R. WILBUR, LYNDELL D. WILBUR, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Complaint in Mortgage Foreclosure and all subsequent pleadings by posting the mortgage premises at: 27 Stonehedge.Drive, Carlisle, PA 17015 And by mailing by certified mail and regular mail to the last known address of Defendant(s) as follows: CHRISTINE BROWN, KNOWN HEIR OF GARY R. WILBUR 797 SPRAGUE ROAD MEMPHIS, NY 13112 LYNDELL D. WILBUR 797 SPRAGUE ROAD MEMPHIS, NY 13112 La ) Z??e e.5 BY T COURT: J. */-al bg '10f, Rk ( . UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER lll WOODCREST ROAD, SUITE 200 CHERRY HILL, N,I 08003-3620 856-669-5400 DEUTSCHE BAND NATIONAL TRUST COMPANY As Trustee for the registered holder of Soundview Home Loan Trust 2006-EQl Asset-Backed Certificates, Series 2006-EQ1 Plaintiff ~. LYNDELL D. WILBUR; et al Defendant(s) ATTORNEY FOR PLAINTIFF COUF:T OF COMr/ION PLEAS CIVIL DIVISION Cumberland County NO. 12-2340-CIVIL PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint on the above-captioned mater. DATE: ~, ~~~ ~~`-~:..~~~ ~ ~~~"~~ ~ ~~ ~~'"~ ~ UDREN LAW OFFICES, P.C. ~' ° ~ , BY•_ _ Att Pl nt~~ ,~- FiARRY i~. ?;FSF, ';S~IUir:; E~~; iu ::~o~a1 (~ C~~ 38 ~ S~ ~~ ~~aa$a Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Deutsche Bank National Trust Company vs. Michael Raymond Wilbur (et al.) _~,, `~F SHERIFF'S RETURN OF SERVICE . I .. is , ~.~1'ICJlrk.~ii~h~rf~?~ 1.,133.'l~ I Case Number 2012-2340 10/25/2012 09:10 AM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on October 25, 2012 at 0910 hours, he served a true copy of the within Complaint in Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program, upon the within named defendant, to wit: Christine Brown, pursuant to order of court by posting the premises located at 27 Stonehedge Drive, Carlisle. Cumberland County, Pennsylvania 17015 with a true and correct copy according to law. RO ERT BITNER, DEPUTY 10/25/2012 09:10 AM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on October 25, <?012 at 0910 hours, he served a true copy of the within Complaint in Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program, upon the within named defendant, to wit: Lynclell D. Wilbur, pursuant to order of court by posting the premises located at 27 Stonehedge Drive, Carlisle. Cumberland County, Pennsylvania 17015 with a true and correct copy according to law. >'~~ix~~~~ ~ ~ 1~ RO ERT BITNEP,. DEPUTY SHERIFF COST 462.45 November 02. 201 SHERIFF'S OFFICE OF CUMBERLAND COUNTY SO ANSWERS, ,,~ % -~~' i RONf~Y R ANDERSON, SHERIFF UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 eleadiniWiDudren.com Deutsche Bank National Trust Company as : COURT OF COMMON PLEAS Trustee for the registered holder of ' CIVIL DIVISION Soundview Home Loan Trust 2006-EQ1 Cumberland County Asset-Backed Certificates, Series 2006-EQ1 Plaintiff V. a �. No. 12-2340-CIVIL Lyndell D. Wilbur; et al Defendant(s) NOTICE OF INTENT TO SERVE -y SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Deutsche Bank National Trust Company as Trustee for the registered holder of Soundview Home Loan Trust 2006-EQ1 Asset-Backed Certificates, Series 2006-EQ1, intends to serve a subpoena identical to the one that is attached to this notice. You have twenty(20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. UDREN LAW OFFICES, P.C. Date: March ��l , 2013 BY: Harry . Ree e, Esquire Pa. ID 310501 Attorney for Plaintiff C-ONP*40'N WEAL:"H OF PEENS` LV ANIA C`UNTY OF CUMBERL kND Plaintiff I=ileNo. vs. Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: � (Name of Person or Entity) Within twenty(20)days after service of this subpoena,you are ordered by the court to produce the following documents .o-r thingsp: j of Lyndelk , ,1 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD CHERRY HILL,NJ 08003 at (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena,together with the certificate of compliance,to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service,the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MA 1 ADDRESS: TELEPH SUPREME COURT ID# ATTORNEY FOR: B RT.j-(2 �l /g vt iv ion Date: Sea of the Court Deputy UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER Ill WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 p1eadings(a,)udren.com Deutsche Bank National Trust Company as = COURT OF COMMON PLEAS Trustee for the registered holder of CIVIL DIVISION Soundview Home Loan Trust 2006-EQ I Cumberland County Asset-Backed Certificates, Series 2006-EQI Plaintiff V. Lyndell D. Wilbur; et al Defendant(s) No. 12-2340-CIVIL CERTIFICATE OF SERVICE 1,the undersigned Attorney,hereby certify that I served or caused to be served true and correct copies of Plaintiffs NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO Pa.R.C.P. 4009.21 upon the following person(s)named herein at their last known address or their attorney of record. xxxxxx Regular First Class Mail Date Served: March A 12013 TO: Unknown Heirs, Successors,Assigns&All Persons, Michael Wilbur, Known Firms or Associations Claiming Right, Title or Interest Heir of Gary R. Wilbur from or Under Gary R. Wilbur, Deceased 27 Stonehedge Drive 27 Stonehedge Drive Carlisle, PA 17015 Carlisle, PA 17015 Christine Brown, Known Gary R. Wilbur, Deceased Lyndell D. Wilbur Heir of Gary R. Wilbur 797 Sprague Road 797 Sprague Road 27 Stonehedge Drive Memphis,NY 13112 Memphis,NY 13112 Carlisle, PA 17015 UDREN 4AW OFFICES,P.C. BY: Harry\E( Reese, Esquire Pa. ID 310501 Attorney for Plaintiff 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 Deutsche Bank National Trust Company as : COURT OF COMMON PLEAS Trustee for the registered holder of CIVIL DIVISION Soundview Home Loan Trust 2006-EQI Cumberland County c: Asset-Backed Certificates, Series 2006-EQ1 M=W � ;i m 5- Plaintiff > ko =-q C)No. 12-2340-CIVIL `•D Lyndell D. Wilbur; et al Defendant(s) CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 Deutsche Bank National Trust Company as Trustee for the registered holder of Soundview Home Loan Trust 2006-EQ1 Asset-Backed Certificates, Series 2006-EQ1, certifies that: (1) a notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) a copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) no objection to the subpoena has been received, and (4) the subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. Date: ' UDR LAW OFFICES, P.C. BY: H B Re se, Es ire Pa. ID 10501 Attorney for Plaintiff 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 Deutsche Bank National Trust Company as ': COURT OF COMMON PLEAS Trustee for the registered holder of € CIVIL DIVISION Soundview Home Loan Trust 2006-EQ1 € Cumberland County Asset-Backed Certificates, Series 2006-EQ1 Plaintiff V. Lyndell D. Wilbur; et al € No. 12-2340-CIVIL Defendant(s) CERTIFICATE OF SERVICE I, the undersigned Attorney, hereby certify that I served or caused to be served true and correct copies of Plaintiffs CERTIFICATE OF PREREQUISITE TO SERVE A SUBPOENA PURSUANT TO Pa.R.C.P.4009.22 upon the following person named herein at their last known address or their attorney of record. xxxxxx Regular First Class Mail Date Served: May , 2013 TO: Unknown Heirs, Successors,Assigns &All Persons, Michael Wilbur, Known Firms or Associations Claiming Right, Title or Interest Heir of Gary R. Wilbur from or Under Gary R. Wilbur, Deceased 27 Stonehedge Drive 27 Stonehedge Drive Carlisle, PA 17015 Carlisle, PA 17015 Christine Brown, Known Gary R. Wilbur, Deceased Lyndell D. Wilbur Heir of Gary R. Wilbur 797 Sprague Road 797 Sprague Road 27 Stonehedge Drive Memphis,NY 13112 Memphis,NY 13112 Carlisle, PA 17015 UDR N L W OFFICES, P.C. BY: Harry Re e, Esquire Pa. ID 310501 Attorney for Plaintiff COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Plaintiff File No. VS. Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCCOOVVERY PURSUANT �"Iul<j TO RULE 4009.22 TO: �J ( �, '` (f V�al (Name of Person or Entity) Within twenty(20)days after service of this subpoena,you are ordered by the court to produce the following documents or things: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD CHERRY HILL, NJ 08003 at (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena,together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service;the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: �f •1 ADDRESS: TELEPH SUPREME COURT m# ATTORNEY FOR: B URT. ,., �� vi iv• ion Date:_ Seallof the Court Deputy UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 pleadings @udren.com Deutsche Bank National Trust Company As COURT OF COMMON PLEAS Trustee for the Registered Holder of CIVIL DIVISION Soundview Home Loans Trust 2006-EQ1 Cumberland County Asset-Backed Certificates, Series 2006-EQ1 �? • Fri z j-r.�'T7 -. r~ Plaintiff v▪,y r - ' co c�' r "= 1 V. Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming NO. 12-2340 Civil -< Right, Title or Interest From or Under Gary R. Wilbur, Deceased Michael Wilbur, Known Heir of Gary R. Wilbur Christine Brown, Known Heir of Gary R. Wilbur Gary R. Wilbur, Deceased Lyndell D. Wilbur Defendants MOTION FOR LEAVE TO FILE AN AMENDED COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, Deutsche Bank National Trust Company As Trustee for the Registered Holder of Soundview Home Loans Trust 2006-EQ1 Asset-Backed Certificates, Series 2006-EQ1,by its Counsel, Udren Law Offices, P.C., and through the undersigned Attorney, respectfully requests that this Honorable Court enter an Order granting Plaintiff leave to file its Amended Complaint in Mortgage Foreclosure, for the following reasons: 1. Plaintiff's original Complaint in Mortgage Foreclosure was filed on April 16, 2012. 2. Plaintiff desires to amend its Complaint in Mortgage Foreclosure in order to correct the amounts claimed due and by naming the deceased Defendant's estate and its representatives as Defendant's in the Complaint: a) Gary R. Wilbur, Last Record Owner; b) Lyndell D. Wilbur, Last Record Owner c) Michael Wilbur, Known Heir of Gary R. Wilbur and Lyndell D. Wilbur; d) Christine Brown, Known Heir of Gary R. Wilbur and Lyndell D. Wilbur; e) Unknown Heirs, Successors, Assigns and all Persons, Firms or Associations Claiming Right, Title or Interest from or Under Gary R. Wilbur, Deceased; and f) Unknown Heirs, Successors, Assigns and all Persons, Firms or Associations Claiming Right, Title or Interest from or Under Lyndell D. Wilbur, Deceased 3. A true and correct copy of the verified Amended Complaint in Mortgage Foreclosure that Plaintiff seeks leave to file is attached hereto as Exhibit "A". WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant the Plaintiff leave to file its Amended Complaint in Mortgage Foreclosure. Respectfully submitted, UDREN LAW OFFICES, P.C. BY: Ha W:. Reese, Esqu' - PAID # 310501 / Attorney for Plaintiff UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadingsAudren.com DEUTSCHE BANK NATIONAL TRUST COURT OF COMMON PLEAS COMPANY As Trustee for the registered holder of CIVIL DIVISION Soundview Home Loan Trust 2006-EQ1 Asset- CUMBERLAND County Certificates,Series 2006-EQ1 tY C/O Ocwen Loan Servicing,LLC 1661 Worthington Road Suite 100 NO. 12-2340-CIVIL West Palm Beach,FL 33409 Plaintiff v. GARY R.WILBUR,LAST RECORD OWNER 797 SPRAGUE RD. MEMPHIS,NY 13112 LYNDELL D.WILBUR,LAST RECORD OWNER 207 BARRINGTON LANE BOURBONNAIS,IL 60914-1673 MICHAEL WILBUR,KNOWN HEIR OF GARY R.WILBUR AND LYNDELL D.WILBUR 27 STONEHEDGE DRIVE CARLISLE,PA 17015 CHRISTINE BROWN,KNOWN HEIR OF GARY R.WILBUR AND LYNDELL D.WILBUR 207 BARRINGTON LANE BOURBONNAIS,IL 60914-1673 UNKNOWN HEIRS,SUCCESSORS,ASSIGNS AND ALL PERSONS,FIRMS OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER GARY R. WILBUR,DECEASED 27 STONEHEDGE DRIVE CARLISLE,PA 17015 UNKNOWN HEIRS,SUCCESSORS,ASSIGNS AND ALL PERSONS,FIRMS OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER LYNDELL D. WILBUR,DECEASED 27 STONEHEDGE DRIVE CARLISLE,PA 17015 Defendant(s) EXHIBIT A AMENDED COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. 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 provisions 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 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 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 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 Plaintiffs favor: Assignor:Mortgage Electronic Registration Systems,Inc.,as nominee for Equifirst Corporation Assignee: DEUTSCHE BANK NATIONAL TRUST COMPANY As Trustee for the registered holder of Soundview Home Loan Trust 2006-EQ1 Asset-Backed Certificates,Series 2006-EQ1 Date of Assignment:09/01/2011 Recorded Date: 10/10/2011 Instrument#: 201127936 2. Upon information and belief Defendant(s)and/or their predecessor: Gary R.Wilbur&Lyndell D.Wilbur (hereinafter"Defendants"),are the owners of property located at 27 Stonehedge Drive, Carlisle,PA 17015 ,by virtue of Deed dated 05/30/2001 and recorded 05/30/2001 in Official Records Book 245 at Page 655 of the Public Records of Cumberland County, Pennsylvania(hereinafter the "Property"). 2A) Michael Wilbur,is being named solely in his capacity as Known Heir of Lyndell D. Wilbur and Gary R. Wilbur,pursuant to Pa.R.C.P. 1144(a)(2). 2B) Christine Brown,is being named solely in her capacity as Known Heir of Lyndell D. Wilbur and Gary R. Wilbur,pursuant to Pa.R.C.P. 1144(a)(2). 2C) Unknown Heirs, Successors,Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest from or Under Lyndell D. Wilbur,Deceased are made party defendants to the extent that they may hold an interest in the subject premises. 2D) Unknown Heirs, Successors,Assigns and All Persons,Firms or Associations Claiming Right, Title or Interest from or Under Gary R. Wilbur,Deceased are made party defendants to the extent that they may hold an interest in the subject premises. 3. On 06/08/2006,Defendant(s)and/or their predecessor: GARY R. WILBUR& LYNDELL D. WILBUR promised to pay to the order of Equifirst Corporation ,the principal sum of $ 142,200.00 payable with interest thereon provided in the Note. 4. By Mortgage dated 06/08/2006,Defendant(s)and/or their predecessor: GARY R. WILBUR& LYNDELL D. WILBUR to secure the Note,mortgaged to Mortgage Electronic Registration Systems,Inc., as nominee for Equifirst Corporation, the Property which is the subject of this action. The Mortgage was recorded on 06/20/2006 in Official Records Book 1955 at Page 1901 . Said Mortgage is incorporated herein by referenced in accordance with Pa.R.C.P 1019(g). A legal description of the mortgage premises is attached hereto and made a part hereof. 5. Said mortgage is in default in that the payment due 05/01/2011, and all subsequent payments have not been made,and by its terms,upon breach and failure to cure said breach after notice,all sums secured by said Mortgage,together with the other charges authorized by said Mortgage and itemized below, shall be immediately due. 6. After demand,the Defendant(s)continues to fail or refused to comply with the terms of the Mortgage as follows: (a) By failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) By failing or refusing to pay other charges,if any,indicated below. The following amounts are due on the said Mortgage or modification agreement as of the date stated below Unpaid Principal Balance $143,578.82 Accumulated Interest $25,757.44 Accumulated Late Charges $110.48 Escrow Deficit/(Reserve) $7,853.80 Title Report $300.00 Attorney Fees- Estimated $1,650.00 Property Inspection $176.50 Property Valuation $1,752.00 Grand Total $181,179.04 The above figures are calculated as of 07/10/2013: The interest rate is subject to adjustment if more fully described as such in the note and mortgage. The interest rate on the subject note is at 8.00000 %. The per diem interest accruing on this debt is$30.94 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$55.24. 7. Breach letters have been sent to Defendant(s) in accordance with the requirements of the subject mortgage and/or The Pennsylvania Act 6 of 1974 of the Commonwealth of Pennsylvania and, if applicable, Act 91 of 1983. Copies of the breach letters are attached hereto as Exhibit"A". WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of$ 181,179.04 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged premises. UDREN LAW OFFICES, P.C. BY: VERIFICATION I, the undersigned, a(n) Contract Management Coordinator of Ocwen Loan Servicing, LLC ("Ocwen") Servicer for DEUTSCHE BANK NATIONAL TRUST COMPANY As Trustee for the registered bolder of Soundview Home Loan Trust 2006-EQ1 Asset-Backed Certificates, Series 2006-EQ1 ("Plaintiff'), am authorized to make this verification on behalf of Ocwen and hereby certify that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. Except where otherwise stated and/or based upon public record, this verification is based upon a review of business records regularly created, kept and maintained in the course of Ocweri s mortgage servicing business conducted on Plaintiffs behalf. In making this verification, I understand that it is a crime under 18 PA C.S. Section 4904 to make a written statement to a public servant or to invite a .ublic servant's reliance upon a written stat:me t or instrument, which I do n,t belt- - to •- ► or which I know to be false Date: 416 1 Name: Jacqueline S Michaelson Title: Contract Management Coordinators Company: Ocwen Loan Servicing, LLC, Servicer for, DEUTSCHE BANK NATIONAL TRUST COMPANY As Trustee for the registered holder of Soundview Home Loan Trust 2006-EQ1 Asset-Backed Certificates, Series 2006-EQ1 MJU#: 11080294-1 ALL THAT lot or parcel of land situate in South Middleton Township,Cumberland County,Pennsylvania,more particularly bounded and described as follows,to wit: COMMENCING at a concrete monument on the northern right-of-way line of Stonehedge Drive,a sixty(60)foot wide right-of-way;thence along said right-of-way line on a curve to the left having a radius of four hundred fifty and zero hundredths (450.00)feet,an arc distance of two hundred twenty-one and thirty-eight hundredths (221.38)feet to a point on the aforesaid right-of-way line also being the southwest corner of Parcel No.5 of Rockland Village at the POINT of BEGINNIG;thence continuing along the same on a curve to the left having a radius of four hundred fifty and zero hundredths (450.00)feet,an arc distance of thirty-four and eighty-seven hundredths (34.87)feet to a point on said right-of-way line also being the southeast corner of Parcel No.3 of Rockland Village;thence along the eastern line of Parcel No.3 and through a common party wall separating Parcel No. 3 from the Parcel described herein,North nineteen degrees nine minutes forty-four seconds East(N 19°09'44"E),one hundred twenty-six and thirty-three hundredths(12633)feet to a point at lands of Garland Court II within the Stonehedge PRD;thence along said lands South sixty-seven degrees forty minutes ten seconds East(S 67°40' 10"E),a distance of thirty-four and eighty-four hundredths(34.84)feet to a point at the northwest corner of Parcel No. 5;thence along the western line of Parcel No.5 and through a common party wall separating Parcel No.5 from the Parcel described herein South nineteen degrees nine minutes forty-four seconds West(S 19°09' 44"W),one hundred twenty-six and fifty-nine hundredths(126.59)feet to a point on the northern right-of-way line of Stonehedge Drive,the place of BEGINNING. THE above-described parcel is subject to a twenty-foot(20')wide sanitary sewer and water line easement through the southern portion of the parcel, and an irregular sized drainage easement along the northern boundary line of the Parcel. Both of these easements are found on the Final Land Development Plan of Rockland Village recorded in Plan Book 80,Page 13,at the Cumberland County Courthouse in the Recorder of Deeds Office. BEING Parcel No.4 of the Final Land Development Plan of Rockland Village recorded in Plan Book 80,Page 13 at the Cumberland Count y Courthouse in the Recorder of Deeds Office. HAVING THEREON erected a brick and vinyl townhouse having a mailing address of 27 Stonehedge Drive,Carlisle,Pennsylvania. UNDER AND SUBJECT to a Declaration of Covenants and Restrictions recorded in Cumberland County Miscellaneous Record Book 311,Page 482,Restated Declaration of Covenants and Restrictions recorded in Cumberland County Miscellaneous Record Book 325,Page 992,and Supplemental Declaration of Covenants and Restrictions recorded in Cumberland County Miscellaneous Record Book 624,Page 1082 and further subject to By-laws of the Stonehedge Homeowners Association as recorded in Cumberland County Miscellaneous Book 311,Page 511. BEING THE SAME PREMISES which Ahrens Development,Inc.,a Pennsylvania corporation by deed dated and recorded May 30,2001 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 245,Page 655,granted and conveyed unto Gary R.Wilbur and Lyndell D.Wilbur,husband and wife. 4. Ocwen Loan Servicing,LLC P.O. Box 24737 D G W E N West Palm Beach, Florida 33416-4737 (Do not send correspondence or payments to the above address.) .��''W.0?Q _N.CQM. . i June 30,2011 - • VIA First Class Mail VIA Certified Mail(return receipt requested) Certified Number: 71069017515142368673 Reference Code:.1106 Estate of Gary Wilbur 27 Stonehedge Dr • Carlisle,PA 17013 Loan.Number: 71058903 Property Address: 27 Stonehedge Drive,Carlisle,PA 17015-00(10 • • • PLEASE SEE THE ENCLOSED DOCUMENT 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 Ocwen Loan Servicing,LLC P.O. Box 24737 • West Palm Beach, Florida 33416-4737 OCWEN - (Do not send correspondence nr•payments to the above address.) W '\'%3 "��'�I _E;OM APPENDIX A . • June 30,2011 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE I v is a o I 'a t' • t• t • .tt i s • . 1 _ 1.o 1a•. ! d• au _ • _t a le • ' t• d t t •c . e, ec' c information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM(HEMP) may be able to_help to+ save your home. This Notice eplainshow the program works. To see if MA' can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN THIRTY 1301 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the CounselingAgency. . t• s' e.l e 4. ,11, !I I I sun.,e. t. .o s • I 4 4_0 - ' ' U 0_.1 aeitd , t.• end of this Notice.If you have at y questions you may callthe_Peousylvania Housing Finance Agency toll free at (800)342-2397(Persons with impaired heari g can call(717)780-1869). • This Notice contains important legal information, if you leave any questions. representatives at the Consumer Credit, 1 ..1 "to ' H .s' Ieale ohete,:rla'1 '. �_ • .s . 1 . . �oiata,. a t • '_ _ + . bar association may be_able to help you find a lawyer. • ' LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A • CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA • NOTIFICACION, OBTENGA UNA TRADUCCION INMEDIATAMENTE- LLAMANDO A ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO • MENCIONADO ARRIBA. USTED PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. • HOMEOWNER'S NAME(S): Estate of Gary Wilbur PROPERTY ADDRESS: 27 Stonehedge Drive Carlisle,PA 17015-0000 LOAN ACCT.NO.: 71058903 ORIGINAL LENDER: • CURRENT LENDER/SERVICER: OCWEN • • • • • • DACT91.Z1 • 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 ac and does not constitute an attempt to collect a debt • NMLS# 1852 Ocwen Loan Servicing, LLC P.O. Box 24737 • - C W E N West Pahn Beach, Florida 33416-4737 O _ (Do not send correspondence or payments to the above address) A?' \V.00WEN.0 OM HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU .MAY BE EIGIBLE 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: I IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES - BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS,AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE —Und._e_r the Act,you are.entitled to a temporary stay of foreclosure on. your mortgage for thirty(30)days from the date of this Notice, During that time you must arrange and attend a"face- .0-face" :e 'J. ith , . , ,-e ,ic „ ,'t ,_n al•, • '.t-, a ,-e -.,d , tf' , is u_ ► MUST OCCUR WITHIN THE NEXT (301 DAY& IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE_ PART OF THIS NOTICE_ CA •LED"HOW TO CURE YOUR MORTGAGE DEFAULT".EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER EDI QUN , N A . .N I .S—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. •........._... you have filed bankr.» t, you eau still-applyfor-Emergency-Mortgage-Assistance). . HOW TO CURE YOUR MORTGAGE DEFAULT(Bring it up to date). DACT92.2r 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 { O Ocwen Loan Servicing,LLC P.O: Box 24737 West Palm Beach, Florida 33416-4737 - (Do not send correspondence orpayments to the above address.) Wt<W.W.0CWl si OM 1 NATURE OF THE DEFAULT.—The MORTGAGE debt held by the above lender on your property located at: 27 • Stonebedge Drive,Carlisle,PA 17015-0000 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months.and the following amounts are now past due: 2 payments in the amount of$1,291.78 from May 01.2011 through June 30.2011. DETAIL SUMMARY : Principal and Interest $2,209.46 Interest.Arrearage $0.00 Escrow $374.1.0 Late Charges $55.24 Insufficient Funds Charges .. $0.00 Fees l Expenses • $413.50 • Suspense Balance(CREDIT) $0.00 Interest Reserve Balance(CREDIT) $0.00 TOTAL DUE $3,052.30 IOW 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 $3,052.30, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD.-Payments must be made either by Money Gram,Cashier's Check,Certified Check or Money Order made payable and sent to: OCWEN P.O. BOX 6440 CAROL STREAM,IL 60197-6440 IF YOU DO NOT CURE THE DEFAULT—If yen 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 vour_mortgaged property. • IF THE MOR GAGE 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 he 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 Wray d9 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 .a d a ' er .ost. r L ed r It he , iff' .1' a y,• 'r ', . • ,° ' 'i d•. at! , r t ',6 ,1 '. 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. • DACT9IZt This communication is frorn 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 • Ocwen Loan Servicing,LLC _ P.O.Box 24737 W e s t Palm Beach, Florida 33416-4737 G O W E N N (Do not send correspondence or payments to the above address.) WlAr ' lM EARLIEST POSSIBLE SHERIFF'S SALE DATE—It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately six(6)months from the date of this Notice.A notice of the actual datee 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 SHER FF'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. ONS +R ,R+ II CS N N ,EN IFS _ 'V_ .0 _R .1 • 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 o debt NMLS#1852 Ocwen Loan Servicing,LLC - P.O. Box 24737 - West Palm Beach, Florida 33416-4737 - °OWEN • • (Do not send correspondence or-payments to the above address.) WWt OCW..N..COM June 30,2011 • VIA First Class Mail VIA Certified Mail (return receipt requested) Certified Number: 71069017515142368666 • Reference Code: 1106 Lyndell D.Wilbur 27 Stonehedge Drive Carlisle,PA 17015-0000 Loan Number: . 71058903 Property Address: 27 Stonehedge Drive,Carlisle,PA 17015-0000 • • PLEASE SEE THE ENCLOSED DOCUMENT • DACT41.Z1 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 1 _ 4 - Omen Loan Servicing,LLC - - P.O.Box.24737 - West Palm Beach, Florida 33416-9737 C C W E.N (Do not send correspondence or payments to the above address.) WWW.0 :;1f E .(".OK APPENDIX A June 30,2011 ACT 91 NOTICE • - TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE • ' r , is . j ii ' • a t ,d .ke • se. i t•,d. s ' ee.s • information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may he able to help to save your home.. This Notice explains how the program works.• . To see if REMAP can help. you must MEET WITH A CONSUMER CREDIT CQUNSELING AGENCY WITHIN THIRTY (30) DAYS QF THE RATE OF THIS NOTICE. Take this Notice with_ you when you meet with the counseling Agency. The name,address and phone mnuber of Consumer Credit Counseling Agencies serving your. County are listed at the sft, s i • + _ ,., s- ' _•..tl ,• 's a a • •1, Val • _,-s - ii 'naic• :• •t ' 1 • (800)342-2397(Persons with impaired hearing can call(717) 780-1869). This Notice cotztainsimportant legaLiuformation. If you have any guesth nc represe n tatives at the Consumer Credit Counseling 4Y• c ,,.s ,• .x • s e t •• s ain 't su a •1 s a o cs,ta t , a , • 71 s r , 1, . oc.. bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION, OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO A ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. USTED PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Lyndell D.Wilbur PROPERTY ADDRESS: 27 Stonehedge Drive Carlisle,PA 17015-0000 LOAN ACCT.NO.: 71058903 ORIGINAL LENDER: CURRENT LENDER/SERVICER: OCWEN DACT91.21 This communication is from a debt collector attempting to collect a debt:any information obtained will be used Jim 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 Ocwen Loan Servicing,LLC - - ' 0 P.O.Box 24737 - ' - West Palm Beach, Florida 33416-4737 O C W E N (Do not send correspondence or payments to the above address.) i'\At '_3C_CvEN_c.'01 HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM • YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE_ANI)HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE•"ACT"),• YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: . IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS,AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE —Under the Act, you are entitled to a temporary stay of foreclosure on.. your mortgayt;for thirty(30)days from the date of this Notice. wring that time von mulct arrange and attend a "face- to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST' OCCUR_WITHIN THE NC)tl (30) DAYS. IF YOU DO NOT APPLY FOR .EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED"HOW TO CURE YOUR MORTGAGE DEFAULT"EXPLAINS BOW TO BRING YOUR MORTGAGE 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. _ 1• a) e a' ' •s . a)o t•_.!! 1' ,_aL'• r_ ±• ia,.•t•d el .0 a .e,it muis• '.i' a'e 'e _ t e 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 immediate y 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. . . .•(Ifyou have filed bankruptcy you can still'appl'y,'fe?..:r.:serge ney Mor.tgage.Assista nce); .. . . .. ... . . .. BOW TO CURE YOUR MORTGAGE DEFAULT(Bring it up to date). • • 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 • • Ocwen Loan Servicing,LLC - P.O.Box 29737 •- West Palm Beach, Florida 33416-4737 OCWEN `Z+V_Wr ' (Do not send correspondence or pa meats to the above address.) +.1 •QCI 1!I c:ii'1 • NATURE OF THE DEFAULT—The MORTGAGE debt held by the above lender-m your property located at:27 Stonehedge Drive,Carlisle,PA 17015-0000 IS SERIOUSLY LN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 2 payments in the amount of$1,291.78 from May 01.2011:the ough June 30,2011 • DETAIL SUMMARY : Principal and Interest $2,209.46 Interest Arrearage 5 0.00 Escrow .. S 374.10 Late Charges 5 55.24 Insufficient Funds Charges $0.00 • Fees/Expenses $413.50 Suspense Balance(CREDIT) $0.00 • Interest Reserve Balance(CREDIT) • S 0.00 TOTAL DUE $3,052.30 • NOW 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 $3,052.30, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by Money Gram. Cashier's Check,Certified Check or Money Order made. • payable and sent to: • OCWEN P.O.BOX 6440 CAROL STREAM,IL 60197-644C 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 ft v it ti sal. at a, time t to the • • ft th . . . _. uta d o ! Lavin the tt a alit It past due.plus any late or other charges then_due_.reasonable attorney's fees and costs connected with the foreclosure a�! a� it. 1. ,5 ct net't 1•• f, a • a S.' ii-' i. 'CA ,v tie e,• •. a • , t•41 JJla 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. DACr91.2I 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 ' Ocwen Loan Servicing,LLC - P.O.Box 24737 C O W E N West Palm Beach,Florida 33416-4737 • (Do not send correspondence or payments to the above address) !W W Oc . N.00;1.M1 FART IEST POSSIBLE SHERIFF'S SALE DATE—It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately six(6)months from the date of this Notice.A notice of the actual date of the Sheriff's 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'S SALE--You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE--You may 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 Al 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 uAC'T91.21 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 . • • • .August 26,2011 1 ACT 91 N TI E 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. Specific information about the nature of the default isprovided 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. ....T.o see ifHEMAP..can help;you must:MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and •hone number of Consumer Credit Counseling_Agencies serving your County are listed at the end of this Notice. If you have any questions,you may call the Pennsylvania. Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call(717)780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer.Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA,PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI. NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENI'E LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA •UN PRESTAMO POR EL PROGRAMA I.LAMADO ... "HOMEOWNER'.S EMERGENCY MORTGAGE..ASSISTANCE PRO. GRAM".EL CUAL . . . . PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU FIIPOTECA. • O HOMEOWNER'S NAME(S): Gary R.Wilbur Lundell D.Wilbur PROPERTY ADDRESS: 27 Stonehedge Drive . Carlisle,PA 17013 LOAN ACCT.NO.: ORIGINAL LENDER: EcLuiFirst Corporation CURRENT LENDER; DEUTSCHE BANK NATIONAL TRUST COMPANY As Trustee for the registered bolder of Soundview Home Loan Trust 2006-EQ1 Asset Backed Certificates Series,2006-E 1 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 TILE HOMEOWNER'S .....EMERGENCY....MORTGAGE.-ASSISTANCE....ACT...OF....198S....(THE,."ACT"),...YOU....MAY -BE....... ...... ................._..... ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS,AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30)days from the date of this Notice (plus three (3)days for mailing). During that time you must arrange and attend a"face-to-face"meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE.YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT', EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES--.If you meet.with.one.of.the..eonsumer.. . . .. . .... .... . .. credit counseling agencies listed at the end of this notice,the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses•and telephone numbers of designated consumer credit counseling agencies for the county in which the property • • is Iocated 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.) To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and.they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30)days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHLN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PUPA.WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE".YOU HAVE THE RIGHT TO P11,F A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A. FORECLOSURE ACTION, BUT IF YOUR APPLICATIONIS EVENTUALLY..APPE(.. ED...AT._ANY..TIME..B.EFORE.A.SHERIFF S..SALE, THE............................................._ FORECLOSURE WILL BE STOPPED. 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 I f 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.) • ROW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT — The MORTGAGE debt held by the above lender on your property located at: 27 Stonehedge Drive • ' + Carlisle,PA 17013 IS SERIOUSLY IN DEFAULT because: I • • A.YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the- following amounts are now past due: • Monthly Paiments of$1,291.78 for May 1,_2011 through August 112011 $5,167.12 • Total Late Charges=$110.48 Other charges(explain/itemizej: Property Inspection Fee=$21:00 • • Property Valuation Fee/BPO=$292.00 • TOTAL AMOUNT PAST DUE: $5,5O._ B.YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION(Do not use if not applicable): N/A 110W TO CURE TIME 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 $5,590,60, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES • WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash_cashier's check,certified check or money order madepayable and sent to: • Udren Law Offices.P.C. • Woodcrest Corporate Center 111 Woodcrest Road. Suite 200 • Cherry Hill,NJ 08003-3620 • You can cure any other default by taking the following action within THIRTY(30)DAYS of the date of . this letter: (Do not use if not applicable,): N/A ....IF...Y.I QU...D.O....N.OT...CURE...THE.DEFAULT..--..If.you..do...not-cure..the..default..wit:hin...THIRTY...(3.0) 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,von 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 revent the sale at any time u to one hour before the Sheriff's 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 'Sheriff's Sale as specifiecl'iii Wiitiiig by t`ttie`lerider gild"tip%•perfonrirrig`ariy'other:recjuireriients uf;der 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. • - i • • EARLIEST POSSIBLE SHERIFF'S SALE DATE-%It is estimated that the earliest date that such a - Sheriff's Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course;the amount needed to cure the default will increase th.e longer.you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: • Name of Lender/Servicer: Ocwen Loan Servicing Address: 12650 Ingenuity Drive Orlandoz i+L 32826 Phone Number: 877-596-8580 Fax Number: 407-737-5693 Contact Person: Customer Service E-Mail Address: , • EFFECT OF SHERIFF'S SALE--You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale,a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. • ASSUMPTION OF MORTGAGE—You may not transfer your home to a buyer or transferee who will • assume tl ernortgagedebt, provided:that all the outstanding..payments, charges and attom.ey's fees and....'......... ... . . _ costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003 856-669-5400 pleadings @udren.com Deutsche Bank National Trust Company As COURT OF COMMON PLEAS Trustee for the Registered Holder of CIVIL DIVISION Soundview Home Loans Trust 2006-EQ1 Asset-Backed Certificates, Series 2006-EQ1 Cumberland County Plaintiff v. Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming NO. 12-2340 Civil Right, Title or Interest From or Under Gary R. Wilbur, Deceased Michael Wilbur, Known Heir of Gary R. Wilbur Christine Brown, Known Heir of Gary R. Wilbur Gary R. Wilbur, Deceased Lyndell D. Wilbur Defendants MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S MOTION FOR LEAVE TO FILE AMENDED COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff seeks leave of Court to amend its Complaint in Mortgage Foreclosure. The facts set forth in the within Motion are incorporated herein by reference as though fully set forth at length. The Pennsylvania Rules Of Civil Procedure state as follows: Rule 1033,Amendment A party, . . . by leave of court, may at any time change the form of action, correct the name of a party or amend his pleading. The amended pleading may aver transactions or occurrences which have happened before or after the filing of the original pleading, even though they give rise to a new cause of action or defense. An amendment may be made to conform the pleading to the evidence offered or admitted. Pa.R.C.P. 1033. In the instant Motion for Leave to File Amended Complaint in Mortgage Foreclosure, Plaintiff requests leave to file the original of the attached Amended Complaint. Pursuant to the Rules of Civil Procedure as above stated and the facts as set forth in the attached Motion, Plaintiff requests that it be permitted to file the Amended Complaint in Mortgage Foreclosure. Respectfully submitted, UDREN LAW OFFICES, P.C. By: Harry . Reese, Esq ire PAID #310501 Attorney for Plaintiff UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003 856-669-5400 pleadings@udren.com Deutsche Bank National Trust Company As COURT OF COMMON PLEAS Trustee for the Registered Holder of CIVIL DIVISION Soundview Home Loans Trust 2006-EQ1 Cumberland County Asset-Backed Certificates, Series 2006-EQ1 Plaintiff v. Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming NO. 12-2340 Civil Right, Title or Interest From or Under Gary R. Wilbur, Deceased Michael Wilbur, Known Heir of Gary R. Wilbur Christine Brown, Known Heir of Gary R. Wilbur Gary R. Wilbur, Deceased Lyndell D. Wilbur Defendants CERTIFICATE OF SERVICE I, Harry B. Reese, Esquire, hereby certify that I have served or caused to be served true and correct copies of the Plaintiffs Motion For Leave To Amend Complaint in Mortgage Foreclosure and Brief in Support upon the following persons named herein at their last known address or their attorney of record. xxxxxx Regular First Class Mail Date Served:O1%) ,Y , 2013 TO: Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Gary R. Wilbur, Deceased 27 Stonehedge Drive Carlisle, PA 17015 Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Lyndell D. Wilbur, Deceased 27 Stonehedge Drive Carlisle, PA 17015 Michael Wilbur, Known Heir of Gary R. Wilbur And Lyndell D. Wilbur 27 Stonehedge Drive Carlisle, PA 17015 Christine Brown, Known Heir of Gary R. Wilbur And Lyndell D. Wilbur 207 Barrington Lane Bourbonnais, IL 60914-1673 Gary R. Wilbur 797 Sprague Road Memphis, NY 13112 Lyndell D. Wilbur 797 Sprague Road Memphis, NY 13112 UDREN LAW OFFICES, P.C. By. ( H . Reese, quire PAID #310501 Attorney for Plaintiff UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: STUART WINNEG, ESQUIRE-ID #45362 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings(&,udren.com Deutsche Bank National Trust Company As COURT OF COMMON PLEAS Trustee for the Registered Holder of CIVIL DIVISION Soundview Home Loans Trust 2006-EQ1 Cumberland County Asset-Backed Certificates, Series 2006-EQ1 t, c _ Plaintiff c - rn -4 t:r v. cnr` r .... - co .,. Unknown Heirs, Successors, Assigns and All ��.r, Persons, Firms or Associations Claiming NO. 12-2340 Civil _T Right, Title or Interest From or Under Gary Wilbur, Deceased .. c =mot Michael Wilbur, Known Heir of Gary R. Wilbur Christine Brown, Known Heir of Gary R. Wilbur Gary R. Wilbur, Deceased Lyndell D. Wilbur Defendants CERTIFICATION OF CONCURRENCE/NON-CONCURRENCE I, Harry B. Reese, Esquire, Attorney for Deutsche Bank National Trust Company As Trustee for the Registered Holder of Soundview Home Loans Trust 2006-EQ1 Asset-Backed Certificates, Series 2006-EQ1, hereby certify that on September a-- , 2013, I served or caused to be served a true and correct copy of the within Motion for Leave To Amend Complaint and the proposed Order by pre-paid first class regular mail along with a request to the other parties to provide their concurrence or non-concurrence. The Concurrence/Non-Concurrence response deadline wasC)C,Oot( 1- ,2013, and, as of OCie( 1, ,2013, the other parties have not responded to the inquiry concerning concurrence. UDREN AW OFFICES P.C. BY: A _ Ha V. '1, Est •ire PAID #311 01 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Deutsche Bank National Trust Company As Trustee for the Registered Holder of Soundview Home Loans Trust 2006-EQ1 Asset-Backed Certificates, Series 2006-EQ1 ' NO. 12-2340 Civil Plaintiff V. Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming o – Right, Title or Interest From or Under Gary R. Wilbur, Deceased - �r — Michael Wilbur, Known Heir of Gary R. -- Wilbur '. Christine Brown, Known Heir of Gary R. - Wilbur Gary R. Wilbur, Deceased Lyndell D. Wilbur Defendants RULE TO SHOW CAUSE AND NOW, this // day of O C n 1-/ , 2013 upon consideration of the foregoing Petition, it is hereby ORDERED that: 1. A Rule is issued upon the Respondent to show cause whythe Petitioneris not entitled to relief requested; 2. The Respondent may file an Answer to the Petition on or before 20 3. The Petition shall be decided under Pennsylvania Rule of Civil Procedure 206.7; 5. Argument shall be held , .n iF w p„r War 6. Notice of the entry of this Order shall be provided to all parties by the Petitioner. BY THE COURT: L` J. D TRIBUTION LIST: arry B.Reese,Esquire: Udren Law Offices, P.C., Woodcrest Corporate Center, 111 Woodcrest Road, Suite 200, Cherry Hill, NJ 08003, phone: 856-669-5400, email: pleadinizs(ri),udren.cwm - Attomey for the Plaintiff ,--*—Unknown Heirs,Successors,Assigns and All Persons,Firms or Associations Claiming Right, Title or Interest From or Under Gary R. Wilbur, Deceased: 27 Stonchedge Drive, Carlisle, PA / v 5 - Defendant nknown Heirs,Successors,Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Lyndell D. Wilbur, Deceased: 27 Stonehedge Drive, Carlisle, PA 17015 - Defendant ichael Wilbur,Known Heir of Gary R.Wilbur and Lyndell D.Wilbur: 27 Stonehedge Drive, Carlisle, PA 17015 - Defendant ristine Brown,Known Heir of Gary R.Wilbur and Lyndell D.Wilbur:207 Barrington Lane, Bourbonnais, IL 60914-1673- Defendant �ary R. Wilbur: 797 Sprague Road, Memphis,NY 13112 -Defendant ,,LyndeB D. Wilbur: 797 Sprague Road, Memphis, NY 13112 -Defendant ��I�:S I/� �3 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 pleadings @udren.com Deutsche Bank National Trust Company As COURT OF COMMON PLEAS Trustee for the Registered Holder of CIVIL DIVISION Soundview Home Loans Trust 2006-EQ1 Cumberland County Asset-Backed Certificates, Series 2006-EQ1 Plaintiff v. Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming NO. 12-2340 Civil Right, Title or Interest From or Under Gary R. -' `r' _ Wilbur, Deceased 13 ci/ ;r ; Michael Wilbur, Known Heir of Gary R. ter- -- 7;D r.,;' Wilbur CC) xfP —t Christine Brown, Known Heir of Gary R. =c) cam-,'' Wilbur x' ' Gary R. Wilbur, Deceased Lyndell D. Wilbur Defendants CERTIFICATE OF SERVICE I, Harry B. Reese, Esquire, hereby certify that I have served or caused to be served true and correct copies of the Plaintiffs Motion For Leave To Amend Complaint in Mortgage Foreclosure and Brief in Support upon the following persons named herein at their last known address or their attorney of record. xxxxxx Regular First Class Mail Date Served: October n, 2013 TO: Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Gary R. Wilbur, Deceased 27 Stonehedge Drive Carlisle, PA 17015 Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Lyndell D. Wilbur, Deceased 27 Stonehedge Drive Carlisle, PA 17015 Michael Wilbur, Known Heir of Gary R. Wilbur And Lyndell D. Wilbur 27 Stonehedge Drive Carlisle, PA 17015 Christine Brown, Known Heir of Gary R. Wilbur And Lyndell D. Wilbur 207 Barrington Lane Bourbonnais, IL 60914-1673 Gary R. Wilbur 797 Sprague Road Memphis,NY 13112 Lyndell D. Wilbur 797 Sprague Road Memphis,NY 13112 UDREN LAW OFFICES, P.C. By: A LAr H. eese, Ess re PA ID #310501 Attorney for Pl.'ntiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Deutsche Bank National Trust Company As Trustee for the Registered Holder of Soundview Home Loans Trust 2006-EQ1 Asset-Backed Certificates, Series 2006-EQ1 NO. 12-2340 Civil Plaintiff v. Unknown Heirs, Successors, Assigns and All a Persons, Firms or Associations Claiming r i Right, Title or Interest From or Under Gary --a R. Wilbur, Deceased cn — ,t Michael Wilbur, Known Heir of Gary R. Wilbur - ^' -- Christine Brown, Known Heir of Gary R. Wilbur Gary R. Wilbur, Deceased Lyndell D. Wilbur Defendants RULE TO SHOW CAUSE AND NOW, this /1 day of d c f'e b t/ , 2013 upon consideration of the foregoing Petition, it is hereby ORDERED that: 1. A Rule is issued upon the Respondent to show cause why the Petitioner is not entitled to relief requested; 2. The Respondent may file an Answer to the Petition on or before Z° yam °I s PT-': 3. The Petition shall be decided under Pennsylvania Rule of Civil Procedure 206.7; 5. Argument shall be held of •• . - .. •- ° - —-- • —- • • T (Iva tatr" 1.a 6. Notice of the entry of this Order shall be provided to all parties by the Petitioner. BY THE COURT: —. J. DISTRIBUTION LIST: Harry B.Reese,Esquire: Udren Law Offices, P.C., Woodcrest Corporate Center, 111 Woodcrest Road, Suite 200, Cherry Hill, NJ 08003, phone: 856-669-5400, email: pleadings@udren.com - Attorney for the Plaintiff Unknown Heirs,Successors,Assigns and All Persons,Firms or Associations Claiming Right, Title or Interest From or Under Gary R.Wilbur,Deceased: 27 Stonehedge Drive, Carlisle,PA 17015 - Defendant Unknown Heirs, Successors,Assigns and All Persons,Firms or Associations Claiming Right, Title or Interest From or Under Lyndell D. Wilbur, Deceased: 27 Stonehedge Drive, Carlisle, PA 17015 - Defendant Michael Wilbur,Known Heir of Gary R.Wilbur and Lyndell D.Wilbur:27 Stonehedge Drive, Carlisle, PA 17015 - Defendant Christine Brown,Known Heir of Gary R.Wilbur and Lyndell D.Wilbur:207 Barrington Lane, Bourbonnais, IL 60914-1673- Defendant Gary R. Wilbur: 797 Sprague Road, Memphis,NY 13112 - Defendant Lyndell D. Wilbur: 797 Sprague Road, Memphis, NY 13112 -Defendant 1 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 pleadings@udren.com Deutsche Bank National Trust Company As Trustee for the Registered Holder of Soundview Home Loans Trust 2006-EQ1 Asset -Backed Certificates, Series 2006-EQ1 Plaintiff v. Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Gary R. Wilbur, Deceased Michael Wilbur, Known Heir of Gary R. Wilbur Christine Brown, Known Heir of Gary R. Wilbur Gary R. Wilbur, Deceased Lyndell D. Wilbur Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 12-2340 Civil CERTIFICATE OF SERVICE c5 I, Nicole LaBletta, Esquire, hereby certify that I served or caused to be served true and correct copies of the Rule to Show Cause dated by the Court, October 11, 2013, with a response date twenty (20) days after date of service, in regard to Plaintiff's Motion For Leave To Filed an Amend Complaint in Mortgage Foreclosure upon the following persons named herein at their last known address or their attorney of record. xxxxxx Regular First Class Mail Date Served: June ('' 2014 TO: Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Gary R. Wilbur, Deceased 27 Stonehedge Drive Carlisle, PA 17015 Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Lyndell D. Wilbur, Deceased 27 Stonehedge Drive Carlisle, PA 17015 Michael Wilbur, Known Heir of Gary R. Wilbur And Lyndell D. Wilbur 27 Stonehedge Drive Carlisle, PA 17015 Christine Brown, Known Heir of Gary R. Wilbur And Lyndell D. Wilbur 207 Barrington Lane Bourbonnais, IL 60914-1673 Gary R. Wilbur 797 Sprague Road Memphis, NY 13112 Lyndell D. Wilbur 797 Sprague Road Memphis, NY 13112 UDREN LAW OFFICES, P.C. By: Nicole L"aBletta, Esquire PA ID # 202194 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION 4r Deutsche Bank National Trust Company As Trustee for the Registered Holder of Soundview Home Loans Trust 2006-EQ1 Asset -Backed Certificates, Series 2006-EQ1 Plaintiff v. Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Gary R. Wilbur, Deceased Michael Wilbur, Known Heir of Gary R. Wilbur Christine Brown, Known Heir of Gary R. Wilbur Gary R. Wilbur, Deceased Lyndell D. Wilbur Defendants NO. 12-2340 Civil RULE TO SHOW CAUSE AND NOW, this IL. day of 0 cfrb , 2013 upon consideration of the foregoing Petition, it is hereby ORDERED that: 1. A Rule is issued upon the Respondent to show cause why the Petitioner is not entitled to relief requested; 2. The Respondent may file an Answer to the Petition on or before Z 3. The Petition shall be decided under Pennsylvania Rule of Civil Procedure 206.7; ; • - • •;" 1; • ' RISS. 5. Argument shall be held -19,14 eta Gy. & it • t - : - : . 4-6-t 12" wet— 6. Notice of the entry of this Order shall be provided to all parties by the Petitioner. BY THE COURT: DISTRIBUTION LIST: Harry B. Reese, Esquire: Udren Law Offices, P.C., Woodcrest Corporate Center, 111 Woodcrest Road, Suite 200, Cherry Hill, NJ 08003, phone: 856-669-5400, email: pleadings@udren.com - Attorney for the Plaintiff Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Gary R. Wilbur, Deceased: 27 Stonehedge Drive, Carlisle, PA 17015 - Defendant Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Lyndell D. Wilbur, Deceased: 27 Stonehedge Drive, Carlisle, PA 17015 - Defendant Michael Wilbur, Known Heir of Gary R. Wilbur and Lyndell D. Wilbur: 27 Stonehedge Drive, Carlisle, PA 17015 - Defendant Christine Brown, Known Heir of Gary R. Wilbur and Lyndell D. Wilbur: 207 Barrington Lane, Bourbonnais, IL 60914-1673- Defendant Gary R. Wilbur: 797 Sprague Road, Memphis, NY 13112 - Defendant Lyndell D. Wilbur: 797 Sprague Road, Memphis, NY 13112 - Defendant UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust Company As Trustee for the Registered Holder of Soundview Home Loans Trust 2006-EQ1 Asset -Backed Certificates, Series 2006-EQ1 Plaintiff v. Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Gary R. Wilbur, Deceased Michael Wilbur, Known Heir of Gary R. Wilbur Christine Brown, Known Heir of Gary R. Wilbur Gary R. Wilbur, Deceased Lyndell D. Wilbur Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 12-2340 Civil Term MOTION TO MAKE RULE ABSOLUTE Plaintiff, Deutsche Bank National Trust Company As Trustee for the Registered Holder of Soundview Home Loans Trust 2006-EQ1 Asset -Backed Certificates, Series 2006-EQ1, by its Counsel, Udren Law Offices, P.C., and the undersigned Attorney, moves for a Rule Absolute, thereby granting Plaintiff the relief prayed for in its Motion for Leave to File Amended Complaint in Mortgage Foreclosure and in support thereof, avers as follows: 1. A Motion for Leave to File Amended Complaint in Mortgage Foreclosure, together with a Rule to Show Cause why said Motion should not be granted was filed by counsel for Plaintiff on October 8, 2013. 2. The Rule to Show Cause was entered on October 11, 2013 with a Rule Returnable date of 20 days from the Date of Service. A true and correct copy of the Rule is attached hereto as Exhibit "A". 3. On June 18, 2014, a true and correct copy of the Rule to Show Cause Order was served upon all the Defendant(s), interested person(s), and/or attorney(s) Via First Class Mail as certified to by the Order provided by the Cumberland County Prothonatary. A true and correct copy of the Certificate of Service of Rule is attached hereto as Exhibit "B". 4. To the best of Plaintiffs knowledge, information and belief, no response was filed or any objections interposed by any of the served parties, attorneys , and/or interested persons. Therefore, no cause has been shown as to why the relief prayed for in said Motion for Leave to File Amended Complaint in Mortgage Foreclosure should not be granted. 5. The Rule to Show Cause should be made Absolute and the relief prayed for in the Plaintiffs Motion for Leave to File Amended Complaint in Mortgage Foreclosure should be granted. WHEREFORE, Plaintiff prays and respectfully requests that this Honorable Court enter an Order making the Rule Absolute and therefore grant the relief prayed for in its Motion for Leave to File Amended Complaint in Mortgage Foreclosure. Respectfully submitted, UDREN LAW OFFICES, P.C. BY: ) 4-tA&e,11,v" Nicole LaBletta, Esquire PA ID # 202194 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Deutsche Bank National Trust Company As Trustee for the Registered Holder of Soundview Home Loans Trust 2006-EQ1 Asset -Backed Certificates, Series 2006-EQ1 Plaintiff v. Unlmown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Gary R. Wilbur, Deceased Michael Wilbur, Known Heir of Gary R. Wilbur Christine Brown, Known Heir of Gary R. Wilbur Gary R. Wilbur, Deceased Lyndell D. Wilbur Defendants NO. 12-2340 Civil RULE TO SHOW CAUSE r.) AND NOW, this jL day of iret , 2013 upon consideration of the foregoing Petition, it is hereby ORDERED that: 1. A Rule is issued upon the Respondent to show cause why the Petitioner is not entitled to relief requested; 2. The Respondent may file an Answer to the Petition on or before Z. 3. The Petition shall be decided under Pennsylvania Rule of Civil Procedure 206.7; • " • ! ; -• Ness* 5. Argument shall be held • r. " • • ;•• ;;; ,;, - .1 • 41.4, 416./ love" EXHIBIT A 6. Notice of the entry of this Order shall be provided to all parties by the Petitioner, BY THE COURT: DISTRIBUTION LIST: Harry B. Reese, Esquire: Udren Law Offices, P.C., Woodcrest Corporate Center, 111 Woodcrest Road, Suite 200, Cherry Hill, NJ 08003, phone: 856-669-5400, email: pleadingsfaudren.com - Attorney for the Plaintiff Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Gary R. Wilbur, Deceased: 27 Stonehedge Drive, Carlisle, PA 17015 - Defendant Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Lyndell D. Wilbur, Deceased: 27 Stonehedge Drive, Carlisle, PA 17015 - Defendant Michael Wilbur, Known Heir of Gary R. Wilbur and Lyndell D. Wilbur: 27 Stonehedge Drive, Carlisle, PA 17015 - Defendant Christine Brown, Known Heir of Gary R. Wilbur and Lyndell D. Wilbur: 207 Barrington Lane, Bourbonnais, IL 60914-1673- Defendant Gary R. Wilbur: 797 Sprague Road, Memphis, NY 13112 - Defendant Lyndell D. Wilbur: 797 Sprague Road, Memphis, NY 13112 - Defendant UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 pleadings@ndren.com Deutsche Bank National Trust Company As Trustee for the Registered Holder of Soundview Home Loans Trust 2006-EQ1 Asset -Backed Certificates, Series 2006-EQ1 Plaintiff v. Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Gary R. Wilbur, Deceased Michael Wilbur, Known Heir of Gary R. Wilbur Christine Brown, Known Heir of Gary R. Wilbur Gary R. Wilbur, Deceased Lyndell D. Wilbur Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 12-2340 Civil CERTIFICATE OF SERVICE c.) -13 -- rn _ Zr11 z") I, Nicole LaBletta, Esquire, hereby certifythat I served or caused to be served true and correct copies of the Rule to Show Cause dated by the Court, October 11, 2013, with a response date twenty (20) days after date of service, in regard to Plaintiff's Motion For Leave To Filed an Amend Complaint in Mortgage Foreclosure upon the following persons named herein at their last known address or their attorney ofrecord. XXXXXX Regular First Class Mail Date Served: June (81 2014 EXHIBIT 6 C OTO'291-1 "ISL Cebk. 41 TO: Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Gary R. Wilbur, Deceased 27 Stonehedge Drive Carlisle, PA 17015 Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Lyndell D. Wilbur, Deceased 27 Stonehedge Drive Carlisle, PA 17015 Michael Wilbur, Known Heir of Gary R. Wilbur And Lyndell D. Wilbur 27 Stonehedge Drive Carlisle, PA 17015 Christine Brown, Known Heir of Gary R. Wilbur And Lyndell D. Wilbur 207 Barrington Lane Bourbonnais, IL 60914-1673 Gary R. Wilbur 797 Sprague Road Memphis, NY 13112 Lyndell D. Wilbur 797 Sprague Road Memphis, NY 13112 UDREN LAW OFFICES, P.C. BY Nicole LaBletta, Esq PAID # 202194 Attorney 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 Deutsche Bank National Trust Company As Trustee for the Registered Holder of Soundview Home Loans Trust 2006-EQ1 Asset -Backed Certificates, Series 2006-EQ1 Plaintiff v. Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Gary R. Wilbur, Deceased Michael Wilbur, Known Heir of Gary R. Wilbur Christine Brown, Known Heir of Gary R. Wilbur Gary R. Wilbur, Deceased Lyndell D. Wilbur Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 12-2340 Civil Term CERTIFICATE OF SERVICE The undersigned certifies that true and correct copies of Motion to Make Rule Absolute were sent to the following person(s) named herein at their last known address or their attorney of record by. xxxxxx Regular First Class Mail Certified Mail Other (certificate of mailing) Date Served: , So 31 , 2014 TO: Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Gary R. Wilbur, Deceased 27 Stonehedge Drive Carlisle, PA 17015 Defendant Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Lyndell D. Wilbur, Deceased 27 Stonehedge Drive Carlisle, PA 17015 Defendant Michael Wilbur, Known Heir of Gary R. Wilbur And Lyndell D. Wilbur 27 Stonehedge Drive Carlisle, PA 17015 Defendant Christine Brown, Known Heir of Gary R. Wilbur And Lyndell D. Wilbur 207 Barrington Lane Bourbonnais, IL 60914-1673 Defendant Gary R. Wilbur 797 Sprague Road Memphis, NY 13112 Defendant Lyndell D. Wilbur 797 Sprague Road Memphis, NY 13112 Defendant UDREN LAW OFFICES, P.C. BY: Nicoleletta, Esquire PAID#202194 Attorney 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 Deutsche Bank National Trust Company As Trustee for the Registered Holder of Soundview Home Loans Trust 2006-EQ1 Asset -Backed Certificates, Series 2006-EQ1 Plaintiff v. Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Gary R. Wilbur, Deceased Michael Wilbur, Known Heir of Gary R. Wilbur Christine Brown, Known Heir of Gary R. Wilbur Gary R. Wilbur, Deceased Lyndell D. Wilbur Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 12-2340 Civil Term ORDER f- G-, -4 rr-i CD --4 CD -ra -0 cD-T C.ri C7'.)i , —i (�l AND NOW, to wit, this f ` day of 44,5x.— , 2(rY, upon consideration of Plaintiff's Motion For Leave To File an Amended Complaint in Mortgage Foreclosure, and any response thereto, it is hereby ORDERED that the Plaintiff is granted leave to file its Amended Complaint in Mortgage Foreclosure; and It is hereby further ORDERED that the Complaint, except as so amended, shall in all other respects, remain unchanged and as filed. BY THE COURT: , RIBUTION LIST: icole LaBletta, Esquire: Udren Law Offices, P.C., Woodcrest Corporate Center, 111 Woodcrest Road, Suite 200, Cherry Hill, NJ 08003, phone: 856-669-5400, email: ple. dingsa,udren.com - Attorney for the Plaintiff nknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Gary R. Wilbur, Deceased: 27 Stonehedge Drive, Carlisle, PA 17015 - Defendant own Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Lyndell D. Wilbur, Deceased: 27 Stonehedge Drive, Carlisle, PA 17015 - Defendant hael Wilbur, Known Heir of Gary R. Wilbur and Lyndell D. Wilbur: 27 Stonehedge • Drive, Carlisle, PA 17015 - Defendant istine Brown, Known Heir of Gary R. Wilbur and Lyndell D. Wilbur: 207 Barrington Lane, Bourbonnais, IL 60914-1673- Defendant R. Wilbur: 797 Sprague Road, Memphis, NY 13112 - Defendant Jyndell D. Wilbur: 797 Sprague Road, Memphis, NY 13112 - Defendant L.L/' C.. UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings(audren.com DEUTSCHE BANK NATIONAL TRUST COMPANY As Trustee for the registered holder of Soundview Home Loan Trust 2006-EQ1 Asset - Backed Certificates, Series 2006-EQ1 C/O Ocwen Loan Servicing, LLC 1661 Worthington Road Suite 100 West Palm Beach, FL 33409 Plaintiff v. GARY R. WILBUR, LAST RECORD OWNER 797 SPRAGUE RD. MEMPHIS, NY 13112 LYNDELL D. WILBUR, LAST RECORD OWNER 207 BARRINGTON LANE BOURBONNAIS, IL 60914-1673 MICHAEL WILBUR, KNOWN HEIR OF GARY R. WILBUR AND LYNDELL D. WILBUR 27 STONEHEDGE DRIVE CARLISLE, PA 17015 CHRISTINE BROWN, KNOWN HEIR OF GARY R. WILBUR AND LYNDELL D. WILBUR 207 BARRINGTON LANE BOURBONNAIS, IL 60914-1673 UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER GARY R. WILBUR, DECEASED 27 STONEHEDGE DRIVE CARLISLE, PA 17015 UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER LYNDELL D. WILBUR, DECEASED 27 STONEHEDGE DRIVE CARLISLE, PA 17015 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. 12 -2340 -CIVIL AMENDED COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO OSI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 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 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 Plaintiffs favor: Assignor: Mortgage Electronic Registration Systems, Inc., as nominee for Equifirst Corporation Assignee: DEUTSCHE BANK NATIONAL TRUST COMPANY As Trustee for the registered holder of Soundview Home Loan Trust 2006-EQ1 Asset -Backed Certificates, Series 2006-EQ1 Date of Assignment: 09/01/2011 Recorded Date: 10/10/2011 Instrument #: 201127936 2. Upon information and belief Defendant(s) and/or their predecessor: Gary R. Wilbur & Lyndell D. Wilbur (hereinafter "Defendants"), are the owners of property located at 27 Stonehedge Drive, Carlisle, PA 17015 , by virtue of Deed dated 05/30/2001 and recorded 05/30/2001 in Official Records Book 245 at Page 655 of the Public Records of Cumberland County, Pennsylvania (hereinafter the "Property"). 2A) Michael Wilbur, is being named solely in his capacity as Known Heir of Lyndell D. Wilbur and Gary R. Wilbur, pursuant to Pa.R.C.P. 1144(a)(2). 2B) Christine Brown, is being named solely in her capacity as Known Heir of Lyndell D. Wilbur and Gary R. Wilbur, pursuant to Pa.R.C.P. 1144(a)(2). 2C) Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest from or Under Lyndell D. Wilbur, Deceased are made party defendants to the extent that they may hold an interest in the subject premises. 2D) Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest from or Under Gary R. Wilbur, Deceased are made party defendants to the extent that they may hold an interest in the subject premises. 3. On 06/08/2006 , Defendant(s) and/or their predecessor: GARY R. WILBUR & LYNDELL D. WILBUR promised to pay to the order of Equifirst Corporation , the principal sum of $ 142,200.00 payable with interest thereon provided in the Note. 4. By Mortgage dated 06/08/2006 , Defendant(s) and/or their predecessor: GARY R. WILBUR & LYNDELL D. WILBUR to secure the Note, mortgaged to Mortgage Electronic Registration Systems, Inc., as nominee for Equifirst Corporation , the Property which is the subject of this action. The Mortgage was recorded on 06/20/2006 in Official Records Book 1955 at Page 1901. Said Mortgage is incorporated herein by referenced in accordance with Pa.R.C.P 1019(g). A legal description of the mortgage premises is attached hereto and made a part hereof 5. Said mortgage is in default in that the payment due 05/01/2011, and all subsequent payments have not been made, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with the other charges authorized by said Mortgage and itemized below, shall be immediately due. 6. After demand, the Defendant(s) continues to fail or refused to comply with the terms of the Mortgage as follows: (a) By failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) By failing or refusing to pay other charges, if any, indicated below. The following amounts are due on the said Mortgage or modification agreement as of the date stated below Unpaid Principal Balance Accumulated Interest Accumulated Late Charges Escrow Deficit/(Reserve) Title Report Attorney Fees- Estimated Property Inspection Property Valuation Grand Total The above figures are calculated as of 07/10/2013: $143,578.82 $25,757.44 $110.48 $7,853.80 $300.00 $1,650.00 $176.50 $1,752.00 $181,179.04 The interest rate is subject to adjustment if more fully described as such in the note and mortgage. The interest rate on the subject note is at 8.00000 %. The per diem interest accruing on this debt is $30.94 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 $55.24. 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 $ 181,179.04 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged premises. UDREN LAW OFFICES, P.C. 5!, BY: '. - BY: VERIFICATION ■ A 7,-,• E 4 -,1 I, the undersigned, a(n) Contract Management Coordinator of Ocwen Loan Servicing, LLC ("Ocwen") Servicer for DEUTSCHE BANK NATIONAL TRUST COMPANY As Trustee for the registered holder of Soundview Home Loan Trust 2006-EQ1 Asset -Backed Certificates, Series 2006-EQ1 ("Plaintiff'), am authorized to make this verification on behalf of Ocwen and hereby certify that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. Except where otherwise stated and/or based upon public record, this verification is based upon a review of business records regularly created, kept and maintained in the course of Ocweri s mortgage servicing business conducted on Plaintiffs behalf. In making this verification, I understand that it is a crime under 18 PA C.S. Section 4904 to make a written statement to a public servant or to invite a .ublic servant's reliance upon a written statment or instrument, which I do n,beh to - r or which I know to be false Date: MJU #: 11080294-1 Name: Title: Jacqueline S Michaelson Contract Management Coordinator Company: Ocwen Loan Servicing, LLC, Servicer for, DEUTSCHE BANK NATIONAL TRUST COMPANY As Trustee for the registered holder of Soundview Home Loan Trust 2006-EQ1 Asset -Backed Certificates, Series 2006-EQ1 ALL THAT lot or parcel of land situate in South Middleton Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: COMMENCING at a concrete monument on the northern right-of-way line of Stonehedge Drive, a sixty (60) foot wide right-of-way, thence along said right-of-way line on a curve to the left having a radius of four hundred fifty and zero hundredths (450.00) feet, an arc distance of two hundred twenty-one and thirty-eight hundredths (221.38) feet to a point on the aforesaid right -of --way line also being the southwest corner of Parcel No. 5 of Rockland Village at the POINT of BEGINNIG; thence continuing along the same on a curve to the left having a radius of four hundred fifty and zero hundredths (450.00) feet, an arc distance of thirty-four and eighty-seven hundredths (34.87) feet to a point on said right-of-way line also being the southeast corner of Parcel No. 3 of Rockland Village; thence along the eastern line of Parcel No. 3 and through a common party wall separating Parcel No. 3 from the Parcel described herein, North nineteen degrees nine minutes forty-four seconds East (N 19° 09' 44" E), one hundred twenty-six and thirty-three hundredths (126.33) feet to a point at lands of Garland Court II within the Stonehedge PRD; thence along said lands South sixty-seven degrees forty minutes ten seconds East (S 67° 40' 10" E), a distance of thirty-four and eighty-four hundredths (34.84) feet to a point at the northwest corner of Parcel No. 5; thence along the western line of .Parcel No. 5 and through a common party wall separating Parcel No. 5 from the Parcel described herein South nineteen degrees nine minutes forty-four seconds West (S 19° 09' 44" W), one hundred twenty-six and fifty-nine hundredths (126.59) feet to a point on the northern right-of-way line of Stonehedge Drive, the place of BEGINNING. THE above-described parcel is subject to a twenty -foot (20') wide sanitary sewer and water line easement through the southern portion of the parcel, and an irregular sized drainage easement along the northern boundary line of the Parcel. Both of these easements are found on the Final Land Development Plan of Rockland Village recorded in Plan Book 80, Page 13, at the Cumberland County Courthouse in the Recorder of Deeds Office. BEING Parcel No. 4 of the Final Land Development Plan of Rockland Village recorded in Plan Book 80, Page 13 at the Cumberland Count y Courthouse in the Recorder of Deeds Office. HAVING THEREON erected a brick and vinyl townhouse having a mailing address of 27 Stonehedge Drive, Carlisle, Pennsylvania. UNDER AND SUBJECT to a Declaration of Covenants and Restrictions recorded in Cumberland County Miscellaneous Record Book 311, Page 482, Restated Declaration of Covenants and Restrictions recorded in Cumberland County Miscellaneous Record Book 325, Page 992, and Supplemental Declaration of Covenants and Restrictions recorded in Cumberland County Miscellaneous Record Book 624, Page 1082 and further subject to By-laws of the Stonehedge Homeowners Associationas.recorded in Cumberland.County . Miscellaneous Book 311, Page 511. ,PGI9:16 BEING THE SAME PREMISES which Ahrens Development, Inc., a Pennsylvania corporation by deed dated and recorded May 30, 2001 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 245, Page 655, granted and conveyed unto Gary R. Wilbur and Lyndell D. Wilbur, husband and wife. Certify chi ) be recorded r ‘Trillf•ri County PA 1111955PG1919 RL,orcter of Deeds Ocwen Loan Servicing, LLC P.O. Box 24737 ----- - West Palm Beach, Florida 33416-4737 0CWEN - (Do not setid correspondence or payments to the above addr .www.ocwEN.CONI, June 30, 2011 VIA First Class Mail VIA Certified Mail (return receipt requested) Certified Number: 71069017515142368673 Reference Code: 1106 Estate of Gary Wilbur 27 Stonehedge Dr Carlisle, PA 17013 Loan. Number: Property Address: 1111o,dge Drive , Carlisle, PA 17015-0000 PLEASE SEE THE ENCLOSED DOCUMENT DAC 121 This communication is from a debt collector attempting to collect a debt; any information obtained will he 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 on attempt to collect a debt NMLS # 1852 Ocwen Loan Servicing, LLQ' P.O. Box 24737 West Palm Beach, Florida 3341.6-4737. (Do not send correspondence or payments to the above address.) June 30, 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. 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 lile1p„vi0 host MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN THIRTY (30) DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions. you may call the Pennsylvania Housing Finance Agency toll free at L3300) 342-2397 (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information If you have any questions representatives at the Consumer Credit encv may be a le to h i ex + ain it. You a al. wan .o co tact a . . ttor . , in ' . a ' . T e + al bar a sociation may be able to help youfind a lawyer. ou e L" 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 BE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Estate of Gary Wilbur PROPERTY ADDRESS: 27 Stonehedge Drive Carlisle, PA 17015-0000 LOAN ACCT. NO.: 1111111111111 ORIGINAL LENDER: CURRENT LENDER/SERVICER: OCWEN DACT91 2.1 This communication is from a debt collector attempting to collect a debt; an)' 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 Ocwen Loan Servicing, LLC P.O. Box 24737 West Palm Beach, Florida 33916-4737 (Do not send cm -respondence or payments to the above address.) WWW.00v.. E.CC.! HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSI TANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE --Under the Act. you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend. a "face- to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING U U• W THIN E 'E 'T 3 D . = 0 F# t EN Y MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED"HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRiNG YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES — If you meet with one of the consumer credit counseling 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 uhcble 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 fillont, 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) daysof your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NO1' FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LET'T'ER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION -- Available funds f elneigei y 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: 1F 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. (Ic_ nax::ltd _•e ffiled..:F.aagak:'.:ptcy- rou-ean:-ctil!<a ; �. •:Eu ergeu r:M T- ae.;. �_. �' ......_ .......p. , `...c .,_... rp.E" ee.� ..:.b...C';j 1 ;�C;rt�,,a'{-,�!i3SESt::RtC �. HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). DACT91.21 This communication is from a debt collector attempting to collect a debt; any information obtained will be used Jrothat 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 Ocwen Loan Servicing, LLC P.O. Box 24737 West'Palm Beach, Florida 33416-4737 (Do not send correspondence or paymen to the above address. 11' 1v:1RT.(;)C;C) 1 NATURE OF THE DEFAULT.—The MORTGAGE debt held by the above lender on your property located at: 27 Stonehedge Drive , Carlisle, PA 17015-0000 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following monthsand the following amounts are now past due: 2 payments in the amount of $ 1,291.78 from May 01, 2011 through June 30,2011, DETAIL SUMMARY : Principal and Interest $ 2,209.46 Interest Arrearage $ 0.00 Escrow $ 374.1.0 Late Charges $ 55.24 Insufficient Funds Charges .. $ 0.00 Fees ! Expenses $ 413.50 Suspense Balance (CREDIT) $ 0.00 Interest Reserve Balance (CREDIT) $ 0.00 TOTAL DUE $ 3,052.30 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 $3,052.30, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. -Payments must be made either by Money Gram, Cashier's Check, Certified Check or Money Order 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 attorneys 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 y to 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 foreclosureproceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's 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 Sheriff's 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. DAC -r91.21 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 GC VIE N Ocwen Loan Servicing, LLC P.O. Box 24737 West Palm Beach, Florida 33416-4737 (Do not send correspondence or payments to the above address.) EARLIEST POSSIBLE SHERIFF'S SALE DATE — It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amountneeded 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'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 : 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 NONEXIS I'LNCE 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 ()OVEN Ocwen Loan Servicing, LLC P.O. Box 24737 West Palm Beach, Florida 33416-4737 (Do not send con-e.spondence orpayments to the above address. YvWVAIDc.:...1.Y.I.EN COM. June 30, 2011 VIA First Class Mail VIA Certified Mail (return receipt requested) Certified Number: 71069017515142368666 Reference Code: 1106 Lyndell D. Wilbur 27 Stonehedge Drive Carlisle, PA 17015-0000 Loan Number: Property Address: 2/111°Pnehedge Drive , Carlisle, PA 17015-0000 PLEASE SEE THE ENCLOSED DOCUMENT DACT91.21 This communication i.s ji-orn a debt collector attempting to collect a debt; any Win -motion 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 • Omen Loan Servicing, LLC P.O. Box 24737 West Palm Beach, Florida 334115-9737 CCWEN • (Do not send correspondence or payments to the above address.) WWIALOGWEN.COM. June 30, 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. 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 programworks. . To see if HEMAP can 1p, Yourmust MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WI1HIN THIRTY (30) DAYS OF THE DATE OF T NOTI ake th's Not' e with von when you meet. with the. Counseling Agency. The name address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may ca I the Pennsylvania sin Fina at (80O) 342-2397 (Persons with impaired hearing can call (7)7) 780-1869), This Notice contains important legal information, If you have any questions, representatives at the Consumer Credit Counselino Agency may he able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find, a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, 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 IIIPOTECA. .HOMEO'WNER'S NAME(S): Lyndell D. Wilbur PROPERTY ADDRESS: 27 Stonehedge Drive Carlisle, PA 170.15-0000 LOAN ACCT. NO.: Min ORIGINAL LENDER: CURRENT LENDER/SERVICER: OCWEN DA C,T91.2 I This communication iS fr0171 a debt collector attempting to collect a debt; any information obtained will be usedfor 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 Cc'NEN Ocwen Loan Servicing, LLC P.O. Box 2473.7 - West Pahn Beach, Florida 33416-4737 (Do not send correspoizdenc•e or payments to the above address.) 11,-"\\ .0CWEi\CO.M 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 BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE —Under the Acct, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30t days from the date of this Notice. During that time you must arrange and attend a "face- to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice.. THIS MEETING MUST OCCUR WITHIN THE NEXT (30i DAYS. IF YOU DO NOT APPLY .FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO PATE. THE PART OF THIS NOTICE CALLED"IIOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling 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 LYIMEDIATELY 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. (:yc:u have-f=l,,d still apply '- . Em„ ortg ce). c._ bankruptcy you can at:...:��th f6= ::.,c�:'t^,:-.. 1. _... _b Gb_ . _ c[c',^i:_��. HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). DACT'91.21 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 C w E , Ocwen Loan Servicing, LLC P.O. Box 24737 - - Nest Palm Beach, Florida 33416-473? (Do not send correspondence or payments to the above address.) Q%;4_s. NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender on your property located at: 27 Stonehedge Drive , Carlisle, PA 17015-0000 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 S 1,291.78 from May 01. 2011; through June 30, 2011 DETAIL SUMMARY : Principal and Interest $ 2,209.46 Interest Arrearage S 0.00 Escrow $ 374.10 Late Charges $ 55.24 Insufficient Funds Charges 5 0.00 Fees / Expenses S 413.50 Suspense Balance (CREDIT) $ 0.00 Interest Reserve Balance (CREDIT) S 0.00 TOTAL DUE $ 3,052.30 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 $3,052.30, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must b.e made either by Money Gram. Cashier's Check, Certified Check or Money Order made payable and sent to: OCWEN P.O. BOX 6440 CAROL STREAM, IL 60197-644C 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 lend•• intends t e .e ci e its ri' Its t+ accelerate tl e n o t' aed i t. 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 fender 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 w'thin the THIRTY (30) DAY period, you will not he 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. R1 ;HT 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 Sheriff's Sale. You may do so by paving 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 yon had never defaulted. DACT91.2{ This communication is from a debt collector• attempting to collect a debt; any information obtained will be used, for than 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 AWLS # 1852 O C W E N Ocwen Loan Servicing, LLC P.O. Box 24737 West Palm Beach, Florida 33416-4737 (Do not send correspondence or payments to the above address.) WWW.QCtu:EN.CD Al EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the. required payment or action will be by contacting the servicer. HOW TO CONTACT THE SERVICER: • Name of Servicer: OCWEN Address: P.O. BOX 24737 WEST PALM BEACH, FL 334164737 Phone Number: 800-310-9229 Fax Number: 407-737-6300 Contact: Early Intervention Dept EFFECT OF SHERIFF'S SAT E - 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 5, 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 TUE 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 THF, LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY DACT93.21 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 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 pags, for specific information about the nature of your default.) To do so, you must al" out, sip and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A !{EMAP APPLICATION AS SOON AS POSSIBLE. 17 YOU HAVE • A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE ANT) FILE AN APPLICATION WITH PHFA. WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR „ .......APPLICATION,,, EVENTU ALLY APP oyEzu..AT ANYTIME.BEFORE is, SHERIFF'S. SA.LE,..TTIE.. FORECLOSURE WILL BE STOPPED. 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 ANT) 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 Brin da e NATURE OF THE DEFAULT — The MORTGAGE debt held by the above lender on your property located at: 27 Stone hedge Drive Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly. Payments of $1,291.78 for May 1, 2011 through August 1, 2011 = $5_2167.12 Total Late Charges = $110.48 Other charges (explain/itemize): Property Inspection Fee = $21:00 Property Valuation Fee / BPO = $292.00 TOTAL AMOUNT PAST DUE: $5,590.60 B, YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): N/A 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 $5,590.60, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash. cashier's check, certified check or money order made payable and sent to: Udren Law Offices. P.C. Woodcrest Corporate Center 111 Woodcrest Road. Suite 200 Cherry Hill. NJ 08003-3620 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter. (Do not use if not applicable.): N/A I...YE;li..1).03....N.OT..C:EII�E...THE.I)EI+Ai1Li ..--..If.you..do...not_cure ..th.e..default..within...TH]RT '.....(3.0)........... 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 attorney s 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 attorneys 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 j;�e�i., s Sile as spectried u� ar�iir rev lite ienaer`afrd liv`penorininUany other rertuiresnent§ unaer the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. ............... • EARLIEST POSSIBLE SHERIFF'S SALE DATE _.: It is estimated that the earliest date that such a • Sheriffs Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course; the amount needed to cure the default will increase the longer .you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT. THE LENDER: Name of Lender/Servicer: Ocwen Loan Servicing Address: 12650 Ingenuity Drive Orlando, FL 32826 Phone Number: 877-596-8580 Fax Number: 407-737-5693'T. Contact Person: Customer Service —... E -Mail Address: 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 not 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. UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 pleadings@udren.com Deutsche Bank National Trust Company As Trustee for the Registered Holder of Soundview Home Loans Trust 2006-EQ1 Asset -Backed Certificates, Series 2006-EQ1 Plaintiff v. Gary R. Wilbur, Last Record Owner Lyndell D. Wilbur, Last Record Owner Michael Wilbur, Known Heir of Gary R. Wilbur and Lyndell D. Wilbur Christine Brown, Known Heir of Gary R. Wilbur and Lyndell D. Wilbur Unknown Heirs, Successors, Assigns and all Persons, Firms or Associations Claiming Right, Title or Interest from or Under Gary R. Wilbur, Deceased Unknown Heirs, Successors, Assigns and all Persons, Firms or Associations Claiming Right, Title or Interest from or Under Lyndell D. Wilbur, Deceased Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 12-2340 Civil CERTIFICATE OF SERVICE C 22 L- ,...4 -r, cz, — -<•P' N 2 cJ Of • .-< I, Nicole LaBletta, Esquire, hereby certify that I have served or caused to be served true and correct copies of the Plaintiffs Amended Complaint In Mortgage Foreclosure upon the following persons named herein at their last known address or their attorney of record. xxxxxx Regular First Class Mail Date Served: August 10 2014 TO: Gary R. Wilbur, Last Record Owner 797 Sprague Road Memphis, NY 13112 Defendant Lyndell D. Wilbur, Last Record Owner 207 Barrington Lane Bourbonnais, IL 60914-1673 Defendant Lyndell D. Wilbur, Last Record Owner 797 Sprague Road Memphis, NY 13112 Defendant Michael Wilbur, Known Heir of Gary R. Wilbur and Lyndell D. Wilbur 27 Stonehedge Drive Carlisle, PA 17015 Defendant Christine Brown, Known Heir of Gary R. Wilbur and Lyndell D. Wilbur 207 Barrington Lane Bourbonnais, IL 60914-1673 Defendant Christine Brown, Known Heir of Gary R. Wilbur and Lyndell D. Wilbur 797 Sprague Road Memphis, NY 13112 Defendant Unknown Heirs, Successors, Assigns and all Persons, Firms or Associations Claiming Right, Title or Interest from or Under Gary R. Wilbur, Deceased 27 Stonehedge Drive Carlisle, PA 17015 Defendant Unknown Heirs, Successors, Assigns and all Persons, Firms or Associations Claiming Right, Title or Interest from or Under Lyndell D. Wilbur, Deceased 27 Stonehedge Drive Carlisle, PA 17015 Defendant UDREN LAW OFFICES, P.C. By: V\.► (A Nicole LaBletta, F;squire PA ID # 202194 Attorney for Plaintiff UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 DEUTSCHE BANK NATIONAL TRUST COMPANY As Trustee for the registered holder of Soundview Home Loan Trust 2006-EQ1 Asset -Backed Certificates, Series 2006-EQ1 Plaintiff V. GARY R. WILBUR, LAST RECORD OWNER; LYNDELL D. WILBUR, LAST RECORD OWNER; et al Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 12 -2340 -CIVIL PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint on the above -captioned matter. DATE: UDREN LAW OFFICES, P.C. cI) rn —cs C) F- C �l C Gr avvj so. -/s Com} �1b31�C� floc, s Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY F -��P�0T�����T8�`� *^� �"*^*�.� ^ / - . ~ .. . .� -,� `����w�� 9A14 OCT -f PH 2:kn CUMBERLAND COUNTY pENNSYUV&N\A Deutsche BanNational Trust Company vs. Michael Raymond Wilbur (et al.) Case Number 2012-2340 SHERIFF'S RETURN OF SERVICE 09/11/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Christine Brown, but was unable to locate the Defendant in his baitiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as "Not Found" at 27 Stonehedge Drive, South Middleton Township, Carlisle, PA 17015. Residence is vacant. 09/23/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Michael Raymond Wilbur, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as "Not Found" at 27 Stonehedge Drive, South Middleton Township, Carlisle, PA 17015. Residence is vacant and per the CarIis!e Postmaster the defendant is deceased. SHERIFF COST: $61.27 SO ANSWERS, September 23, 2014 RONR ANDERSON, SHERIFF (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 DEUTSCHE BANK NATIONAL TRUST COMPANY As Trustee for the registered holder of Soundview Home Loan Trust 2006-EQ1 Asset -Backed Certificates, Series 2006-EQ1 Plaintiff V. GARY R. WILBUR, LAST RECORD OWNER; LYNDELL D. WILBUR, LAST RECORD OWNER; et al ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 12 -2340 -CIVIL Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: (Asi LI BY: A AW OFFICES, P.0 or Plaintiff David Neeren, Esquire PA ID 204252 Deut.lche Bank National Trust Company, as Trustee, et. al., Pla;—'n�:=tom vs. Gary R. Wilbur, et. al., Defendant(s) UDREN LAW OFFICES Ms. Laura Dolly 111 Woodcrest Rd., Ste. 200 Cherry Hill, NJ 08003-3620 Service of Process by APS International, Ltd. 1-800-328-7171 APS International Plaza 7800 Glenroy Rd. Minneapolis, MN 55439-3122 APS File #: 131168-0001 AFFIDAVIT OF SERVICE -- Individual Service of Process on: --Christine Brown, Known Heir of Gary R. Wilbur and Lyndell D. Wilbur Court Case No. Cumberland Co 12 -2340 -Civil State of: ILl.&A) 'Ov�L ) ss. County of: (`)10),-) �c) l Name of Server: ice/ %) i /Ce)G Date/Time of Service: Place of Service: Documents Served: Service of Process on: Person Served, and Method of Service: Description of Person Receiving Documents: Signature of Server: , undersigned, being duly sworn, deposes and says that at the time of service, s/he was of legal age and was not a party to this action; that on the oc day of ,/ -e r t/ , 20 l4", at c'30o'clock M at 797 Sprague Road the undersigned served the documents described as: Amended Complaint in Mortgage Foreclosure in Memphis, NY 13112 A true and correct copy of the aforesaid document(s) was served on: C ristine Brown, Known Heir of Gary R. Wilbur and Lyndell D. Wilbur By personally delivering them into the hands of the person to be served. ❑ By delivering them into the hands of , a person of suitable age, who verified, or who upon questioning stated, that he/she resides with Christine Brown, Known Heir of Gary R. Wilbur and Lyndell D. Wilbur at the place of service, and whose relationship to the person is: The person receiving documents is described as follows: Sex r ; Skin Color (4k -d .2- ; Hair Color ; Facial Hair Approx. Age `7S ; Approx. Height 5301 ; Approx. Weight / To the best of my knowledge and belief, said person was not engaged in the US Military at the time of service. Undersigned declares under penalty of perjury that s - foregoing is true and correct. Subscrribed and sworn t before me this ay of , �► 1» l! i Vii! , 20 Signature of APS International, Ltd. W i f c 0->c Sherman McDonell Notary Public, State of New York No. 01MC6247919 Qualified in Onondaga County Commission Expires Sept. 6. 2015 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 DEUTSCHE BANK NATIONAL TRUST COMPANY As Trustee for the registered holder of Soundview Home Loan Trust 2006-EQ1 Asset -Backed Certificates, Series 2006-EQ1 Plaintiff v. Gary R. Wilbur, Last Record Owner; Lyndell D. Wilbur, Last Record Owner; ET AL Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. 12 -2340 -CIVIL MOTION FOR SPECIAL 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 upon Defendant(s): MICHAEL WILBUR, KNOWN HEIR OF GARY R. WILBUR AND LYNDELL D. WILBUR, by regular mail and certified mail, and by posting the mortgaged premises and in support thereof avers the following: 1. Process was unable to be served at the then last known address of said Defendant(s) as follows: MICHAEL WILBUR, KNOWN HEIR OF GARY R. WILBUR AND LYNDELL D. WILBUR 27 STONEHEDGE DRIVE CARLISLE, PA 17015 A copy of the Return of Service is attached hereto as Exhibit "A". 2. Pursuant to Pa.R.C.P. 430, Plaintiff made a Good Faith Investigation, the report thereof being attached hereto as Exhibit "B". 3. Said investigation was unable to determine an alternate address for said Defendant(s). 4. The last known address of Defendant(s) is as set forth in the attached Exhibits. WHEREFORE, Plaintiff prays and respectfully requests that this Honorable Court enter an Order pursuant to Pa.R.C.P. 430 directing service of the Complaint in Mortgage Foreclosure upon said in paragraph 1, by regular mail and certified mail, and by posting the mortgaged premises. UDREN LFICES, P.C. BY: Attorneys AMANDA L. '" ' ER. ESQUIRE PA. W. D . # 307028 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE OF THE SHERIFF Deutsche Bank National Trust Company vs. Michael Raymond Wilbur (et al.) Case Number 2012-2340 SHERIFF'S RETURN OF SERVICE 09/11/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Christine Brown, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as "Not Found" at 27 Stonehedge Drive, South Middleton Township, Carlisle, PA 17015. Residence is vacant. 09/23/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Michael Raymond Wilbur, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as "Not Found" at 27 Stonehedge Drive, South Middleton Township, Carlisle, PA 17015. Residence is vacant and per the Carlisle Postmaster the defendant is deceased. SHERIFF COST: $61.27 SO ANSWERS, September 30, 2014 RONF'ES' R ANDERSON, SHERIFF EXHIBIT A (c) CountySuite Sheriff, Teleosoft, Inc. Affidavit of Good Faith Investigation At the request of the law firm identified below I initiated an investigation into the whereabouts of the defendant identified as the subject below. The following is true and accurate representation of my investigation. Client provided information: File Number: 11080294-1 Attorney/Law Firm: UDREN LAW OFFICES, P.C. (PA) Subject Name: MICHAEL WILBUR, KNOWN HEIR OF GARY R. WILBUR AND LYNDELL D. WILBUR Property Address: Street: 27 Stonehedge Drive City: Carlisle State: PA Zip: 17015 Skip Results: Date of Birth: Last Known Address (as of 10/8/2014) Street: 27 Stonehedge Dr City: Carlisle State: PA ProVest File Number: 4115031 Zip: 17015 9120 Death Record Search As of 10/08/2014, the Social Security Administration has no death record on file for Michael Wilbur. Social Security Number [X] Verifed [ ] Not Verified SSN# Employment Search During a search for employment of our defendant no employment information was provided prior to the investigation or found during the Investigation. Business Records Search No business records found. Creditor Header Inquiry The latest address from the credit header info is: Address: 27 STONEHEDGE DR, CARLISLE, PA 17015 9120 Department of Motor Vehicle Records Search* Unable to obtain Motor Vehicle Records in the State of Pennsylvania. Drivers License Information Search [ ] GovemmentaP + [X] Non-govemmental No verifiable information. Professional Licenses Search No records found. Freedom Of Information Act Inquiry Made to U.S. Postal Service FREEDOM OF INFORMATION ACT INQUIRY MADE TO U.S. POSTAL SERVICE: THE FOLLOWING ADDRESSES WERE SENT TO THE UNITED STATES POSTAL INSPECTOR AT THE ZIP CODE LISTED WITH NO RETURN INFORMATION TO DATE: Military Search Not on Active Duty; Did not leave Active Duty within the past 367 days; Has not been notified of a future call up to Active Duty Inquiry of Relatives, Neighbors, & Friends 717-249-4194: Spoke with possible neighbor, Marilyn Finkenbinder, does not know defendant. Comments: 717-249-0234: Called number listed to defendant, Michael Wilbur, there was no answer. 717-422-2049 (Mobile): Called number listed to defendant, Michael Wilbur, number has been disconnected. A search of Federal Bureau of Prisons resulted in no records for our defendant. Our defendant was not found to be currently incarcerated searching Pennsylvania County Jails. A search of Philadelphia Prison Systems resulted in no records for our defendant. Google: no additional records found Facebook: no poe listed Linkedln: no records found • Data not available In AL, AR, CA, HI, NH, OR, PA, VA, WA. '* Historical data in CO, DE, ID, IL, KY, LA, MD, MA, MS, MO, NH, ND, EXHIBIT B SC, WV. + Data available in CO, CT, DE, FL, ID, IL, KY, LA, ME, MD, MA, MI, MN, MS, MO, NH, ND, OH, SC, TN, TX, WV, WI, WY. The foregoing statement is true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unswom falsification to authorities. Under penalties of perjury, I declare that I have read the foregoing affidavit and that the facts stated in it are true. Glenna Hemandez ProVest File Number Provest Services LLC Date: ,OOt aU i 4 STATE OF FLORIDA COUNTY OF HILLSBOROUGH 31 Swom to or affirmed and signe (Seal) p1p{IY O014,i',2i ;; sLE Notary Pul:lit - Staff;; of flc da . = My Comm. Expire, 14, 201: a} Cornimss'.{l;i 15:35 FL''` Bonded Intoner, ; ati:ral i1o;ry!,ssn. OCT 0 9 2014 Printed Name of Nota ublic (ersonaily Known ( ) Produced as identification UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 DEUTSCHE BANK NATIONAL TRUST COMPANY As Trustee for the registered holder of Soundview Home Loan Trust 2006-EQ1 Asset -Backed Certificates, Series 2006-EQ1 Plaintiff v. Gary R. Wilbur, Last Record Owner; Lyndell D. Wilbur, Last Record Owner; ET AL Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. 12 -2340 -CIVIL MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (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 motion shall be accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. NOTE: A sheriffs return of "not found" or the fact that a defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). Notice of intended adoption mailed to last known address requires a "good faith effort" to discover the correct address. Adoption of Walker, 468 Pa. 165, 360 A2d 603 (1976). An illustration of a good faith effort to locate the defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and employers of the defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As set forth in the Return of Service marked Exhibit "A", the Sheriff and/or Process Server has been unable to serve the following Defendant(s) at their last known addresses. A good faith effort to discover the whereabouts of the Defendant(s) has been made as evidenced by the attached Affidavit of Good Faith Investigation marked Exhibit "B". WHEREFORE, Plaintiff prays and respectfully requests service of the Complaint in Mortgage Foreclosure upon Defendant(s) by regular mail and certified mail, and by posting the mortgaged premises. UDREN iOFFICES, P.C. BY: Attorneys or Plaintiff AMANDA L. RAUER, ESQUIRE AD, 4 30702S VERIFICATION The undersigned hereby states that he/she is the Attorney for the Plaintiff in this action, that he/she is authorized to make this Verification, and that the statements made in the foregoing MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Sec 4904 relating to unsworn falsification to authorities. Date: UDREN OFFICES, P.C. BY: Att AMA ntiff RAUER HA, P.D.. # 3O7f2 .. UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 DEUTSCHE BANK NATIONAL TRUST COMPANY As Trustee for the registered holder of Soundview Home Loan Trust 2006-EQ1 Asset -Backed Certificates, Series 2006-EQ1 Plaintiff v. Gary R. Wilbur, Last Record Owner; Lyndell D. Wilbur, Last Record Owner; ET AL Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. 12 -2340 -CIVIL CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was served by U.S. mail on each of the attached parties or their attorneys this 21ST day of October, 2014. Udren Law Offices, P.C. Attorney for Plaintiff By: AMANDA L. RAUER. ESQUIRE PA. I . D. # 307028 SERVICE LIST DELAWARE COUNTY, PENNSYLVANIA CCP. No. Docket Number: 12 -2340 -CIVIL NAME: MICHAEL WILBUR, KNOWN HEIR OF GARY R. WILBUR AND LYNDELL D. WILBUR MAILING ADDRESS: 27 STONEHEDGE DRIVE CARLISLE, PA 17015 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL TRIAL DIVISION DEUTSCHE BANK NATIONAL TRUST COMPANY As Trustee for the registered holder of Soundview Home Loan Trust 2006-EQ1 Asset -Backed Certificates, Series 2006-EQ1 Plaintiff v. Gary R. Wilbur, Last Record Owner; Lyndell D. Wilbur, Last Record Owner; ET AL Defendant(s) NO. 12 -2340 -CIVIL CD ORDER AND NOW, this 30 • day of Oda La" , 2014, upon consideration of Plaintiffs Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage Foreclosure on Defendant(s), Michael Wilbur, Known Heir of Gary R. Wilbur and Lyndell D. Wilbur, shall be complete when Plaintiff or its counsel or agent has served true and correct copies of the Complaint in Mortgage Foreclosure by posting the mortgage premises at: 27 STONEHEDGE DRIVE CARLISLE, PA 17015 And by mailing by certified mail and regular mail to the last known address of Defendant(s) as follows: MICHAEL WILBUR, KNOWN HEIR OF GARY R. WILBUR AND LYNDELL D. WILBUR 27 STONEHEDGE DRIVE CARLISLE, PA 17015 le) 3ify BY THE COURT: J. UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust Company, as Trustee for the registered holder of Soundview Home Loan Trust 2006-EQ1 Asset -Backed Certificates, Series 2006-EQ1 C/O Ocwen Loan Servicing, LLC Plaintiff v. Gary R. Wilbur, Last Record Owner Lyndell D. Wilbur, last Record Owner Michael Wilbur, Known Heir of Gary R, Wilbur and Lyndell D. Wilbur Christine Brown, Known Heir of Gary R, Wilbur and Lyndell D. Wilbur Unknown Heirs, Successors, Assigns, and all Persons, Firms, or Associations Claiming Right, Title, or Interest from or under Gary R. Wilbur, deceased Unknown Heirs, Successors, Assigns, and all Persons, Firms, or Associations Claiming Right, Title, or Interest from or under Lyndell D. Wilbur, deceased ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. 12-2340 Civil a 10 C:."1 Defendant(s) 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, Gary R, Wilbur and Lyndell D. Wilbur, Last Record Owners, and the Unknown Heirs, Successors, Assigns and All Persons, Finns or Associations Claiming Right Title or Interest From or Under Gary R, Wilbur and Lyndell D. Wilbur, deceased by posting only, of the subject premises located at 27 Stonehedge Drive, Carlisle,PA, 17015, 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 Defendants Gary R, Wilbur and Lyndell D. Wilbur may be deceased. 3. Plaintiff inquired with the Social Security Death Index and found an entries for Gary R, Wilbur and Lyndell D. Wilbur. A true and correct copy is attached hereto as Exhibits "A". 4. Plaintiff inquired and found Obituaries for Gary R, Wilbur and Lyndell D. Wilbur. A true and correct copy is attached hereto as Exhibits "B". 5. Plaintiff inquired with the Department of Vital Records and found a Death Certificate for Lyndell D. Wilbur. A true and correct copy is attached hereto as Exhibits "C" 6. 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 for either defendant. A true and correct copy of Plaintiffs Good Faith Investigation is attached hereto as Exhibit "D". 7. It is therefore believed, averred and suggested that Defendants Gary R, Wilbur and Lyndell D. Wilbu are deceased. 8. Plaintiff has made a good faith effort to locate all known heirs so as to name them as party defendants pursuant to Pa.R.C.P. 1144(a)(2) as evidenced by the attached Exhibits. 9. 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(0(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, Gary R, Wilbur and Lyndell D. Wilbur, Last Record Owners and the Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right Title or Interest From or Under Gary R, Wilbur and Lyndell D. Wilbur, Deceased; and service of any and all subsequent pleadings including, inter alia, the Notice of Sheriffs Sale, that require personal service by posting only, of the subject premises located at 27 Stonehedge Drive, Carlisle, PA, 17015. UDREN LAW OFFICES, P.C. BY: ) Nicole LaBletta, Esquire Pa. ID 202194 Attorneys for Plaintiff UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsna,udren.com Deutsche Bank National Trust Company, as Trustee for the registered holder of Soundview Home Loan Trust 2006-EQ1 Asset -Backed Certificates, Series 2006-EQ1 C/O Ocwen Loan Servicing, LLC Plaintiff v. Gary R. Wilbur, Last Record Owner Lyndell D. Wilbur, last Record Owner Michael Wilbur, Known Heir of Gary R, Wilbur and Lyndell D. Wilbur Christine Brown, Known Heir of Gary R, Wilbur and Lyndell D. Wilbur Unknown Heirs, Successors, Assigns, and all Persons, Firms, or Associations Claiming Right, Title, or Interest from or under Gary R. Wilbur, deceased Unknown Heirs, Successors, Assigns, and all Persons, Firms, or Associations Claiming Right, Title, or Interest from or under Lyndell D. Wilbur, deceased Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO.12-2340-CIVIL MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, Deutsche Bank National Trust Company, as Trustee for the registered holder of Soundview Home Loan Trust 2006-EQ1 Asset -Backed Certificates, Series 2006-EQ1 C/O Ocwen Loan Servicing, LLC, 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 Gary R, Wilbur and Lyndell D. Wilbur, Last Record Owners and the Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right Title or Interest From or Under Gary R, Wilbur and Lyndell D. Wilbur, 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, Defendants Gary R, Wilbur and Lyndell D. Wilbur are 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 ,Gary R, Wilbur and Lyndell D. Wilbur, 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(b)(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 Defendants Gary R, Wilbur and Lyndell D. Wilbur, 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 ,Gary R, Wilbur and Lyndell D. Wilbur, Last Record Owners, and the Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right Title or Interest From or Under Gary R, Wilbur and Lyndell D. Wilbur, 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 27 Stonehedge Drive, Carlisle, PA, 17015. Respectfully submitted, UDREN LAW OFFICES, P.C. BY: ,/11C..t., h1 Nicole LaBletta Esquire Pa. ID 202194 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 Deutsche Bank National Trust Company, as Trustee for the registered holder of Soundview Home Loan Trust 2006-EQ1 Asset -Backed Certificates, Series 2006-EQ1 C/O Ocwen Loan Servicing, LLC Plaintiff v. Gary R. Wilbur, Last Record Owner Lyndell D. Wilbur, last Record Owner Michael Wilbur, Known Heir of Gary R, Wilbur and Lyndell D. Wilbur Christine Brown, Known Heir of Gary R, Wilbur and Lyndell D. Wilbur Unknown Heirs, Successors, Assigns, and all Persons, Firms, or Associations Claiming Right, Title, or Interest from or under Gary R. Wilbur, deceased Unknown Heirs, Successors, Assigns, and all Persons, Firms, or Associations Claiming Right, Title, or Interest from or under Lyndell D. Wilbur, deceased Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. 12-2340 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: x Regular First Class Mail Date Served: November 10, 2014 TO: Gary R. Wilbur, Last Record Owner 797 Sprague Road Memphis, NY 13122 Lyndell D. Wilbur, last Record Owner 797 Sprague Road Memphis, NY 13122 Michael Wilbur, Known Heir of Gary R, Wilbur and Lyndell D. Wilbur 27 Stonehedge Drive Carlisle, PA 17015 Christine Brown, Known Heir of Gary R, Wilbur and Lyndell D. Wilbur 797 Sprague Road Memphis, NY 13122 Unknown Heirs, Successors, Assigns, and all Persons, Firms, or Associations Claiming Right, Title, or Interest from or under Gary R. Wilbur, deceased 27 Stonehedge Drive Carlisle, PA 17015 Unknown Heirs, Successors, Assigns, and all Persons, Firms, or Associations Claiming Right, Title, or Interest from or under Lyndell D. Wilbur, deceased 27 Stonehedge Drive Carlisle, PA 17015 Gary R. Wilbur, Last Record Owner 27 Stonehedge Drive Carlisle, PA 17015 Lyndell D. Wilbur, last Record Owner 27 Stonehedge Drive Carlisle, PA 17015 UDREN LAW OFFICES, P.C. BY: Nicole LaBletta, Esquire Pa. ID 202194 Attorneys for Plaintiff Ancestry.com - Social Security Death Index Page 1 of 1 Di ancestry coin - Social Security Death Index Name: Gary Wilbur SSN: Last Residence: 17015 Colebrook, Lebanon, Pennsylvania Born: 1.111.11. Died: 16 Aug 2010 State (Year) SSN Indiana (1955) issued: Source Citation: Number: 316-35-7899:Issue State: Indiana;Issue Date: /95.5. Source Information: Ancestry.com. Social Security Death Index [database on-linej. Provo, UT, USA: Ancestry.com Operations Inc, 2011. Original data: Social Security Administration. Social Security Death Index, Master File. Social. Security Administration. Description: The Social Security 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 1875 to last year. Information in these records includes name, birth date, death date, and last known residence. © 2011, The Generations Network, Inc. EXHIBIT A http://search.ancestry.com/cgi-bin/sse.dl]?MS AdvCB=1 &db=ssdi&rank=1 &new=1 &MSAV=2&... 10/6/2011 Social Security Death Index - Ancestry.com ancestry.com- Page 1 of 1 MIS197 ME Get Help Home Family Trees DNA - Collaborate Learning Center Publish Shop Hire An Expert All Results Contact Us 1 Ancestry.com Blog 1 Affiliates 1 Gift Memberships 1 Careers Visit our other sites: United States B 1997-2013 Ancestry.com 'Corporate Information 1 Privacy 1 Terms and Conditions EXHIBIT A http://search.ancestry.com/cgi-bin/sse.dll?MS_AdvCB=1 &rank=1 &new=1 &MSAV=2&m... 3/1.9/2013 �Su§ st d Reco ds These records may also be relevant to Lyndell D Wilbur: Lyndell Wilbur U.S. Public Records Index, Volume 1 Lyndell Wilbur U.S. Public Records Index, Volume 1 Lyndell Wilbur United States Obituary Collection Save record to someone in my Name: Lyndell D Wilbur ree Save record to my shoebox Born: — --- — Add Alternate Information Died: 2 Oct 2012 ! Order Original Document State (Year) SSN Indiana (1957-1958) View printer -friendly issued: 5 Request copy of original -----_...-_.—.----__-____—_—....-...—. application Save This Record Attach this record to a person in your tree as a source record, or save for later evaluation. rrecodare no comments for this I Source Citation: ;Issue State: Indiana; Issue Date: 1957-1958. Source Information: - - - Make a Connection Find others who are researching your ancestors in Public Member Trees: Find others researching Lyndell D Ancestry.com. Social Security Death Index [database on-line]. Provo, UT, USA: Ancestry.com Operations Inc, 2011. Original data: Social Security Administration. Social Security Death Index, Master File. Social Security Administration. Description: The Social Security 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 Wilbur individuals listed range from 1875 to last year. Information in these records includes name, birth date, death date, and last known residence. Learn more,,, Contact Us 1 Ancestry.com Blog 1 Affiliates 1 Gift Memberships 1 Careers Visit our other sites: United States B 1997-2013 Ancestry.com 'Corporate Information 1 Privacy 1 Terms and Conditions EXHIBIT A http://search.ancestry.com/cgi-bin/sse.dll?MS_AdvCB=1 &rank=1 &new=1 &MSAV=2&m... 3/1.9/2013 Greencastle Banner -Graphic: Print Story : Gary R. Wilbur. Page 1 of 1 Gary R. Wilbur Thursday, August 19, 2010 - Aug. 16,2010 Gary R. Wilbur, 71, passed away Monday, Aug. 16, 2010 in his home in Carlisle, Penn. He was born MN= in Johnson City, N.Y. to the late Fredric and Helen Francis Wilbur. He retired from IBM as a parts analyzer and was a member of BPOE Lodge #578 and the Conservation Club in Cloverdale. Gary loved to hunt and fish. He is survived by his wife Lyndell D. Allen Wilbur; son Michael of Carlisle; daughter Christine (Shannon) Brown of Memphis, NY; two grandchildren, Joseph Brown and Maggie Brown; stepmother Clara Wilbur; brother Fredric Wilbur of Pittsburgh; and sister Dawn Minyard of Speedway. He was preceded in death by a brother Brian and a sister Diane Coffey. A Celebration of Life Service will be held at 3 p.m. Friday in Hollinger Funeral Home & Crematory, 501 N. Baltimore Ave., Mt. Holly Springs, PA with Chaplain Tim Wheeler officiating. There will be a visitation in the funeral home one hour prior to services. Burial will be at the convenience of the family. Memorial contributions may be made to Hershey Medical Center Cancer Research, 500 Centerview Drive, Room A120, Hershey, PA 17033 or Celtic Hospice of Carlisle, 220 Wilson St., Carlisle, PA 17013. C Copyright 2010, Greencastle Banner -Graphic Story URL: http://www.bannergraphic.com/story/1657804.html EXHIBIT B http://www.bannergraphic.com/story/print/1657804.html 3/13/2012 Greencastle Banner -Graphic: Obituaries: Lyndell D. Wilbur (10/04/12) Concepts the Cabinet Shop 765-653.1080 Find mole on MaikcLolacclndinne Subscriber login 1 Subscribe/register now 1 Subscription help BANNER GRAPHIC Who is Putnam County's outstanding Teacher of the Month? Page 1 of 1 Fair - 32°F High: 40"F - Low' 22°F Tuesday, Mar. 19, 2013 Home News Sports Obituaries Records Opinion Entertainment Blogs Photos Contests Marketplace Classifieds Police/Fire Weddings Engagements Anniversaries OPrint BEmail link 9Respond to editor Share:©' f L L Lyndell D. Wilbur Thursday, October 4, 2012 Greencastle Banner -Graphic y_n_e_ D.Wilbur, 69, of Carlisle, Pa., passed away on Tuesday, Oct. 2, 2012 at the Forest Park Health Care Center in Carlisle with her family by her side. Lynn was born in Greencastle, the daughter of the Averil and Willard Allen. She graduated from Cloverdale High School in 1961. She met her husband Gary R. Wilbur at IBM and married him in 1963. He preceded her in death. She relocated to Boiling Springs, Pa., with her husband and family in 1987 where she continued to raise her family and started working for Sprint and would continue for more than zo years. She is survived by two children, Christine H. Brown and husband Shannon of Syracuse, N.Y., and Michael Wilbur of Carlisle; three grandchildren, Joey, Maggie and Lucy; sister Helen Simms of Indianapolis; brother-in-law Fred Wilbur of Rochester Mills, Pa.; and many nieces, nephews and cousins. She loved spending time with her family, especially her grandchildren. A private memorial services will be held at a later date. Arrangements are being handled by the Hollinger Funeral Home and Crematory, Mt. Holly Springs, Pa. © Copyright 2012 Greencastle Banucr-Graphic. All rights reserved. This material in not be published, broadcast, rewritlen or redistributed. Enlarge text Ei ilyndell d. wilbur I lSearch SMILEY'S HEAT COOL 765.653.8802 Cmi'S11cal(.. THE $249 LAPTOP FROM GO lchrornebook Home 1 News 1 Sports 1 Obituaries 1 Records! Opinion 1 Blogs 1 Classifieds © 2013 Greencastle Banner -Graphic 'Contact Us 1 Terms of Service 1 Media Partners 1 Search EXHIBIT B http://www.bannergraphic.com/story/1900666.html 3/19/2013 H105.905 REV.01/11) This is to certify that this is a true copy of the record which is on file ,n the Pennsylvania Department of Health, in accordance with the Vital Statistics Law of 1953, as amended. WARNING: It is illegal to duplicate this copy by photostat or photograph. 7473377 No. Type/Print to . Parmanant Rbtk Ink Marina O'Reilly Matthew State Registrar JUN 1 '5 2013 Date COM MON WPALTS DP PENNSYLVANIA • DEPARTMENT OP HEALTH • VITAL RECORDS CERTIFICATE OF QEATt1 Seta Ma Number. 100548 ToEaollel2dyidlear MEWoIEM 1. I 1. D*eedenrs IRj.TN•me (Perot, MIddI., Last. Sellae) 2. 5.k % ndell • 1•_ 9. Social Sort Numbet 4. Date Of Death (Mo/0. /Yi) (spoil MO) October 2 2012 Sa, Aga- at Si0* •Y -n) Sb. Urydtr 1 Year Sc. Und•r • .. Paq o • rt Mo D.y tar S Mon • 7*. dei hplace (Qty en • State or Forefgm Country Mon tia Days NOUno MI es Greancant1 ..mN 69 yrs _ 1 /b. ick,$ pill* 1COu tV) Putnam 6.. pr. 14.ncG fat.te or ro7.len Country) PS� Ob.arjjdenseAs&eet kph Nugl or - InctuS Apt No.) Sc. Did Dae.d.nt UV. In a Township? L Cf aia:n1lef'S aC7ge [7 Yaa, decedent hyad In foo_ Middleton Twio Sd.Rat(dena(County) Carlialey PA Cumberletea e.. Raa,dan . (Zip Code) 1 7 015 No, tlaeeaenr °eyed arlt,m Rm1Ts of dsy/b°ro. 6. Ever to VS Arrrhetd FOKO.A (iD. M46*01 0 Yes Ip No 0 Unknown J 0 0Mroad State: at Tme of 0o0m (j Marflad 1 widowed �11. sumVlnl{ apeuse^a Name (1r veil•, =Na °atm• prior m that ma, l*gel ' n Nova r M.rdad O Unknown 3.2. Fat*er'a Name (Flt.*, Mlddla, Let, 9uMa( Willard E» Alam 19. Mott * Nome Pear to First Merrtage (Pinot. Middle, Last) Avaril V Smith 24*. I) 36,ard's Name 146. Aofattonshlp t0 tic-eedent chrisrinc }L. Brown ( n t 14c. Informon s Maling Address (Strerid Number, City, sate, Zip COda1 797 • Spayua Rd. Memphis. NY 13112 »«....__.»,...._._.g.,-•-r•».VI•e. 1f D0.th Occurred In a NOspl*(:.... InpatlerR n„ Emergency Room/OUtpotlent 0 Dead On Arrival o('at(, Chick o one)) ...... ..._._... rw -fit ......-... If Doth OccuTed $omewhare DDhK Than . lfoap4U31 LJ NOs9IN *ditty [J Dou�int'e Neme t.1 Nursing Noma/Lor g.Torm Can Facility 0 Other (specify) iSb. P*G)Ay Nona (if not r sUtudoM *1 . atrgt and rumbas; FOrAst Park Haalt!X gAre Cts. *26. Qty 0r r0wry Stats, and 2jp Code SSd. Oou1337 of Math Carlisle, PA 17015 Cumharlan4 16a. Method of 01spodton 0 Curie Crematon 0 Rommel from State 0 Donation ' In Oth r(apeat 166. Data of Dlsposldon 10-4-2012 36c. Pi.* of DUpo.mon (Nam* of ranh.tafV, MOm.,Ory. Or otter 91.0* Hollinger FH/Crematory! 1pd. tecatlOO OP dspostteon (tRty or Town, 52ate, end ZIP) Mt_Holiy Springs, PA 17065 17a. 9{g f eYnYni 3037)ca U Pend Charge 0f lMarmafft 1t17b. UCMsa N Vmber !FO -011932-L 174, Name and Complete Address of Funeral Facility 5 1 N, Sa t i ore Ave. Siol,line r PH/cremetarv.Ina`` Mt _Holly Spring*_ 1' . 17065 1g. Dessauem's ed0ce3On - Chock tM Matron beat describes Mt highee degree or 100.3 of ed,oat camptend at Lha rima of death. 0gth gr do or less ..�No diploma, h12th h - 12grade i,n High sehd0l mad** or GSD COmplated CCI game Colles troth, but no dame* 0 Ass0W to dogma (ass. M, AS) 0 g•dheiw"a degree 10..41. 6A. AO, 03) 0 Mostar.* dogma (e,g. MA. MS. MEng, MEd, MSW, MOA) 0 Doctorate (e¢ PhD, EdD) or Pndfesslenal degree le. Debpant of mamma Origin • Chaad4 the boa that bast d. 116*0 whether the deeed0m is 3panlah/Mispanl*/Lattnn. Check the -N0' 6011 11 decadent la not Spuds NMsp.nlc/L.Uno. IlIgrivo. AOI: Spanish/Nispania/Ladn° 0 Yes, Modem. Meofcan AmoNdn, Chl*n0 CI Yes. Puerto Rican 0 Yea, Cuban 0 Yea, other Spanl.h/Nfspanir/Latino ' (gpe*jfy) 20. Dasedam 's Ram - Cheek ONE OR MOAE rosea M 1AOIea te whet the decedent *smoldered hlmaelf or hence* ba AlfWhit. 0 Konen 0 Sloth 01 Mao, Amenun 0 Metnamau 0 Amerl*n Indian Or Atom* MAIM 0 Other Allen 0 Aston Indian 0 OHM* Maw.fan 0 0,116.at 0 Guamanian Or Chamorro 0 Filipino 0 Samoan 0 repaint* 0 Other Pacific (sander 0 Other (sp.dly) hag. MO, DDS. DVM. U.S. OA 21. D.ce4*n0. Gnats Race S.°.Detgnatton - Check ONLY ONE to Ind10*t* what the d.ced.nt 0Or0tderad hinS**lf or het*O to be. ,S . 0 Jan....* 0 SmO ean R4Ck Or African American Cj Kansan 0 Oilier Pa tete islander 0 Amori*n Indian Or Alaska Native 0 Vietnamese 0 Don't Know/Not Sura 21.. Dec*tlent'* Us uea OcatpegOn - indits to linos of 660111 done dun* most of working Ole. 00 NOT USE REM RED. Sprint Corp. 0 Alden Indian 0 Other Allan 0 Refused 0 Chinas* 0 Native N0.ratla1 0 Other (Specify) 2Rb. land of guelnecs/Industry Ci 6)11Pmo 0 0uam•nian 0r 01.6064* Cuitltamar Serviaa y ITCH 7A* -2 f17DUST OC COMPLETED OY PERSON WHO PRONOUNCES OR cEMINg2 DEATH 33 Owe Pronounced Daad (Mo/Day/V,) ��/ n FYt.A4LJVL. . /C 2610. re of 94re013 Pron rising Matt, (Only wham apphcabl.l 104 hie �0.-- , 40 Ce -PA.) 206.,steam. Number 25. 5�rhed�t w,„...hr) 24. Tme of De M "is" ,eN,soogy,L [t:.•17T l7•[.�4 �t , 2/.3. .%•O 2ga Wes Madtcai Unmm.r or Coroner contacted? 0 Yea t�i(to CAUSE OF DEATH 26. Pare I. gmt.r the th.M of eva(3±-•d11•ases, In•w100, Of Compllcetons-that directly *used trio d4.th. DO NOT enter terminal went. sutat as .rdl•c arra. r.aplrat0ry amen. 03 ventricular RbrlltIaad.�an without showing rho atlosogy, DO NOrT.4�011340VIATE. Enter Only one sus• on • lin.. Add eddmona1110001/ no rsr IMM•Dltl76 I•"✓r •! • ST, 'g'L+✓ d 241/..P1 APProodnitita Interval: tCrrnt m O.atn CAUSE a. T / _ .__ _. ) dies* or mndmon Due to (or as • coaaqu4nN 01): _ ..... r.NJrang In 040th) b. TLS 9.queMlelly int oondltlonl, Dur to (or as • doraevuanc. of): If ani, leading to Mr *u.. OKtted on Zine is. Omar the 0, _ UND•RL01N0 CAUSS Due OD (oras • 0009pu•10* 01)t (610e100 0, In10,Y eh•t InIt1*t•d the mann ♦asuman d. In drtth) {./LST. Due to (or es a consequents °f» 2ga Part it. enter °that a(f0)(in• 6460 not raauhlng In aha und.6Rnng Cause 4Mn to Part t /- iVA ,010-'77a7E.y f'x¢2L 17. W* an autepay portermod7 0 Ifrt "A",:079�j .7'"j� •'•VG4C0 , . 20. Want autopsy finding. mailable to en npl.t. the duan of death/ 0 YN 29. If maim ret pregnantwaddn post year Prawn ort .t done of death • 0 Not pregnant. but pregnant within 42 dos° OF death 9D. DEd Tobacco Vat Contribute c0 OMth? 0 yes 0 Probably M.N. 0 Unknown 31w.M'MMr 4f Death @sato,./ 0 Nemlelda 0 Acel8O* 0 Panding InvosltfM OO 0 stia/do 0 Could not ba determined 0 Not pregnant. but pregnant 43 days t01 year before death , p2, Date of Injury (N0o/Day/Yr) igp.11 Month) 0 Unknown If pregnant whhIn Me pest veer , eg 7tms bf (dory 154. Mace of Injury (t.g. homO; construction Met nom; 0410034 5*. Laments at Injury (Swaim end Number, City. Stat•, Zip Coda)" 36. /dory St Work 0 Yea 0 No 97, R Traria on injury. Specify; 0 OHwa /Operator 0 P.d.etnan 0 Posse • 0 other (aaadly) t.0, Omen a How °duty Occum[d: 39a. C.rttner (lOteck only geC•rtttying physes Pronouncing A C4/tilymg 0 Medical Eaam)ne mire er *ria ora): an • 7o the Mint of my Mnewled*a, teeth oeeurred due t0 the *u.K0) Phytican - To the beat of my knowledge, death occurred / no�r -- 0 ba aom, }�d/or mv.silgadon• in of//a6,*mln��t nt1 _ .R "Y' Teta and manner stated et tett Min, date, and p1IN. end due to tic• *6K.) and manna, orated en my ep1nbn, °ooaatth� �Meow* at the time, dirt*, and pimp, and tan to tin Iuaa(a) d mantras mated sof +r f..I' Clem* Numb*,,/�67. I5..Y' i t:'OZ• o . 3 Nome, Address and WpCoda *anon Com mina Cams Of`Deeth (Atm 2 /2.117, tate Eh *.4&. 3p..P.D 1.m(.YB� L•C T2.M.S.c>s.' ,,tr0 8&OZ., 5- si+x.5+s4S Oaf -/7650 7 . 39c. Mta 5)gyed ( F0 y/41 /e -CS - a 40, tq ftstra1' * otatrirs Fiumber -t-Akr: i 41. R:Liter*? era L� 42. AngltAer Fi%asta IM00Dey/Tr) - 4. ao‘a 42. Amenamor, EXHIBIT C O)spositon *Mgt No N105.143 REV07/203.1 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust Company, as Trustee for the registered holder of Soundview Home Loan Trust 2006-EQ1 Asset -Backed Certificates, Series 2006-EQ1 CIO Ocwen Loan Servicing, LLC Plaintiff v. Gary R. Wilbur, Last Record Owner Lyndell D. Wilbur, last Record Owner Michael Wilbur, Known Heir of Gary R, Wilbur and Lyndell D. Wilbur Christine Brown, Known Heir of Gary R, Wilbur and Lyndell D. Wilbur Unknown Heirs, Successors, Assigns, and all Persons, Firms, or Associations Claiming Right, Title, or Interest from or under Gary R. Wilbur, deceased Unknown Heirs, Successors, Assigns, and all Persons, Firms, or Associations Claiming Right, Title, or Interest from or under Lyndell D. Wilbur, deceased Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. 12-2340 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 owners, Gary R, Wilbur and Lyndell D. Wilbur , 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. EXHIBIT D T he 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: November , 2014 UDREN LAW OFFICES, P.C. BY: de,e6A Nicole LaBletta, squire Pa. ID 202194 Attorneys for Plaintiff UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 DEUTSCHE BANK NATIONAL TRUST COMPANY As Trustee for the registered holder of Soundview Home Loan Trust 2006-EQ1 Asset -Backed Certificates, Series 2006-EQ1 Plaintiff v. GARY R. WILBUR, LAST RECORD OWNER; LYNDELL D. WILBUR, LAST RECORD OWNER; et al Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 12 -2340 -CIVIL PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint on the above -captioned matter. DATE: (OW icl David Neeren, Esquire PA IP 204252 6.5D con./ .s// /*Da/ gi# 7aroaa� �# 20 -(Lib IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Deutsche Bank National Trust Company, as Trustee for the registered holder of Soundview Home Loan Trust 2006-EQ1 Asset -Backed Certificates, Series 2006-EQ1 C/O Ocwen Loan Servicing, LLC Plaintiff v. Gary R. Wilbur, Last Record Owner Lyndell D. Wilbur, last Record Owner Michael Wilbur, Known Heir of Gary R, Wilbur and Lyndell D. Wilbur Christine Brown, Known Heir of Gary R, Wilbur and Lyndell D. Wilbur Unknown Heirs, Successors, Assigns, and all Persons, Firms, or Associations Claiming Right, Title, or Interest from or under Gary R. Wilbur, deceased Unknown Heirs, Successors, Assigns, and all Persons, Firms, or Associations Claiming Right, Title, or Interest from or under Lyndell D. Wilbur, deceased Defendant(s) NO. 12-2340 Civil ORDER AND NOW, this /9" Day of 0.04"/ , 2014, 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 Gary R, Wilbur and Lyndell D. Wilbur, Last Record Owners, and the Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right Title or Interest From or Under Gary R, Wilbur and Lyndell D. Wilbur, 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: 27 Stonehedge Drive, Carlisle, PA, 17015, which is the subject matter of this action in mortgage foreclosure. BY THE COURT: ct""1" irb. 144-1,1 J/II all Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY P I EL -UF THE i RO kiONl1 2911, OEC -4 AM 9:57 CUMBERLAND COUNTY PENNSYLVANIA Deutsche Bank National Trust Company vs. Michael Raymond Wilbur (et al.) Case Number 2012-2340 SHERIFF'S RETURN OF SERVICE 11/20/2014 01:37 PM - Deputy Christopher Sharpe, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the within named Defendant, to wit: Michael Raymond Wilbur, pursuant to Order of Court by "Posting" the premises located at 27 Stonehedge Drive, South Middleton Township, Carlisle, PA 17015 with a true and correct copy according to law. HRISTOP SH RPE, DEPUTY SHERIFF COST: $41.27 SO ANSWERS, November 21, 2014 RONNY R ANDERSON, SHERIFF (c.) COun,ySuito Sheriff, Toieosott. 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 DEUTSCHE BANK NATIONAL TRUST COMPANY As Trustee for the registered holder of Soundview Home Loan Trust 2006-EQ1 Asset -Backed Certificates, Series 2006-EQ1 Plaintiff v. Gary R. Wilbur, Last Record Owner; Lyndell D. Wilbur, Last Record Owner; et al Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 12 -2340 -Civil VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter a true and correct copy of the Complaint in Mortgage Foreclosure was mailed to Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: DATE MAILED: 12/3/14 Michael Wilbur, Known Heir of Gary R. Wilbur and Lyndell D. Wilbur 27 Stonehedge Drive Carlisle, PA 17015 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: AMANDA-AUER.. ESQUIRE .D. # 307028 N LAW OFFICES, P.C. WOO CRESTT ROAD RRY HILL, NJ 08003 11 u 1 91 7199 9991 7034 2541 1894 (\\\ca'uosi, Wilber knows I%eir of Gc31 R. a -sad LAind,e.l\ W d bur 2."1 Sic"0Y1Z\'ltd'e, e. C.c.a- 1�Pc l"l1S lbur riTA "ore Vic.. 11P08003 - az tw 0001387090D{EC 03 r.1' 1 LAW OFFICES, P.C. ST C7'"--::"7: E CENTER 0;;- • 1' ROAD RY HILL, NJ 08003 1\A \ci\nosik \bur and Lin& _1 acl\s\g,.. ? known (3.1 G 1A'0\ov\c-- 110\s US. POSTP,GE. >> F iTNEY SONES ZIP 08003 k rqo 02 11.) 414 *;:t•`_, 0001387090DEC 03 2014 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 DEUTSCHE BANK NATIONAL TRUST COMPANY As Trustee for the registered holder of Soundview Home Loan Trust 2006-EQ1 Asset -Backed Certificates, Series 2006-EQ1 Plaintiff v. GARY R. WILBUR, LAST RECORD OWNER; LYNDELL D. WILBUR, LAST RECORD OWNER; et al ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County c= Cl �..�, -Al f,+^� -.1 NO. 12 -2340 -CIVIL c.y c 3 .'t ""'' c F c_.a Wit•, ,,_... --c- C.? -t y•:. f Defendant(s) PRAECIPE TO REINSTATE AMENDED COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Amended Complaint on the above -captioned matter. DATE: 1 / fl3/i S UDREN LAW OFFICES, P.C. BY: UC Imo& togfet Attorneys for Plaintiff Nicole LaBicita, PA ID 2O214