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HomeMy WebLinkAbout12-7249~ ;~°G: E. t i t 4 r "' e -~i )1.V Jl ~. r l 1) r` ~..r ~ ~ ~ F ~ G 4) i~ t t I .~ r,, `a [..1st' !'~ ! 4 r r, 'd l . McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARL S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. MCQUAIL, ESQUHtE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIItE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Citibank, N.A. as Trustee for Bear Stearns ALT-A, Mortgage Pass-Through Certificates, Series 2007-2 2780 Lake Vista Drive Lewisville, Texas 75067 v. Victoria Ryan 110 Fairway Drive Carlisle, Pennsylvania 17015 and Darryl J. Ryan 110 Fairway Drive Cazlisle, Pennsylvania 17015 Attorneys for Plaintiff Cumberland County Court of Common Plelasl Number f a - ~~-C COMPLAINT IN MORTGAGE FORECLOSURE r/I S ~~ ~~o3?jam' ~`i Cl~~ l7&'aio p~a831~~1 File #t 53997 Page 1 NOTICE 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. ff YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THATMAY OFFERLEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800)990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notification. Hate falta asentar 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 defiende, la corte tomara medidas y puede continuar la demanda en contra soya sin previo aviso o notification. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes pars usted. LISTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI LISTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMATION ACERCA DE EMPLEAR A UN ABOGADO. SI LISTED NO PUEDE PROPORCIONAR PARR EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800)990-9108 File # 53997 Page 2 This is a communication from a debt collector who is attempting to collect a debt, and any information obtained will be used for that purpose. Unless, within thirty (30) days after your receipt of this communication, you dispute the validity of the debt, or any portion of the debt, we will assume that the debt is valid. If you notify us in writing within thirty (30) days of your receipt of this communication that the debt, or a portion of the debt, is disputed, we will obtain verification of the debt or a copy of the judgment against you, and we will mail to you a copy of the verification or judgment that we obtain. Upon Your written request to us within thirty (30) days of your receipt of this communication, we will provide to you the name and address of the original creditor, if different from the current creditor. Case Name: Citibank, N.A. as Trustee for Bear Stearns ALT-A, Mortgage Pass-Through Certificates, Series 2007-2 v. Victoria Ryan and Darryl J. Ryan Cumberland County File # 53997 Page 3 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is Citibank, N.A. as Trustee for Bear Stearns AL'T-A, Mortgage Pass-Through Certificates, Series 2007-2, duly organized and doing business at the above-captioned address. 2. The Defendant is Victoria Ryan, who is the mortgagor and real owner of the mortgaged property hereinafter described, and his/her last-known address is 110 Fairway Drive, Carlisle, Pennsylvania 17015. 3. The Defendant is Darryl J. Ryan, who is the mortgagor and real owner of the mortgaged property hereinafter described, and his/her last-known address is 110 Fairway Drive, Carlisle, Pennsylvania 17015. 4. On September 26, 2006, mortgagors made, executed and delivered a mortgage upon the premises hereinafter described to Mortgage Electronic Registration Systems, Inc., as nominee for CTX Mortgage Company, LLC, its successors and assigns which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1968, Page 468, such Mortgage being incorporated herein by reference by virtue of Rule 1019(g) Pa. R. C. P. 5. On March 30, 2012, the aforesaid mortgage was thereafter assigned by Mortgage Electronic Registration Systems, Inc., as nominee for CTX Mortgage Company, LLC, its successors and assigns to Citibank, N.A., as Trustee for Bear Stearns ALT-A, Mortgage Pass-Through Certificates, Series 2007-2 by Assignment of Mortgage, recorded in the Office of the Recorder of Cumberland County in Assignment of Mortgage Instrument No. 201217511, such Assignment of Mortgage being incorporated herein by reference by virtue of Rule 1019(g) Pa. R. C. P. 6. The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as 110 Fairway Drive, Carlisle, Pennsylvania 17015. 7. The mortgage is in default because monthly payments of principal and interest upon said mortgage due January 1, 2010 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. File # 53997 Page 4 The following amounts are due on the mortgage: sp Principal Balance .~1uog Interest from December 1, 2699 through June 15, 2012 Late Charges Attorney's Fee Escrow Advance Property Insepections BPO/Appraisals Property Preservation $ 434,875.7] $ 70,022.02 $ 706.68 $ l ,450.00 $ 18;198.72 $ 217.00 $ 250.00 $ 220.00 GRAND TOTAL 525,940.13 The attomey's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third pazty purchaser at Sheriff's sale. If the mortgage is reinstated prior to sale, reasonable and actually incurred attorney's fees will be chazged in accordance with the reduction provisions of Act 6, if applicable. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendant by regular mail with a certificate of mailing and by certified mail, return receipt requested required. 10. A copy of Chase's Homeowner Information Packet is attached hereto as Exhibit "B. " WHEREFORE, Plaintiff demands in rem Judgment against the Defendant in the sum of $525,940.13, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. McCABE, WEISBERG AND CONWAY,P.C. BY: ] RRENCE J. McCABE, ESQUIRE ] MARC S. WEISBERG, ESQUIRE [ ]EDWARD D. CONWAY, ESQUIRE [ ]MARGARET GAIRO, ESQUIRE [ ]ANDREW L. MARKOWITZ, ESQUIRE [ ] HEIDI R. SPIVAK, ESQUIRE [ )MARISA J. COHEN, ESQUIRE [ ]KEVIN T. MCQUAIL, ESQUIRE [ ]CHRISTINE L. GRAHAM, ESQUIRE [ ]BRIAN T. LAMANNA, ESQUIRE Attorneys for Plaintiff File # 53997 Page 5 Pennsylvania Verification Stephanie Blouin ,hereby states that he sh is Vice President of JPMor~an Chase Bank, N.A. as Attorney-In-Fact for the Plaintiff in this matter, and is authorized to make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of my information, and belief. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Stephanie Blouin Vice President Date: 11/17/12 JPMor~an Chase Bank, N.A. as Attorney-In-Fact for the Plaintiff Borrower: Darryl J. Ryan and Victoria Ryan Property Address: 110 Fairway Dr., Carlisle, PA 17015 County: Cumberland Last Four of Loan Number: 9045 LEGAL DESCRIPTYON AY;I. ~'fIAT CERTAIN tract of land with the improvements erected thereon located in b ro Township, Cumberland County, Pennsylvania, bounded and described as follows: 33EGINNING at a point, said point being on the eastern side of Fairway Drive at the dividing line between L''ot No. 7 and Lot No. 11 on the hereinafter mentioned plan of lots; thence North 34 degrees 25 minutes OOseconds West, 52.87 feet along the eastern side of Fairway Drive to a point; thence North 74 degrees 32 minutes 5q seconds East, 779.07 feet (erroneously referred to as 719.09 feet in deed of prior record) along lands now or formerly of J. Dale Jardine, et ux to a point marked by an iron pin; thence South 19 degrees 03 minutes 32 seconds East, 659.52 feet, along lands now or formed}~ of Katharine A. Haas to another iron pin; thence South 68 degrees 5.7 minutes 20 seconds-West, 275.26 feet along 3 tracts of land now or . formerly belonging to: (1) Robert L. and Mildred L. Welsh; (2) Irvin F. and.Edna M. Rupp; and (3) Jack R. and Mary Cruil, to a point marked by a fence post; thence South 69 degrees 2S minutes 00 seconds West, 59 feet along lands. now or formerly of Albert Lindsay and Lillian K. Rowland; thence North 19 degrees 47 minutes 39 seconds West, 355.14 feet along Lots Nos. 10, 9 and part of Lot No. 8, to a point; thence North 03 degrees 59 minutes 22 seconds West, 13$.95 feet, also along Lot No. 8 to a point; thence North 19 degrees 54 minutes 06 seconds West,15U.45 feet along Lot No. 7 to a point; thence South 74 degrees 32 minutes 50 seconds. West, 459.72 feet alonb Lot No. 7 to a point on the eastern side of Fairway Drive, the place of Beginning. ' . BEING Lot No. 1l in a plan of lots known as Fairway Acres, which will fully appear in Plan Book 55, Page 90, in the Recorder of Deeds Office in the Cumberland County Courthouse. CONTAINING S.5SS9 acres. HAVING erected thereon a dwelling house known as and numbered 110 Fairvf~ay Drive, Carlisle, Pennsylvania 1'7013. SUBJECT, nevertheless, to existing restrictions, rights of way and easements as appear iu the plot plan and otherwise of record In the Recorder of Deeds Office in and for Cumberland County, Pennsylvania. BEING THE SAME PREMISES which Cynthia A. Karst, single woman, by Deed dated December 19, 2002 and recorded January 2, 2003 in the Office of the Recorder of Deeds in and for Cumberland Count,, Pennsylvania, in Record Book 255, Fage 963, granted and conveyed unto Henry R. Sodano, adult individual. Parcel No.: 46-08.0583-114 ~#A s ~y t~~ir; t;~ he recorded ~~~.~~~t.~;z~larld County P~1. - .~ ,~ .~ ..~° ,-r~N~-e.,~ ~' ~' ~ ,~1; t'; ~~~c~l~cler of deeds FORM 1 Citibank, N.A. as Trustee far Bear Stearns A:LT-A, Mortgage Pass-Through Certificates, Series 2007-2 Plaintiff V S. Victoria Ryan and Darryl ,I. Ryan Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA _... -. y', ; ~..~ , CIV11 -' '~7 . - ~ t.. __ _ 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 acourt-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) days 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. Date c u ly subm tted -~~-- [Signature of Counsel for Plaintiff) 53997 Page 1 FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date: Cumberland County Court of Common Pleas Docket # t3UKRUWEK 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: Emai 1: # of people on household: Mailing Address (if different): C'n'~ State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people on household: First Mortgage Lender: Type of Loan: Loan Number: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payment Amount $ Date of Last Payment: Primary Reason for Default: Included Taxes & Insurance: State: Zip: Yes ^ No ^ Listing date: Price $ Realtor Phone: Yes ^ No ^ State: Zip: Home: Office: Cell: _ Other: How long? How long? Date You Closed Your Loan: Is the loan in Bankruptcy? Yes ^ No ^ If yes; provide names, location of court, case number & attorney: Assets Amount Owed: Value Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #l: Model: Amount owed: Value: Automobile #2: Model: _ Amount owed: Value: Other transportation (automobiles, boats, motorcvclesl: Year: Amount owed: Monthly Income Name of Employers: 1. Year: Year: Model Value: 2. 3. Additional Income Description (not wages): l . monthly amount: 2. monthly amount: Borrower Pay Days: Co-Borrower Pay Days: Months Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2nd Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child Support/Alim. Spending Money Da /Child Care/Tuft. Other Ex enses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ^ No ^ [f yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: 2 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 deliquency? Yes ^ No ^ [f yes, please indicate the status of those negotiations: Please provide the following information, if known, 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 obiligation to use the services provided by the above named Borrower Signature Co-Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Proof of income Past 2 bank statements 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 (hardship letter) Listing agreement (if property is currently on the market) Date 3 ELSE IF County name MC - "Lackawamna"~ Citibank, N.A. as Trustee for Bear Stearns ALT-A, Mortgage Pass-Through Certificates, Series 2007-2 Plaintiff v. Victoria Ryan and Darryl J. Ryan Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM PURSUANT TO LACKA. CO. R.C.P. 205.2(b) and 1143(a) 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 acourt-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have an attorney, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact a housing counselor at either the Neighborhood Housing Services of Lackawanna County (570) 558-2490 or the United Neighborhood Centers of Northeastern Pennsylvania (570) 343-8835 to schedule an appointment. Second, once you have contacted one of the housing counselors, you must promptly meet with that housing counselor within twenty (20) days of your telephone contact with them. During that meeting, you must provide the housing counselor with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you take these steps, the housing counselor will help you prepare and file a Request for Conciliation Conference with the Court. 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, it is not necessary for you to contact one of the housing counseling agencies. However, you and your attorney must complete a financial worksheet in the format attached hereto so that you will be able to submit a loan resolution proposal to your lender. If you and your lawyer complete a financial worksheet within forty (40) days of your receipt of this Notice, your lawyer will be able to file a Request for Conciliation Conference on your behalf so that a conciliation conference can be scheduled. At that time, you and your lawyer will meet with a representative of your lender in an effort to work out reasonable arrangements with your lender. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully^submitted: I l lay 1~ t 2 ~ ~~. Date [Signature of Counsel for Plaintiff) (Form 8 -Notice of Residential Mortgage Foreclosure Diversion Program Pursuant to Lacka. Co. R.C.P. 205.2(b) and 1143(a). 53997 Page 1 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE, ESQUIRE- ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID#17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET CAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.McQUAIL,ESQUIRE-ID#307169 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 c7 —r3 BRIAN T.LAMANNA,ESQUIRE-ID#310321 - w ANN E.SWARTZ,ESQUIRE-ID#201926 t�,�c = JOSEPH F.RIGA,ESQUIRE-ID#57716 0 . JOSEPH I. FOLEY,ESQUIRE-ID#314675 C CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 G� o n 123 South Broad Street,Suite 1400 A Philadelphia,Pennsylvania 19109 yG o n. (215)790-1010 G CO Citibank,N. A. as Trustee for Bear Stearns ALT- Cumberland County A, Mortgage Pass-Through Certificates, Series Court of Common Pleas 2007-2 Plaintiff V. Number 12-7249 Darryl J. Ryan and Victoria Ryan Defendants PRAECIPE TO MARK JUDGMENT TO PLAINTIFF'S USE TO THE PROTHONOTARY: Kindly mark the judgment entered on March 4,2013 relative to the above-captioned matter to the use of Plaintiff, Wilmington Trust,National Association, as Successor Trustee to Citibank,N.A. as Trustee for Bear Stearns ALT-A Trust 2007-2,Mortgage Pass-Through Certificates, Series 2007-2,whose address is 2780 Lake Vista Drive,Lewisville, Texas 75067. BY: , Date: May 16.2013 [ ] Terrence J. McCabe, Esq. arc S. Weisberg, Esq. [ ] Edward D. Conway,Esq. [ ] Margaret Gairo,Esq. [ ]Andrew L. Markowitz,Esq. [ ]Heidi R. Spivak,Esq. [Marisa J. Cohen,Esq. [ ] Kevin T. McQuail,Esq. Christine L. Graham,Esq. [ ]Brian T.LaManna,Esq. [ ]Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq. [ ] Joseph I.Foley,Esq. [ ] Celine P.DerKrikorian,Esq. Attorneys for Plaintiff CL Pro IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION Wilmington Trust,National Association, as Successor FILE NO.: 12-7249 Civil Term Trustee to Citibank,N.A.as Trustee for Bear Steams ALT-A Trust 2007-2,Mortgage Pass-Through AMOUNT DUE: $525,940.13 Certificates, Series 2007-2 C-) !�i�; V, INTEREST: from 02/22/13 $16,859.70 at$86.46 Darryl J.Ryan and Victoria Ryan ATTY'S COMM.: rri rY 1— ('10 CD COSTS: :VP C:D­1 C= rQ TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale,contract,or account based on a confession of judgment,but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended;and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County,for debt,interest and costs upon the following described property of the defendant(s) 110 Fairway Drive,Carlisle,Pennsylvania 17015 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County,for debt, interest and costs,as above, directing attachment against the above-named gamishee(s)for the following property(if real estate,supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s)in the possession,custody or control of the said gamishee(s). (Indicate)Index this writ against the gamishee(s)as a hs pendens against real estate of the defendant(s) described in the attached exhibit. DATE: BY: TeTru-n`ce i7MjC_abe,Esq. Marc S. Weisberg,Esq. Edward D.Conway,Esq Margaret Gairo,Esq. Andrew L.Markowitz,Esq. Heidi R. Spivak,Esq, .0o Marisa J.Cohen,Esq. Kevin T.McQuail,Esq. M Christine L.Graham,Esq. Brian T.LaManna,Esq. [ ]Ann E. Swartz,Esq. Joseph F. Riga,Esq. 6 [ ]Joseph 1.Foley,Esq, Celine P.DerKrikorian,Esq. 9 Attorneys for Plaintiff • Firm:MCCABE, WEISBERG AND CONWAY /_�N Address:123 S.Broad Street,Suite 1400 Philadelphia,PA 19109 Attorney for:Plaintiff Telephone:(215)790 1010 wn Supreme Court ID 307169 Co C . rD.U_ -)q get LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with the iniprovenients erected thereon situate in West Pennsboro To'Aqisllip, Cumberland County,Pennsylvania, bounded and described as follows: BEGINNING at a point.. said point being on the eastern side of Fairway Drive at the dividing line between Lot No. 7 and Lot No. I I on the hereinafter mentioned plan of lots-, thence North 34 degrees 25 ininutes 00 seconds West, 52.87 feet along the eastern side of Fairway Drive to a point: thence North 74 degrees 32 minutes 50 seconds East. 779,07 feet (erroneously referred to as 719.09 feet,in deed of prior record) along lands now or fortnerly of J. Dale Jardine, et ux to a point marked by an iron pin: thence South 19 degrees 03 rninutes 32 seconds East, 659.51 feet. along lands now or formerly of Katherine A. Haas to another iron pin-, thence South 68 degrees 57 minutes 20 seconds West. 275.26 feet along 3 tracts of land now or formerly of belonging to: (1) Robert L. and Mildred L. Welsh-. (2) Irvin F. and Edna M. Rupp; (3) Jack- R. and Mary Crull, to a point inaried by a fence post. thence South 69 degrees 25 ininutes 00 seconds lAfest,1 59 feet along lands now or formerly of Albert Lindsay and Lillian K. Rowland: thence North 19 degrees 47 minutes 39 seconds West. 355.14 feet along Lots Nos. 10.9 and part of Lot No. 8,to a point.-.thence North 03 degrees 59 ininutes 22 seconds West, 150,45 feet,along Lo No. 7 to a point; thence South 74 degrees 32 minutes 50 seconds West. 459.72 feet along Lot No. 7 to a point on the eastern side of Fairway Drive,the place of BEGINNING. BEING LOT No. I1 in a plan of lots known as Faitivay Acres. which will fully appear in Plan Book 55, Page 90, in the Recorder of Deeds Office in the Cumberland County Courthouse. CONTAINTING 5.5559 acres. HAVING erected thereon a dxvelling house known as and nurnbered 110 Fairway Drive,Carlisle,Pennsylvania 17013. SUBJECT, nevertheless. to existing restrictions, rights of way and easements as appear in the plot plan and othenvise of record in the Recorder of Deeds Office in and for Cuiriberland County,Pennsylvania. RB5678 110 Fairway Drive,Carlisle,Pennsylvania 17015. BEING the same premises which HENRY R. SODANO by deed dated August 25,2006 and recorded October 3, 2006 in the office of the Recorder in and for Cumberland County in Deed Book 267,Page 4803,granted and conveyed to Darryl J.Ryan and Victoria Ryan,husband and wife, in fee. TAX MAP PARCEL NUMBER:46-08-0583-114 i + McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK, ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.McQUAIL,ESQUIRE-1D#307169 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T. LaMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 c� ,.,, cr JOSEPH I.FOLEY,ESQUIRE-ID#314675 C o .� 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 215 ---790-1010 cnr : D o G ' _Wilmington Trust,National Association,as Successor CUMBERLAND COUNTY r_ Trustee to Citibank,N.A. as Trustee for Bear Stearns COURT OF COMMON PLEAS ALT-A Trust 2007-2,Mortgage Pass-Through �T Certificates, Series 2007-2 S>= PQ NO: 12-7249 Plaintiff ` V. Darryl J. Ryan and Victoria Ryan Defendants AFFIDAVIT PURSUANT TO RULE 3129 The undersigned, attorney for Plaintiff in the above action, sets forth the following information concerning the real property located at: 110 Fairway Drive,Carlisle,Pennsylvania 17015, as of the date the Praecipe for the Writ of Execution was filed.A copy of the description of said property being attached hereto. 1. Name and address of Owners or Reputed Owners Name Address Darryl J.Ryan 2050 Danbury Drive Rock Wall,Texas 75032 Victoria Ryan 2050 Danbury Drive Rock Wall,Texas 75032 2. Name and address of Defendants in the judgment: Name Address Darryl J. Ryan 2050 Danbury Drive Rockwall,Texas 75032 Victoria Ryan 2050 Danbury Drive Rockwall,Texas 75032 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: � L Name Address Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein JP Morgan Chase Bank,N. A. c/o Chase Home Finance LLC 3415 Vision Drive,P.O. Box 24696 Columbus, Ohio 43219-6009 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 110 Fairway Drive Carlisle,Pennsylvania 17015 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg,PA 17105 ATTN: Dan Richard Commonwealth of Pennsylvania 110 North 811 Street Inheritance Tax Office Suite#204 Philadelphia,PA 19107 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O.Box 8486 Recovery Program Harrisburg,PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg,PA 17128-1230 PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg,PA 17128-1230 Compliance ATTN: Sheriff's Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 Domestic Relations P.O. Box 320 Cumberland County Carlisle,PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building&Courthouse 228 Walnut Street, Ste.220 Harrisburg,PA 17108-1754 United States of America c/o U.S.Dept of Justice,Room 5111 Atty General of the United States 950 Pennsylvania Avenue NW Washington,DC 20530-0001 United States of America c/o U.S.Dept of Justice,Room 4400 Atty General of the United States 950 Pennsylvania Avenue NW Washington, DC 20530-0001 8. Name and address of Attorney of record: Name Address None I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. BY: May 16,2013 [ ] Terrence J.McCabe,Esq. )Marc S.Weisberg,Esq. DATE [ ]Edward D.Conway,Esq. Margaret Gairo, Esq. [ ]Andrew L.Markowitz,Esq. [ ] Heidi R. Spivak, Esq. [ ] arisa J.Cohen,Esq. [ ] Kevin T.McQuail,Esq. [Vf Christine L. Graham, Esq. [ ]Brian T. LaManna,Esq. [ ] Ann E. Swartz,Esq. [ ]Joseph F. Riga, Esq. [ ]Joseph I.Foley,Esq. [ ) Celine P.DerKrikorian,Esq. Attorneys for Plaintiff LEGAL DESCRIPTION ALL THAT CERTAIN tract of land w.1th. the impro-venients erected thereon situate in West Pennsboro To-w-iiship, Cumberland Comity, Peiuisylvaiva. bounded and described as follows: BEGI]NNIING at a point. said point beu' ia on the eastern side of Faiv%vay Drive at the di-viding line bet«reen Lot No. I and Lot No. 11 on the hereinafter mentioned plan of lots; thence North 34 degrees 25 minutes 00 seconds West, 52,57 feet along: the eastern side of Fairway Drive to a point.. thence North 74 degrees 32 ininutes 50 seconds East, 779.07 feet (erroneously referred to as 719.09 feet.in deed of prior record) alone lands now or forinerly of J. Dale Jardine.. et ux to a point iiiarked by an iron pu' i.- thence South 19 degrees 031 ininutes 32 seconds East, 659.51 feet along lands now or forinerly of Katherine A. Haas to another iron pill: thence South 68 degrees 57 minutes 20 seconds West, 275.26 feet along 3 tracts of land now oi- forinerly of belonging to: (1) Robert L. and Mildred L. Welsh; (2) Irwin F. and Edna.M. Rupp, and (3) Jack R. and Mary Crull. to a point,inarked by a fence post; thence South 69 degrees 25 minutes 00 seconds West. 59 feet along lands now or formerly of Albert Lindsay and Lillian K. Rovvland: thence North 19 degrees 47 minutes 39 secondslAtest-. 355.14 feet along Lots Nos. 10, 9 and part of Lot No. 8, to a point; thence North 03 degrees 59 minutes 22 seconds West, 150.45 feet along Lot No. 7 to a point; thence South 74 degrees 32 ininutes 50 seconds West.. 459.72 feet along Lot No. 7 to a point on the eastern side of FailvN ay Drive. the place of BEGINNING. BEING LOT No. 11 in a plan of lots known as Faiiivav Acres, which will fully appear in Plan Book 55, Page 90. in the Recorder of Deeds Office in the Cuniberland County Courthouse. CONTAINZ\iG 5.5559 acres. HA'%71NG erected thereon a dwellu' la house kno-w-ii as and numbired 110 Fairway Drive, Carlisle,Pennsylvania 17013. SUBJECT. nevertheless. to existina restrictions, rights of way and easen-lents as -appear in the plot plan and otherwise of record in the Recorder of Deeds Office in and for Cuniberland County, Pennsylvania. RB5678 110 Fairway Drive,Carlisle,Pennsylvania 17015. BEING the same premises which HENRY R. SODANO by deed dated August 25,2006 and recorded October 3, 2006 in the office of the Recorder in and for Cumberland County in Deed Book 267,Page 4803,granted and conveyed to Darryl J.Ryan and Victoria Ryan,husband and wife, in fee. TAX MAP PARCEL NUMBER:46-08-0583-114 r McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID#16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 c. MARISA J. COHEN,ESQUIRE-ID#87830 Q KEVIN T.McQUAIL,ESQUIRE-ID#307169 -�3 �' =-,-1 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 r= BRIAN T.LaMANNA,ESQUIRE-ID#310321 N r" ANN E.SWARTZ,ESQUIRE-ID#201926 �� o o JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 - 123 South Broad Street,Suite 1400 s ., o Philadelphia,Pennsylvania 19109 (215)790-1010 c a CIVIL ACTION LAW Wilmington Trust,National Association, as Successor COURT OF COMMON PLEAS Trustee to Citibank,N.A. as Trustee for Bear Stearns ALT-A Trust 2007-2, Mortgage Pass-Through CUMBERLAND COUNTY Certificates, Series 2007-2 V. Number 12-7249 Darryl J.Ryan and Victoria Ryan NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Darryl J. Ryan Victoria Ryan 2050 Danbury Drive 2050 Danbury Drive Rockwall,Texas 75032 Rockwall,Texas 75032 Your house(real estate)at 110 Fairway Drive,Carlisle,Pennsylvania 17015 is scheduled to be sold at Sheriffs Sale on September 4,2013 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square,Carlisle,Pennsylvania 17013 to enforce the court judgment of$525,940.13 obtained by Wilmington Trust,National Association, as Successor Trustee to Citibank, N.A. as Trustee for Bear Stearns ALT-A Trust 2007-2,Mortgage Pass-Through Certificates, Series 2007-2 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: I. The sale will be canceled if you pay to Wilmington Trust,National Association,as Successor Trustee to Citibank,N.A. as Trustee for Bear Stearns ALT-A Trust 2007-2,Mortgage Pass-Through Certificates, Series 2007-2 the back payments,.late charges, costs,and reasonable attorney's fees due. To find out how much you must pay,you may call McCabe, Weisberg and Conway,P.C.,Esquire at(215)790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find out the price bid by calling McCabe, Weisberg and Conway,P.C.,Esquire at(215)790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened,you may call McCabe, Weisberg and Conway,P.C.at(215)790-1010. 4. If the amount due from the buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty(30)days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed schedule of distribution is wrong)are filed with the Sheriff within ten(10)days after the posting of the schedule of distribution. 7. You may also have other rights and defenses,or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with the irnprovenients erected thereon situate in West Pennsboro Tow-iiship, Cumberland County, Pennsylvania,bounded and described as follows: BEGINNING at a point, said point being on the eastern side of Fairway Drive at the dividing line between Lot No. 7 and Lot No. I I on the hereinafter mentioned plan of lots: thence North 34 degrees 25 minutes 00 seconds West, 52.S7 feet along the eastern side of Fairway Drive to a point.- thence North 74 degrees 32 iiiinutes 50 seconds East, 779.07 feet (erroneously referred to as 719.09 feet.in deed of prior record) along lands 110 or formerly of J. Dale Jardine. et ux to a point inarked by an iron piii,- thence South 19 degrees 03 minutes 32 seconds East, 659.51 feet... alone lands now,or formerly of Katherine A. Haas to another iron pin; thence South 6S degrees 57 minutes 20 seconds West, 275.26 feet along 3 tracts of land noIN., or forinerl-N, of belonging to: (1) Robert L. and Mildred L. Welsh: (2) Irvin F. and Edna M. Rupp: and (3) Jack R. and Mary Crull. to a point marked by a fence post: thence South 69 degrees 25 minutes 00 seconds West. 59 feet along lands now or formerly of Albert Lindsay and Lillian K. Rovvland: thence North 19 degrees 47 irliiiiites 39 seconds West. 355.14 feet along Lots Nos. 10. 9 and part of Lot No. 8, to a point: thence North 03 dec-,rees 59 minutes 22 seconds West. 150.45 feet along Lot No. 7 to a point thence South 74 degrees 32 iiiii1tites 50 seconds West. 459.72 feet along Lot No. 7 to a point on the eastern side ide of Fair%vay Drive,the place of BEGINNING. BEING LOT No. 11 in a plan of lots kno-wri as Fairway Acres, which will fiilly appear in Plan Book 55, Page 90. in the Recorder of Deed,,: Office in the Cumberland County Cow-thouse. CONTAINTR�!G 5.5559 acres. HA"VINCTerected thereon a dwelling house known as and numbered 110 Fairway Drive, Carlisle,Pennsylvania 17013. SUBJECT, nevertheless., to existing restrictions,. rights of way and easements as appear in the-plot plan and otherwise of record in the Recorder of Deeds Office in and for C'uniberland County.Pemisylvania. RB5678 110 Fairway Drive,Carlisle,Pennsylvania 17015. BEING the same premises which HENRY R. SODANO by deed dated August 25,2006 and recorded October 3, 2006 in the office of the Recorder in and for Cumberland County in Deed Book 267,Page 4803,granted and conveyed to Darryl J.Ryan and Victoria Ryan,husband and wife, in fee. TAX MAP PARCEL NUMBER:46-08-0583-114 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 12-7249 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WILMINGTON TRUST,NATIONAL ASSOCIATION, AS SUCCESSOR TRUSTEE TO CITIBANK,N.A.AS TRUSTEE FOR BEAR STEARNS ALT-A TRUST 2007-2,MORTGAGE PASS-THROUGH CERTIFICATES,SERIES 2007-2 Plaintiff(s) From DARRYL J.RYAN AND VICTORIA RYAN (1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows:. and to notify the garnishee(s)that: (a)an attachment has been issued; (b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant (s)or otherwise disposing thereof; (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $525,940.13 L.L.: $.50 Interest FROM 2/22/13-$16,859.70 AT$86.46 Atty's Comm: Due Prothy: $2.25 Atty Paid: $218.25 Other Costs: Plaintiff Paid: Date: 5/20/13 David D. Buell,Prothonotary (Seal) r Deputy REQUESTING PARTY: Name: CHRISTINE L. GRAHAM,ESQUIRE Address: MCCABE,WEISBERG AND CONWAY 123 S.BROAD STREET,SUITE 1400 PHILADELPHIA,PA 19103 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No.307169 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID# 87830 KEVIN T. MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L. GRAHAM,ESQUIRE-ID# 309480 C) ,., CD BRIAN T.LAMANNA, ESQUIRE-ID# 310321 C: { ANN E. SWARTZ,ESQUIRE-ID#201926 rr co :Z--.l JOSEPH F.RIGA,ESQUIRE-ID# 57716 :;= JOSEPH I. FOLEY, ESQUIRE-ID#314675 r"c� CELINE P. DERKRIKORIAN,ESQUIRE-ID#313673 ~1 c 123 South Broad Street, Suite 1400 MC) Philadelphia, Pennsylvania 19109 :>a C i 215 790-1010 =i C.4 Wilmington Trust,National Association,as Successor CUMBERLAND COUNTY Trustee to Citibank,N.A. as Trustee for Bear Stearns COURT OF COMMON PLEAS ALT-A Trust 2007-2,Mortgage Pass-Through Certificates, Series 2007-2 Number 12-7249 Plaintiff V. Darryl J.Ryan and Victoria Ryan Defendant AFFIDAVIT OF SERVICE OF AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned attorney for the Plaintiff in the within matter,hereby certifies that on the 25th day of July, 2013, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s)as set forth in Amended Affidavit Pursuant to 3129 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part hereof. SWORN AND SUBSCRIBED McCABE,WEISBE CONWAY,P.C. BEFO ME TH �DAY BY: [ ]Terrence J.Mc e, arc S.Weisberg,Esquire OF ,2013 ]Edward D.Conway,Esquire ]Margaret Gairo,Esquire Andrew L.Markowitz,Esquire [ ]Heidi R. Spivak,Esquire [ ]Marisa J. Cohen,Esquire [ ]Kevin T.McQuail,Esquire [ ]Christine L.Graham,Esquire [ ]Brian T.LaManna,Esquire NOTARY PUB [ ]Ann E. Swartz,Esquire [ ] Joseph F.Riga,Esquire �MMt WE �TH� OF�� , y I [ ] Joseph I.Foley,Esquire [ ] Celine P.DerKrikorian,Esquire @�®TAR 1 A 0 P b C Attorneys for Plaintiff ga6ara J.MMOyV'-l'btsry CiV o Philad*612,Ph63dC'4)hi3 Coady W'f COMMISSION EXPIRES JAN.12,2014 McCABE,WEISBERG AND;CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID# 87830 KEVIN T. MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L. GRAHAM,i ESQUIRE-ID#309480 BRIAN T. LAMANNA,ESQUIRE- ID# 31.0321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID# 57716 JOSEPH 1.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 Wilmington Trust,National Association,as Successor CUMBERLAND COUNTY Trustee to Citibank,N.A. as Trustee for Bear Stearns COURT OF COMMON PLEAS ALT-A Trust 2007-2,Mortgage Pass-Through Certificates,Series 2007-2 NO: 12-7249 Plaintiff V. Darryl J.Ryan and Victoria Ryan Defendants AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned attorney for Plaintiff in the above action sets forth the following information concerning the real property located at 110 Fairway Drive,Carlisle,Pennsylvania 17015,as of the date the Praecipe for the Writ of Execution was filed.A copy of the description of said property is attached hereto. 1. Name and address of Owners or Reputed Owners Name Address Darryl J.Ryan 2050 Danbury Drive Rock Wall,Texas 75032 Victoria Ryan 2050 Danbury Drive Rock Wall,Texas 75032 2. Name and address of Defendants in the judgment: Name Address File#53997 Page 1 Darryl J.Ryan 2050 Danbury Drive Rockwall,Texas 75032 Victoria Ryan 2050 Danbury Drive Rockwall,Texas 75032 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein JP Morgan Chase Bank,N.A. c/o Chase Home Finance LLC 3415 Vision Drive,P.O.Box 24696 Columbus,Ohio 43219-6009 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 110 Fairway Drive Carlisle,Pennsylvania 17015 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O.Box 2675 Harrisburg,PA 17105 ATTN:Dan Richard Commonwealth of Pennsylvania 110 North 8`h Street Inheritance Tax Office Suite#204 Philadelphia,PA 19107 File 953997 Page 2 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O.Box 8486 Recovery Program Harrisburg,PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg,PA 17128-1230 Compliance ATTN: Sheriffs Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 Domestic Relations . P.O.Box 320 Cumberland County Carlisle,PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton,PA 18503 and Harrisburg Federal Building&Courthouse 228 Walnut Street, Ste.220 Harrisburg,PA 17108-1754 United States of America c/o U.S.Dept.of Justice,Rm 4400 Atty General of the United States 950 Pennsylvania Avenue,NW Washington,DC 20530 United States of America c/o U.S.Dept.of Justice,Rm 5111 Atty General of the United States 950 Pennsylvania Avenue,NW Washington,DC 20530 8. Name and address of Attorney of record: Name Address File#53997 Page 3 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. July 25,2013 McCABE,WEISBERG CONWAY,P.C. DATE BY: [ ]Terrence J.McCabIrE uir Weisberg,Esquire [ ]Edward D. Conway,Esquire [ ] argaret Gairo,Esquire Andrew L.Markowitz,Esquire [ Heidi R. Spivak,Esquire [ ]Marisa J. Cohen,Esquire ]Kevin T.McQuail,Esquire [ ]Christine.L.Graham,Esquire ]Brian T.LaManna,Esquire [ ]Ann E. Swartz,Esquire ] Joseph F.Riga,Esquire [ ]Joseph I.Foley,Esquire [ ] Celine P.DerKrikorian,Esquire Attorneys for Plaintiff Re: Wilmington Trust,National Association,as Successor Trustee to Citibank,N.A. as Trustee for Bear Stearns ALT-A Trust 2007-2,Mortgage Pass-Through Certificates, Series 2007-2 v.Darryl J.Ryan.et al. Cumberland County;Number: 12-7249 File#53997 Page 4 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff. MARC S. WEISBERG,ESQUIRE-ID fl 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-1D# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 Wilmington Trust,National Association,as Successor COURT OF COMMON PLEAS Trustee to Citibank,N.A.as Trustee for Bear Steams CUMBERLAND COUNTY ALT-A Trust 2007-2,Mortgage Pass-Through Certificates,Series 2007-2 Plaintiff Number 12-7249 V. Darryl J.Ryan and Victoria Ryan Defendants DATE:July 25,2013 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS:Darryl J.Ryan and Victoria Ryan PROPERTY: 110 Fairway Drive,Carlisle,Pennsylvania 17015 IMPROVEMENTS:Residential Dwelling JUDGMENT AMOUNT:$525,940.13 The above-captioned property is scheduled to be sold pursuant to the judgment of the court caption above at the Sheriffs Sale on September 4,2013 at 10:00 a.m.in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, I Courthouse Square,Carlisle,Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on,and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty(30)days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10)days after the filing of the schedule. If you have any questions regarding the type of lien or the effect of the Sheriffs Sale upon your lien,we urge you to CONTACT YOUR OWN ATTORNEY as WE ARE NOT PERMITTED TO GIVE YOU LEGAL ADVICE. Check type of mail or service: ,r U.S.POSTAGE>>PITNEY BOWES Name and Address of Sender 17 Certified ❑Recorded Delivery(International) s A� McCabe,Weisberg and Conway,P.C. ❑COD ❑Registered 123'S.nroad St.,Suite 2080 0 Delivery Confirrnation ❑Return Receipt for Merchandise 4A ❑Express Mail ❑Signature Confirmation ZIP 19109 $ 018.00 { Philadelphia,PA 19109 0 Express VVV 11 ATTN:K.Keller-53997 R 02 IR 0001377494JUL. 26. 2013 Line Article Number Postage 1 Wilmington Trust, JP Morgan Chase Bank,N.A. National Association,as c/o Chase Home Finance LLC Successor Trustee to 3415 Vision Drive,P.O.Box 24696 Citibank,N.A.as Trustee Columbus,Ohio 43219-6009 for Bear Stearns ALT-A Trust 2007-2,Mortgage Pass-Through Certificates,Series 2007-2 Plaintiff V. Darryl J.Ryan and Victoria Ryan Defendants 2 Tenants/Occupants 110 Fairway Drive Carlisle,Pennsylvania 17015 3 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg,PA 17105 ATTN: Dan Richard Commonwealth of Pennsylvania 4 Inheritance Tax Office 110 North 8"Street Suite#204 Philadelphia,PA 19107 5 Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division 6th Floor,Strawberry Square Department#280601 Harrisburg,PA 17128 6 Department of Public Welfare TPL Casualty Unit Estate Recovery Program Willow Oak Building P.O.Box 8486 Harrisburg,PA 17105-8486 7 PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 8 PA Department of Revenue Bureau of Compliance Lien Section PO BOX 280948 Harrisburg PA 17128-0948 9 Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Clearance Support Department 281230 Harrisburg,PA 17128-1230 ATTN: Sheriff's Sales 10 United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 11 Domestic Relations Cumberland County P.O.Box 320 Carlisle,PA 17013 12 United States of America c/o United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue,Ste.311 Scranton,PA 18503 13 Harrisburg Federal Building&Courthouse 228 Walnut Street,Ste.220 Harrisburg,PA 17108-1754 14 United States of America c/o Atty General of the United States a U.S.Dept.of Justice,Rm 4400 �C 950 Pennsylvania Avenue,NW 1,� Washington,DC 20530 o 15 United States of America c/o Atty General of the United States NoI1dLy' U.S.Dept.of Justice,Rm 5111 950 Pennsylvania Avenue,NW Washington,DC 20530 Total Number of Pieces Listed by Sender f� C 15 f > COURT OF COMMON PLEAS OF PENNSYLVANIA, CUMBER COUNTY L.W OTHONOTAR) WILMINGTON TRUST,NATIONAL ASSOCIATION,AS 2013 �� 109 SUCCESSOR TRUSTEE TO CITIBANK,N.A.AS Case No.: � �LQNQ COUNT TRUSTEE FOR BEAR STEARNS ALT-A TRUST 2007-2, MORTGAGE PASS-THROUGH CERTIFICATES,SERIES PENNYLVANiA 2007-2, AFFIDAVIT OF SERVI Plaintiff(s), VS. DARRYL J.RYAN,et al., Defendant(s). 92113 STATE OF -C�G� County of -T) L S ss: the undersigned being duly sworn,deposes and says that I was at the time of service over the age of eighteen and not a party to this action. On at AM/ M, served the within NOTICE OF SHERIFF'S SALE OF REAL PROPERTY on DARRYL J.RYA 2050 DANBURY DRIVE,ROCKWALL,TX 75032,in 9-Gthe m nner indicated below: (J� PERSONAL SERVICE: By delivering thereat a true copy of the aforementioned documents to said recipient personally;deponent knew the person so served to be the person described herein by deponent asking if he or she is the named Recipient and the person responding that he or she is in fact the person named in this action as the Recipient. [SUITABLE AGE SERVICE: By delivering thereat a true copy of the aforementioned documents to a person of suitable age and discretion at the above address which is DARRYL J.RYAN's usual place of residence/place of abode/place of business,with: ` Recipient's Name: V t 4oriQ 1�qw) > Relationship: C n-C)C)r-u t>CJLA a family member or other person at said address. ❑ POSTED IN ACCORDANCE WITH COURT ORDER: I affixed thereat a true copy of the aforementioned documents in a conspicuous manner at the above address in accordance with the court order, Q PREVIOUS ATTEMPTS: I previously attempted to serve the above named defendant on at AM/PM,on ,at AM/PM,and on ,at AM/PM. Additional Comments: Description of person process was left with: Sex: — Skin/Race: AC01 6-n —Approx.Age: "ID- Hair Color: lr�l L_ _Height:S Weight: Other: Is defendant in the military?YES ❑NO ❑ - X Signet' d s orn &ree n r' 1 �q this 1 a of 20 0,0� Vy))' M(Print Namej VV "K Notd4y Public .0,191111„ Firm Ref#:267-0832PA ,W7g�;., CYNTHIA GAMLIN ROSSER N9 Ft Notary Public,State of Texas McCabe,Weisberg&Conway,P.C.CID#28 My Commission Expires 123 S.Broad Street October 24, 2016 Philadel hia PA 19109 COURT OF COMMON PLEAS OF PENNSYLVANIA, CUMBERLAND C, COUNTY c C= -O:r w WILMINGTON TRUST,NATIONAL ASSOCIATION,AS zrn M SUCCESSOR TRUSTEE TO CITIBANK,N.A.AS M= -0 TRUSTEE FOR BEAR STEARNS ALT-A TRUST 2007-2, Case No.: 12-7249 --<> r� MORTGAGE PASS-THROUGH CERTIFICATES,SERIES r--= •--I c— 2007-2, AFFIDAVIT OF SERVICE <o .L � - C:) Plaintiff(s), VS. ; . DARRYL J.RYAN,et al., Defendant(s). 92114 STATE OF County of ss: O.A,y I the undersigned being duly sworn,deposes and says that I was at the time of service over the age of eighteen and not a party to this action. On 1 at 1 AM I served the within NOTICE OF SHERIFF'S SALE OF REArPROVERTY on VICTORIA RYA at 2050 DANBURY DRIVE,ROCKWALL,TX 75032,in the manner indicated below: PERSONAL SERVICE:By delivering thereat a true copy of the aforementioned documents to said recipient personally;deponent knew the person so served to be the person described herein by deponent asking if he or she is the named Recipient and the person responding that he or she is in fact the person named in this action as the -_1 ecipient. GMSUITABLE AGE SERVICE: By delivering thereat a true copy of the aforementioned documents to a person of suitable age and discretion at the above address which is VICTORIA RYAN's usual place of residence/place of abode/place of business,with: Recipient's Name: Relationship: ,a family member or other person at said address. ❑ POSTED IN ACCORDANCE WITH COURT ORDER:I affixed thereat a true copy of the aforementioned documents in a conspicuous manner at the above address in accordance with the court order. ❑ PREVIOUS ATTEMPTS: I previously attempted to serve the above named defendant on ,at AM/PM,on at AM/PM,and on ,at AM/PM. Additional Comments: Description of person process was left with: `-` Sex: Skin/Race: Approx.Age: 1-Ea Hair Color:bla Height:S�_ Weight: Other: Is defendant in the military?YES ❑NO❑ X am Sign"d swo o b gr n Nis j I day 2 1 (Print Name)' Not Public CYNTHIA GAM1,1N ROSSER Notary Aublib,$tote of Texas Firm Ref#:267-0832PA ;o.• c�= my commission Expires McCabe,Weisberg&Conway,P.C.CID#28 October 24, 2016 123'S.Broad Street """"� Philadelphia,PA 19109 ' McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 ; MARISA J.COHEN,ESQUIRE-ID#87830 �,':.m '.. KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 Z c.ANN E. SWARTZ,ESQUIRE-ID#201926 £ 2 JOSEPH F. RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 Wilmington Trust,National Association,as Successor Trustee to CUMBERLAND COUNTY Citibank,N.A.as Trustee for Bear Stearns ALT-A Trust 2007-2, COURT OF COMMON PLEAS Mortgage Pass-Through Certificates,Series 2007-2 Plaintiff Number 12-7249 v. Darryl J.Ryan and Victoria Ryan Defendant AFFIDAVIT OF SERVICE OF AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned attorney for the Plaintiff in the within matter,hereby certifies that on the 10th day of October,2013, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder - forth in Amended Affidavit Pursuant to 3129 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailin:is . o attac hed, . . . :de a part : eof. SWORN AND SUBSCRIBED McCABE,WEISBERG AND 'ONWA ,P.C. BEFORE ME TH S LAY BY: j [ ]Terrence J �� bf, :111-Fe' [ ]Marc S.Weisberg,Esquire OF in . ' ,20 [ ]Edward D.Conway,Esquire [ ]Margaret Gairo,Esquire [ ]Andrew L.Markowitz,Esquire [ ]Heidi R.Spivak,Esquire - [ ]Marisa J.Cohen,Esquire [ ]Kevin T.McQuail,Esquire 0 .4 [ ]Christine L.Graham,Esquire [ ]Brian T.LaManna,Esquire N• ARY PUBLIC [ ]Ann E.Swartz,Esquire COMM> WEALTH OF PENNSYLVA Swartz Es 4 [Joseph F.Riga,Esquire NOTARIAL SEAL [ ]Joseph I.Foley,Esquire [ ]Celine P.DerKrikorian,Esquire RHONDELSHA SMITH,Notary Public Attorneys for Plaintiff City of Philadelphia,Phda.t 5,"2017 McCABE,WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID# 34687 MARGARET GAIRO, ESQUIRE- ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID# 87830 KEVIN T. MCQUAIL, ESQUIRE-ID# 307169 CHRISTINE L. GRAHAM, ESQUIRE-ID# 309480 BRIAN T. LAMANNA, ESQUIRE-ID# 310321 ANN E. SWARTZ, ESQUIRE- ID#201926 JOSEPH F. RIGA, ESQUIRE- ID# 57716 JOSEPH I. FOLEY, ESQUIRE- ID#314675 CELINE P. DERKRIKORIAN, ESQUIRE-ID# 313673 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wilmington Trust,National Association,as Successor CUMBERLAND COUNTY Trustee to Citibank,N.A. as Trustee for Bear Stearns COURT OF COMMON PLEAS ALT-A Trust 2007-2,Mortgage Pass-Through Certificates, Series 2007-2 NO: 12-7249 Plaintiff v. Darryl J.Ryan and Victoria Ryan Defendants AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned attorney for Plaintiff in the above action sets forth the following information concerning the real property located at 110 Fairway Drive,Carlisle,Pennsylvania 17015,as of the date the Praecipe for the Writ of Execution was filed.A copy of the description of said property is attached hereto. 1. Name and address of Owners or Reputed Owners Name Address Darryl J. Ryan 2050 Danbury Drive Rock Wall,Texas 75032 Victoria Ryan 2050 Danbury Drive Rock Wall,Texas 75032 2. Name and address of Defendants in the judgment: Name Address File 453997 Page 1 Darryl J. Ryan 2050 Danbury Drive Rockwall, Texas 75032 Victoria Ryan 2050 Danbury Drive Rockwall, Texas 75032 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein American Express 200 Vesey Street New York,NY 10285 FIA Card Services 4161 Piedmont PKWY Greensboro,NC 27410 Wilmington Trust National Assoc. 82 E Main St Newark, DE 19711 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein JP Morgan Chase Bank,N.A. c/o Chase Home Finance LLC 3415 Vision Drive,P.O. Box 24696 Columbus,Ohio 43219-6009 MERS PO BOX 2026 Flint,MI 48501 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest File#53997 Page 2 in the property which may be affected by the sale: Name Address Tenants/Occupants 110 Fairway Drive Carlisle,Pennsylvania 17015 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O.Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard Commonwealth of Pennsylvania 110 North 8`"Street Inheritance Tax Office Suite#204 Philadelphia,PA 19107 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O.Box 8486 Recovery Program Harrisburg,PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg,PA 17128-1230 PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg,PA 17128-1230 Compliance ATTN: Sheriff's Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 File#53997 Page 3 Domestic Relations P.O. Box 320 Cumberland County Carlisle, PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton,PA 18503 and Harrisburg Federal Building&Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 United States of America c/o U.S.Dept. of Justice,Rm 4400 Atty General of the United States 950 Pennsylvania Avenue,NW Washington,DC 20530 United States of America c/o U.S.Dept.of Justice,Rm 5111 Atty General of the United States 950 Pennsylvania Avenue,NW Washington,DC 20530 8. Name and address of Attorney of record: Name Address None File#53997 Page 4 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to th• e •alties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. October 10,2013 McCABE,WEISBRG A C P 4,P,C. DATE BY: [ ]Terrence J. s e,Es I uire [ ] .rc S. Weisberg,Esquire [ ] Edward D. Conway,Esquire [ ]Margaret Gairo,Esquire [ ]Andrew L.Markowitz,Esquire [ ]Heidi R. Spivak,Esquire [ ]Marisa J. Cohen,Esquire [ ]Kevin T.McQuail,Esquire [ ]Christine L. Graham,Esquire [ ] Brian T. LaManna, Esquire [ ]Ann E. Swartz, Esquire [,& Joseph F. Riga,Esquire [ ] Joseph I. Foley,Esquire [ ] Celine P. DerKrikorian, Esquire Attorneys for Plaintiff Re: Wilmington Trust,National Association,as Successor Trustee to Citibank,N.A. as Trustee for Bear Stearns ALT-A Trust 2007-2,Mortgage Pass-Through Certificates, Series 2007-2 v. Darryl J. Ryan. et al. Cumberland County;Number: 12-7249 File#53997 Page 5 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 Wilmington Trust,National Association,as Successor Trustee COURT OF COMMON PLEAS to Citibank,N.A.as Trustee for Bear Stearns ALT-A Trust CUMBERLAND COUNTY 2007-2,Mortgage Pass-Through Certificates,Series 2007-2 Plaintiff v. Number 12-7249 Darryl J.Ryan and Victoria Ryan Defendants DATE:October 10,2013 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS:Darryl J.Ryan and Victoria Ryan PROPERTY: 110 Fairway Drive,Carlisle,Pennsylvania 17015 IMPROVEMENTS:Residential Dwelling JUDGMENT AMOUNT:$525,940.13 The above-captioned property is scheduled to be sold pursuant to the judgment of the court caption above at the Sheriffs Sale on September 4,2013 at 10:00 a.m.in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square,Carlisle,Pennsylvania 17013.Our records indicate that you may hold a mortgage or judgments and liens on,and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty(30)days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten(10)days after the filing of the schedule. If you have any questions regarding the type of lien or the effect of the Sheriffs Sale upon your lien,we urge you to CONTACT YOUR OWN ATTORNEY as WE ARE NOT PERMITTED TO GIVE YOU LEGAL ADVICE. .• Vt ,19• ,. - © m y F..W n ra 1"3 d•y A V Z-�co o.a v cam° a A Q@ L1 C 'N- e :.a rn-, ro„gin• AO Y� AA a rD ti Fir °° CD A W Ni r. s� aCA N 'p 0o a ° "'300 Z °� 9 I � CD 9. 00 9.0 y �9.1• CM C�N� = ~ 0 V_ 0:1 O AN,CD •� O- O . . y . , ,n v ,A OR! � NtOoifD CG 9� _ nr C = U = �= fD CD Ow CD cm eli.04 00 nA ZN� 0 ❑❑❑n fD N� . 9,� fD n 5 K d p n P C O r DD 7Q C CD 9 5 et, A- 8 8 (o N i Z �n co Z.(,� o w 0C el) • r J y .o 7, -'�,,I, ❑ ❑❑❑N eo v , d°N.o MG,2.A7 �+ E dg,^ $p. — . d O c R n, A9 ° z I. ,4 5 . a 3 n r.- N J a otia ���'�P9��Qr i • • OON �������� C ONE (n O Q V) W co J -0(0 0 � � IC m ° o � I ' o l � 4I Z 0iN o o O w O iii McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ` ANN E.SWARTZ,ESQUIRE-ID#201926 rT1` ? T, ,.. ■JOSEPH F.RIGA,ESQUIRE-ID#57716 mil` r-- JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 lc7 —o 123 South Broad Street,Suite 1400 t- r Philadelphia,Pennsylvania 19109 (215)790-1010 Wilmington Trust,National Association,as Successor Trustee to CUMBERLAND COUNTY Citibank,N.A.as Trustee for Bear Stearns ALT-A Trust 2007-2, COURT OF COMMON PLEAS Mortgage Pass-Through Certificates,Series 2007-2 Plaintiff Number 12-7249 v. Darryl J.Ryan and Victoria Ryan Defendant AFFIDAVIT OF SERVICE OF AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned attorney for the Plaintiff in the within matter,hereby certifies that on the 25th day of July,2013, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s)as set forth in Amended Affidavit Pursuant to 3129 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing i r•1 .��•: . : -to and made a art -reo£ SWORN AND SUBSCRIBED MICA ,WEISBERG AND CO�'` ,P '. BEFORE ME THIS LJ DAY BY: h [ ]Terrence J.McCa,,?;q;AOir [ ] arc S.Weisberg,Esquire OF k U / 201 [ ]Edward D.Co.e ay,E . ire [ ]Margaret Gairo,Esquire [ ]Andrew L.Markowitz,Esquire [ ]Heidi R.Spivak,Esquire [ ]Marisa J.Cohen,Esquire [ ]Kevin T.McQuail,Esquire [ ]Christine L.Graham,Esquire [ ]Brian T.LaManna,Esquire NOTARY PUBLIC [ ]Ann E.Swartz,Esquire Joseph F.Riga,Esquire COMMONWEALTH OF PENNSYLVANIA [ ]Joseph I.Foley,Esquire [ ]Celine P.DerKrikorian,Esquire NOTARIAL SEAL Attorneys for Plaintiff RHONDEtSHA SMITH,Notary Public City of Philadelphia,Phila.County My Commission Expires August 5,2017 McCABE, WEISBERG AND'CONWAY, P.C. BY: TERRENCE J. McCABE,'ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN, ESQUIRE-ID# 87830 KEVIN T. MCQUAIL,ESQUIRE-ID# 307169 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T. LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F. RIGA, ESQUIRE-ID# 57716 JOSEPH I. FOLEY,ESQUIRE-ID#314675 CELINE P. DERKRIKORIAN,ESQUIRE-ID# 313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 (215) 790-1010 Wilmington Trust,National Association,as Successor CUMBERLAND COUNTY Trustee to Citibank,N.A. as Trustee for Bear Stearns COURT OF COMMON PLEAS ALT-A Trust 2007-2,Mortgage Pass-Through Certificates, Series 2007-2 NO: 12-7249 Plaintiff v. Darryl J. Ryan and Victoria Ryan Defendants AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned attorney for Plaintiff in the above action sets forth the following information concerning the real property located at 110 Fairway Drive,Carlisle,Pennsylvania 17015,as of the date the Praecipe for the Writ of Execution was filed.A copy of the description of said property is attached hereto. 1. Name and address of Owners or Reputed Owners Name Address Darryl J.Ryan 2050 Danbury Drive Rock Wall,Texas 75032 Victoria Ryan 2050 Danbury Drive Rock Wall,Texas 75032 2. Name and address of Defendants in the judgment: Name Address File#53997 Page 1 Darryl J.Ryan 2050 Danbury Drive Rockwall,Texas 75032 Victoria Ryan 2050 Danbury Drive Rockwall, Texas 75032 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein American Express 200 Vesey Street New York,NY 10285 FIA Card Services 4161 Piedmont PKWY Greensboro,NC 27410 Wilmington Trust National Assoc. 82 E Main St Newark, DE 19711 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein JP Morgan Chase Bank,N.A. c/o Chase Home Finance LLC 3415 Vision Drive,P.O.Box 24696 Columbus,Ohio 43219-6009 MERS PO BOX 2026 Flint,MI 48501 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest File#53997 Page 2 in the property which may be affected by the sale: Name Address Tenants/Occupants 110 Fairway Drive Carlisle,Pennsylvania 17015 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O.Box 2675 Harrisburg,PA 17105 ATTN: Dan Richard Commonwealth of Pennsylvania 110 North 8`h Street Inheritance Tax Office Suite#204 Philadelphia,PA 19107 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O.Box 8486 Recovery Program Harrisburg,PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg,PA 17128-1230 Compliance ATTN: Sheriff's Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 File#53997 Page 3 Domestic Relations P.O.Box 320 Cumberland County Carlisle,PA 17013 United States of America do United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue, Ste.311 Scranton,PA 18503 and Harrisburg Federal Building&Courthouse 228 Walnut Street, Ste.220 Harrisburg, PA 17108-1754 United States of America do U.S.Dept. of Justice,Rm 4400 Atty General of the United States 950 Pennsylvania Avenue,NW Washington,DC 20530 United States of America do U.S. Dept.of Justice,Rm 5111 Atty General of the United States 950 Pennsylvania Avenue,NW Washington,DC 20530 8. Name and address of Attorney of record: Name Address None File#53997 Page 4 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. November 1,2013 McCABE • ISBERG .i�''1 CONW-A ,P.C. DATE [ ] Terrence J. ■ ,.e, ' ire [ ] Marc S. Weisberg,Esquire [ ]Edward D. onway,Esquire [ ]Margaret Gairo,Esquire [ ]Andrew L.Markowitz,Esquire [ ]Heidi R. Spivak,Esquire [ ] Marisa J. Cohen,Esquire [ ] Kevin T.McQuail,Esquire [ ] Christine L. Graham,Esquire [ ]Brian T.LaManna,Esquire [ ]Ann E. Swartz,Esquire [k Joseph F.Riga,Esquire [ ]Joseph I. Foley,Esquire [ ] Celine P.DerKrikorian,Esquire Attorneys for Plaintiff Re: Wilmington Trust,National Association,as Successor Trustee to Citibank,N.A.as Trustee for Bear Stearns ALT-A Trust 2007-2,Mortgage Pass-Through Certificates, Series 2007-2 v.Darryl J. Ryan. et al. Cumberland County;Number: 12-7249 File#53997 Page 5 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 Wilmington Trust,National Association,as Successor COURT OF COMMON PLEAS Trustee to Citibank,N.A.as Trustee for Bear Stearns ALT-A CUMBERLAND COUNTY Trust 2007-2,Mortgage Pass-Through Certificates,Series 2007-2 Plaintiff v. Number 12-7249 Darryl J.Ryan and Victoria Ryan Defendants DATE:November 1,2013 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS:Darryl J.Ryan and Victoria Ryan PROPERTY: 110 Fairway Drive,Carlisle,Pennsylvania 17015 IMPROVEMENTS:Residential Dwelling JUDGMENT AMOUNT:$525,940.13 25 The above-captioned property is scheduled to be sold pursuant to the judgment of the court caption above at the Sheriffs Sale on December 4,2013 at 10:00 a.m.in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square,Carlisle,Pennsylvania 17013.Our records indicate that you may hold a mortgage or judgments and liens on,and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty(30)days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten(10)days after the filing of the schedule. YOUR OWNy AgTTORNEYasdWEtAREpNOTiPERMITTED of GIVE YOU LEGALyADVIC We urge you to CONTACT W O M m W ON • } O _Z 1 i( 8 w � �z 0 . W M CL O NOO • ,L ti• r T { a1. I • I 0770-9997 V E s c °" I Ca' ,- > G G 0 N Q Chi U C 11 9 c)c m ifiC L d i••1 a I C e%1 W N 4: W {% Z .!Ii\-' --.. c •f6 Y 4 a Z V el o Z Q W > c6 i cu 0 u0 a, 5' W 3 Q t0 0: E 0 d c c_.)000 ❑❑ 3 0o Z Y. Q N Z v, ea ea y- et y =N •yam CH • L�.bA0 2 co y CJ CSC vim.., 0 LN i = •.. sz,Z c v w .0. O �� C $.NF.Lw C C o y CI 1:1 a 7 d V � E h ez C C> 6e '"i - = E � by 4.0 F. C� = o i 0 0 1.--- =; 2E.E* A 0 EUo o, EQ.N M y Law),-1 6) 0 u 9�`o'ax E A GO Q3 7 d M oL4 z Y4MAF - CR. z :4ad ' McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 ��k f MARGARET GAIRO,ESQUIRE-ID# 34419 `- ' ` J 2: ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 f + L t L tr; r (y, yr HEIDI R. SPIVAK,ESQUIRE-ID#74770 C dal a�J Y L VA A MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 Wilmington Trust,National Association,as Successor Trustee to CUMBERLAND COUNTY Citibank,N.A.as Trustee for Bear Steams ALT-A Trust 2007-2, COURT OF COMMON PLEAS Mortgage Pass-Through Certificates,Series 2007-2 Plaintiff Number 12-7249 V. Darryl J.Ryan and Victoria Ryan Defendant AFFIDAVIT OF SERVICE OF AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned attorney for the Plaintiff in the within matter,hereby certifies that on the 1st day of November,2013, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s)as set forth in Amended Affidavit Pursuant to 3129 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part hereof. SWORN AND SUBSCRIBED McCABE,WEISBERG AND CONWAY,IP✓�C.�_N BEFORE ME THIS r DAY BY; [ ]Terrence J.McCabe,Esquire [ Marc S.Weisberg,Esquire OF/1 l JY[ -2013 [ ]Edward D.Conway,Esquire [ ]Margaret Gairo,Esquire [ ]Andrew L.Markowitz,Esquire [ ]Heidi R.Spivak,Esquire [ ]Marisa J.Cohen,Esquire [ ]Kevin T.McQuail,Esquire [ ]Christine L.Graham,Esquire [ ]Brian T.LaMantia,Esquire OTAVIUBLIC [ ]Ann E.Swartz,Esquire [ ]Joseph F.Riga,Esquire [ ]Joseph I.Foley,Esquire [ ]Celine P,DerKrikorian,Esquire Attorneys for Plaintiff McCABE,WEISBERG kNDLONWAY,P.C. BY: TERRENCE J. McCABE,'.'ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID# 87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T. LAMANNA,ESQUIRE-ID# 310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I. FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 Wilmington Trust,National Association,as Successor CUMBERLAND COUNTY Trustee to Citibank,N.A. as Trustee for Bear Stearns COURT OF COMMON PLEAS ALT-A Trust 2007-2,Mortgage Pass-Through Certificates,Series 2007-2 NO: 12-7249 Plaintiff V. Darryl J.Ryan and Victoria Ryan Defendants AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned attorney for Plaintiff in the above action sets forth the following information concerning the real property located at 110 Fairway Drive,Carlisle,Pennsylvania 17015,as of the date the Praecipe for the Writ of Execution was filed.A copy of the description of said property is attached hereto. 1. Name and address of Owners or Reputed Owners Name Address Darryl J. Ryan 2050 Danbury Drive Rock Wall,Texas 75032 Victoria Ryan 2050 Danbury Drive Rock Wall,Texas 75032 2. Name and address of Defendants in the judgment: Name Address File#53997 Page 1 Darryl J. Ryan 2050 Danbury Drive Rockwall,Texas 75032 Victoria Ryan 2050 Danbury Drive Rockwall,Texas 75032 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein American Express 200 Vesey Street New York,NY 10285 FIA Card Services 4161 Piedmont PKWY Greensboro,NC 27410 Wilmington Trust National Assoc. 82 E Main St Newark, DE 19711 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein JP Morgan Chase Bank,N.A. c/o Chase Home Finance LLC 3415 Vision Drive,P.O.Box 24696 Columbus,Ohio 43219-6009 MERS PO BOX 2026 Flint,MI 48501 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest File#53997 Page 2 in the property which may be affected by the sale: Name Address Tenants/Occupants 110 Fairway Drive Carlisle,Pennsylvania 17015 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O.Box 2675 Harrisburg,PA 17105 ATTN: Dan Richard Commonwealth of Pennsylvania 110 North 8'h Street Inheritance Tax Office Suite#204 Philadelphia,PA 19107 Commonwealth of Pennsylvania 6th Floor,Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O.Box 8486 Recovery Program Harrisburg,PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg,PA 17128-1230 Compliance ATTN: Sheriffs Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 File#53997 Page 3 Domestic Relations P.O.Box 320 Cumberland County Carlisle,PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue,Ste.311 Scranton,PA 18503 and Harrisburg Federal Building&Courthouse 228 Walnut Street,Ste.220 Harrisburg,PA 17108-1754 United States of America c/o U.S.Dept.of Justice,Rm 4400 Atty General of the United States 950 Pennsylvania Avenue,NW Washington,DC 20530 United States of America c/o U.S.Dept.of Justice,Rm 5111 Atty General of the United States 950 Pennsylvania Avenue,NW Washington,DC 20530 8. Name and address of Attorney of record: Name Address None File 953997 Page 4 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. November 15,2013 McCABE,WEISBERG AND CONWAY,P.C. DATE BY: [ ]Terrence J.McCabe,Esquire [Li4arc S.Weisberg,Esquire [ ]Edward D.Conway,Esquire [ ]Margaret Gairo,Esquire [ ]Andrew L.Markowitz,Esquire [ ]Heidi R. Spivak,Esquire [ ]Marisa J.Cohen,Esquire [ ]Kevin T.McQuail,Esquire [ ]Christine L. Graham,Esquire [ ]Brian T.LaManna,Esquire [ ]Ann E. Swartz,Esquire [ ]Joseph F.Riga,Esquire [ ] Joseph I.Foley,Esquire [ ] Celine P.DerKrikorian,Esquire Attorneys for Plaintiff Re:Wilmington Trust,National Association,as Successor Trustee to Citibank,N.A. as Trustee for Bear Stearns ALT-A Trust 2007-2,Mortgage Pass-Through Certificates, Series 2007-2 v.Darryl J.Ryan.et al. Cumberland County;Number: 12-7249 File#53997 Page 5 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 I-IEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 Wilmington Trust,National Association,as Successor COURT OF COMMON PLEAS Trustee to Citibank,N,A,as Trustee for Bear Stearns ALT-A CUMBERLAND COUNTY Trust 2007-2,Mortgage Pass-Through Certificates,Series 2007-2 Plaintiff V. Number 12-7249 Darryl J.Ryan and Victoria Ryan Defendants DATE:November 1,2013 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS:Darryl J.Ryan and Victoria Ryan PROPERTY: 110 Fairway Drive,Carlisle,Pennsylvania 17015 IMPROVEMENTS: Residential Dwelling JUDGMENT AMOUNT:$525,940.13 25 The above-captioned property is scheduled to be sold pursuant to the judgment of the court caption above at the Sheriffs Sale on December 4,2013 at 10:00 a.m.in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square,Carlisle,Pennsylvania 17013.Our records indicate that you may hold a mortgage or judgments and liens on,and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty(30)days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten(10)days after the filing of the schedule. uu� Y6UI2 OWNyAgiufO�l]ElasasWE AR) pNOTiPERMI�IeTED TO GIVE`YOU LEGALYADVICt We urge you to CONTACT i (mow n to ^x LU 0) m co uj 00 cz rvo� k ❑ u z 01 ar .-4 �❑ 1= o�C O O CL to CA p z m (A O C c fYiC Q a W .L. ; SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff �xop of Csrlt1j)" �� 'o �i Jody S Smith , Chief Deputy Richard W Stewart M11" Solicitor OFFICE OF THE SRERIFF P t'S Y VA 14 C Wilmington Trust National Association Case Number vs. Darryl Ryan (et al.) 2012-7249 SHERIFF'S RETURN OF SERVICE 06/27/2013 04:36 PM - Deputy Jason Kinsler, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 110 Fairway Drive, West Pennsboro Township, Carlisle, PA 17015, Cumberland County. 08/28/2013 As directed by Terrance McCabe,Attorney for the Plaintiff, Sheriffs Sale Continued to 11/6/2013 11/01/2013 As directed by Terrance McCabe,Attorney for the Plaintiff, Sheriffs Sale Continued to 12/4/2013 12/04/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania on December 04, 2013 at 10:00 AM. He sold the same for the sum of$1.00 to Attorney Terrance McCabe, on behalf of Wilmington Trust Company, successor trustee to Citibank, N.A., as Trustee f/b/o holders of Structured Asset Mortgage, being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $1,174.46 SO ANSWERS, January 10, 2014 RON W R ANDERSON, SHERIFF 70 (c)CountySuite Sheriff,Teleosoft,Inc. On May 30, 2013 the Sheriff levied upon the defendant's interest in the real property situated in West Pennsboro Township, Cumberland County, PA, Known and numbered as, 110 Fairway Drive, Carlisle as Exhibit "A" filed with this writ and by this Reference incorporated herein. Date: May 30, 2013 By: � : � Real Estate Coordinator LXII 30 CUMBERLAND LAW JOURNAL 07/26/13 2012-7249 Civil Term Lot no. 7 to a point on the eastern side of Fairway Drive, the place of WILMINGTON TRUST NATIONAL BEGINNING. ASSOCIATION BEING LOT No. 11 in a plan of lots vs. known as Fairway Acres,which will DARRYL RYAN,Victoria S.Ryan fully appear in Plan Book 55, Page Atty.:Terrance McCabe 90,in the Recorder of Deeds Office in the Cumberland County Courthouse. ALL THAT CERTAIN tract of CONTAINING 5.5559 acres,HAV- land with the improvements erected ING erected thereon a dwelling house thereon situate in West Pennsboro known and numbered 110 Fairway Township, Cumberland County, Drive,Carlisle,Pennsylvania 17013. Pennsylvania, bounded and de- SUBJECT, nevertheless, to ex- scribed as follows: isting restrictions, rights of way BEGINNING at a point,said point and easement as appear in the plot being on the eastern side of Fairway plan and otherwise of record in the Drive at the dividing line between Lot Recorder of Deeds Office in and for No. 7 and Lot No. 11 on the herein- after mentioned plan of lots;thence Cumberland County,Pennsylvania. North 34 degrees 25 minutes 00 sec- BEING the same property acquired onds West,52.87 feet along the east- by Darryl J.Ryan and Victoria Ryan, ern side of Fairway Drive to a point; by Deed Recorded 10/03/2006, of thence North 74 degrees 32 minutes record in Deed Book 276,Page 4803, 50 seconds East, 779.07 feet (er- in the Office of the Recorder of Cum- roneously referred to as 719.09 feet berland County,Pennsylvania. in deed of prior record) along lands nor or formerly of J.Dale Jardine,et ux to a point marked by an iron pin; thence South 19 degrees 03 minutes 32 seconds East, 659.51 feet, along lands nor or formerly of Katherine A. Haas to another iron pin; South 68 degrees 57 minutes 20 seconds West, 275.26 feet along 3 tracts of land now or formerly of belonging to: (1) Robert L. and Mildred L. Welsh; (2) Irvin F. and Edna M. Rupp; and (3)Jack R.and Mary Crull,to a point marked by a fence post;thence South 69 degrees 25 minutes 00 seconds West, 59 feet along lands now or formerly of Albert Lindsay and Lillian K.Rowland;thence North 19 degrees 47 minutes 39 seconds West,355.14 feet along Lots Nos. 10,9 and part of Lot No.8,to a point thence North 03 degrees 59 minutes 22 seconds West, 150.45 feet along Lot No.7 to a point; thence South 74 degrees 32 minutes 50 seconds West, 459.72 feet along 93 n PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952,been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 26, August 2 and August 9, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time,place and character of publication are true. Lisa Marie Cole, Editor SWORN TO AND SUBSCRIBED before me this 9 day of August, 2013 ���Z i Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 The Patriot-News Co. • ` ` 1900 Patriot,Drive i4e Patr1ot~Xew5 I�fe6hanicsburg, PA 17050 Inquiries - 717-255-8213 Now YOU know CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Michael J. Morrow, being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 1900 Patriot Drive, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317. 2012-7249 Civil Term WILM L This ad ran on the date(s)shown below: ToARRYL TON TRUST NATION ASSOCIATION 07/28/13 VS. RYAN 08/04113 Victoria S.Ryan Any: Terrance McCabe s 08/11/13 ALL THAT dCERTAINetract Of land tu with in West Pennsboro Township County, Penn p nded land describert as follows:ania, bounded and BEGINNING at a point,said point being Sworn(a ubscriberreme day of August, 2013 A.D. on the eastern side of Faitway Drive at the dividing line between Lot No 7 and It No.I1 on the hereinafter mentioned plan of lots;thence North 34 degrees 25 minutes 00 seconds West,52.87 feet along the eastern (:77 t llc side of Fairway Drive to a point; thence North 74 degrees 32 minutes 50 seconds East, 779.07 feet(erroneously referred to as 719.09 feet in deed of prior record)along lands nor or formerly of J.-Dale Jardine,et ux to a COMMONWEALTH OF PENNGYLVANIA Point marked by an iron pin.thence South 19 Notarial Seal degrees 03 minutes 32 seconds East,659.51 Warfel,Notary Public feet,along stoa lands norOrformerlyofKatherine Twp.,Dauphin County A.Haas to anotheriron in'South 68 degrees 57minutes20seco commission Expires Dec.12,2016 75.26 feet along M ASSOCIATION OF NOTARIES 3 tracts of land now or formerly of belonging to:(7)Roberti and Mildred L.Welsh;(2) Irvin F.and Edna M.Rupp;and(3)Jack R. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: 1, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Wilmington Trust Co, successor trustee to Citibank,NA as Trustee f/b/o holders of Structured Asset Mortgage is the grantee the same having been sold to said grantee on the 4th day of December A.D., 2013, under and by virtue of a writ Execution issued on the 20th day of May, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2012 Number 7249, at the suit of Wilmington Trust,NA as Successor Trustee to Citibank,NA as Trustee for Bear Stearns ALT-A Trust 2007-2, Mortgage Pass-Through Certificates Series 2007-2 against Darryl J. Ryan and Victoria Ryan is duly recorded as Instrument Number 201401152. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this fs- day of A.D. c�D( C RecmW of Deeds. "'N rland County,Car►iste,PA Recorder of De ds MY Commission Expires the First Monday of Jan.2018