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Home My WebLink About13-2335 Court of Common Pleas Civil Cover Sheet For Prothonotary Use Only Docket No: Cumberland County La The information collected on this form is used solely for court administration purposes. This form does not supplement or replace thefifing and service ofpleadings or other papers as required by law or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition S ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking E Lead Plaintiff's Name: Citibank N.A., as Successor Trustee for the Lead Defendant's Name: Timothy F. Straub and C holders of MASTR Adjustable Mortgages Taut 2007 -HF2 in a Calvin W. Williams, III and Occupants Securititation Transaction Pursuant to Pooling and Servicing T Agreement dated as of July 1, 2007 [ Dollar Amount Requested: LJ within arbitration limits O Are money damages requested ?: ❑ Yes ® No (Check one ®outside arbitration limits N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJ Appeal? ❑ Yes ® No A Name of Plaintiff7Appellant's Attorney: Christopher A. DeNardo. Esquire ❑ Check here if you have no attorney (are a Self- Represented [Pro Se] Litigant) Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. if you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (dons include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other S ❑ Product Liability (does not ❑ Employment Dispute: include mass tort) Discrimination E ❑ Slander /Libel/Defamation ❑ Employment Dispute: Other C ❑ Other. ❑Zoning Board T ❑ Other: I I ❑ Other. O MASS TORT N ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Ton - Implant REAL PROPERTY MISCELLANEOUS B ❑ Toxic Waste ® Ejectment [3 Common Law /Statutory Arbitration O Other. ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations ❑ Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Watranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Updateatnaott L EO- OFF ICE _�ri PROTHONOTARY SHAPIRO & DeNARDO, LLC 2013 APR 2 9 FM 1: 5 2 BY: CHRISTOPHER A. DeNARDO, ESQUIRE CUMBERLAND COUNTY ATTORNEY I.D. NO: PA Bar # 78447 P E N NSYLVANIA 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278 -6800 S & D FILE NO. 12- 041440 Citibank N.A., as Successor Trustee for the COURT OF COMMON PLEAS holders of MASTR Adjustable Mortgages CUMBERLAND COUNTY Trust 2007 -HF2 in a Securitization ?< - Transaction Pursuant to Pooling and NO.: Servicing Agreement dated as of July 1, 2007 PLAINTIFF ; VS. Timothy F. Straub, Calvin W. Williams, III ; and Occupants 328 S. Old Stone House Road Boiling Springs, PA 17007 DEFENDANTS CIVIL ACTION EJECTMENT 21000 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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. O a t z CLI� l /aa �ao 0 -do �� Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717- 249 -3166 NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIEREDEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES,USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LADEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIAESCRITA 0 EN PERSONA 0 POR ABOGADO Y ARCHIVAR EN LA CORTE ENFORMA ESCRITA SUS DEFENSAS 0 SUS OBJECIONES A LAS DEMANDAS ENCONTRA DE SU PERSONA. SEA AVISADO QUE SI USTED NO SE DEFIENDE,LA CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SINPREVIO AVISO 0 NOTIFICACION Y POR CUALQUIER QUEJA 0 ALIVIO QUE ESPEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO OSUS PROPIEDADES 0 OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENEABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO,VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CU.YA DIRECCIONSE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDECONSEGUIR ASISTENCIA LEGAL. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717- 249 -3166 12- 041440 SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE ATTORNEY I.D. NO: PA Bar # 78447 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278 -6800 S & D FILE NO. 12- 041440 Citibank N.A., as Successor Trustee for the COURT OF COMMON PLEAS holders of MASTR Adjustable Mortgages CUMBERLAND COUNTY Trust 2007 -HF2 in a Securitization Transaction Pursuant to Pooling and ; NO.: Servicing Agreement dated as of July 1, 2007 PLAINTIFF ; VS. Timothy F. Straub and Calvin W. Williams, ; III and Occupants 328 S. Old Stone House Road ; Boiling Springs, PA 17007 DEFENDANTS C IVIL ACTION EJECTMENT Plaintiff hereby complains against Defendants as follows: I . Plaintiff, Citibank N.A., as Successor Trustee for the holders of MASTR Adjustable Mortgages Trust 2007 -HF2 in a Securitization Transaction Pursuant to Pooling and Servicing Agreement dated as of July 1, 2007 ( "Plaintiff'), has an office located at c/o Ocwen Loan Servicing, LLC, 1661 Worthington Road, West Palm Beach, FL 33409, and is properly conducting business in the Commonwealth of Pennsylvania. 2. Defendants are Timothy F. Straub and Calvin W. Williams, III and Occupants ( "Defendants ") and they reside at 328 S. Old Stone House Road, Boiling Springs, PA 17007 ( "the Premises "). 3. The Premises, which is where the ejectment is to take place, is located at 328 S. Old Stone House Road, Boiling Springs, PA 17007. A true and correct copy of the legal description of the Premises, is attached incorporated herein by reference, and as Exhibit "A." 4. The Premises were sold at Sheriffs sale by the Sheriff of Cumberland County, Pennsylvania, after due advertisement and according to law, under and by virtue of a Writ of Execution issued to satisfy a Judgment In Mortgage Foreclosure entered in the Court of Common Pleas of Cumberland County, Pennsylvania, at the suit of Citibank N.A., as Successor Trustee for the holders of MASTR Adjustable Mortgages Trust 2007 -HF2 in a Securitization Transaction Pursuant to Pooling and Servicing Agreement dated as of July 1, 2007 v. Timothy F. Straub and Calvin W. Williams, III. 5. The case number of said Judgment is: 2009 -4560. 6. The sale was held on: March 2, 2011. 7. Plaintiff purchased the Premises at the Sheriffs sale. 8. The Plaintiff acquired valid title to the Premises on the date of and by virtue of said Sheriffs sale. 9. Plaintiff is still the real owner of said Premises and is entitled to immediate possession of the Premises. 10. Said Deed is a matter of State public record and therefore, is hereby incorporated by reference herein as if fully set forth at length. A true and correct copy of the Sheriff's Deed, is attached hereto, incorporated herein by reference, and marked as Exhibit "B." 11. The persons in possession of the Premises are believed to be the Defendants in this action who are occupying the Premises without right and without claim to title. 12. Plaintiff is entitled to immediate possession of the Premises. WHEREFORE, Plaintiff demands judgment, in ejectment, for immediate possession of the Premises, issuance of a Writ of Possession'and a judgment of its costs and disbursements in this action. Respectfully submitted, SHAPIRO & DeNAR LLC Date: q BY: �'hMSW FIAt.KOFF,-19SQbJAg I rk. Attorney for Plaintiff VERIFICATION The undersigned, an authorized representative of Plaintiff's servicing agent, Ocwen Loan Servicing, LLC ( "Ocwen "), is authorized to make this verification on behalf of Plaintiff and hereby certify that the facts set forth in the foregoing Complaint are true and correct to the best of their knowledge, information and belief. Except where otherwise stated and/or based upon public record, this verification is based upon a review of business records regularly created, kept and maintained in the course of Ocwen's mortgage servicing business conducted on Plaintiff's behalf. I understand that false statements herein are made subject to the penalties of 18 PA.C.S SECTION 4904 relating to unsworn falsificati o authorities. r DATE: 1 4 -1 4 J NAME: Regina Pei TITLE: Contract Management Coordlnato� Ocwen Loan Servicing, LLC as attorney -in -fact for Plaintiff Timothy F. Straub and Calvin W. Williams, III and Occupants 328 S. Old Stone House Road, Boiling Springs, PA 17007 ALL THAT CERTAIN lot or piece of land situate in the Village of Churchtowa, Monroe Township Cumberland County, Pennsylvania, bounded and described in accordance with a Survey and Plan thereof made by William B. Whitlock, Professional Engineer, dated May 29,1969, as follows: - BEGINNING at a point on the western line of Main Street, said point being one hundred thirty -four (I34) feet Southeast of the southeastern line of West Street; thence along the western line of Main Street, South 24 degrees 30 minutes East, ninety-nine and forty hundredths (99.40) feet to the northern line of a ten (10) feet wide alley, thence along the same, South 65 degrees 30 minutes West, forty -two and seventy-four hundredths (42.74) feet to an angle therein; thence continuing along the same, South 38 degrees 24 minutes 45 seconds West, one hundred forty -nine and seventy-nine hundredths (149.79) feet to a comer of land now or late of Sarah Liggett; thence along said land, North 27 degrees 49 minutes West, one hundred sixty- seven and fifty hundredths (167.50) feet to a comer of land now or late of Mrs. K. Lucas; thence along said land, North 65 degrees 30 minutes East, one hundred eighty-six (186) feet to the point and place of Beginning, J DWELLING KNOWN AS 328 S. OLD STONE HOUSE ROAD, BOILING SPRINGS, PA 17007. IDENTIFIED as TAX/PARCEL IDA 09 -4560 CIVIL TERM in the Deed Registry Office of Cumberland County, Pennsylvania. 1 Being the same premises conveyed to Timothy F. Straub and Calvin W. Williams, III, as joint tenants with the right of survivorship, by Deed of Gary J. Loper and Marjorie A. Loper, his wife, dated 2/282005 and recorded 322005 in Cumberland County Deed Book 267, page 3840. s _ 0027PK Tax Parcel No. 22 -28 -2401 -017 Know all Men by these Presents That 1, Ronny R. Anderson, Sheriff of the County of Cumberland, In the State of Pennsylvania, for and in consideration of the sum of S 1.00 (One Dollar) to me in hand paid, do hereby grant and convey to Citibank N.A., as Successor Trustee for the holders of MASTR Adjustable Mortgages Trust 2007 -HF2 in a Securitization Transaction Pursuant to Pooling and Servicing Agreement dated as of July 1, 2007 Writ No. 2009 - 4560 Civil Term Citibank N.A., as Successor Trustee for the holders of MASTR Adjustable Mortgages Trust 2007 -HF2 in a SecuritizationTransaction Pursuant to Pooling and Servicing Agreement dated as of July t, 2007 Vs Timothy F. Straub Calvin W. Williams, III ALL THA'r CERTAIN lot or piece of land situate in the Village of Churchtown, Monroe Township Cumberland County, Pennsylvania, bounded and described in accordance with a Survey and Plan thereof made by William B. Whittock, Professional Engineer, dated May 29,1969, as follows: BEGINNING at a point on the westem line of Main Street, said point being one hundred thirty-four (134) feet Southeast of the southeastern line of West Street; thence along the western line of Main Street, Soullr 24 degrees 30 minutes East, ninety-nine and forty hundredths (99.40) feet to the northern line of a ten (10) feet wide alley; thence along the same, South 65 degrees 30 minutes West, forty -two and seventy -four hundredths (42.74) feet to an angle therein; thence continuing along the same, South 38 degrees 24 minutes 45 seconds West, one hundred forty -nine and seventy -trine hundredths (149.79) feet to a corner of land now or late of Sarah Liggett; thence along said land. North 27 degrees 49 minutes West, one hundred sixty - seven and fifty hundredths (167.50) feet to a corner of land now or late of Mrs. K. Lucas; thence along said land, North 65 degrees 30 minutes East, one hundred eighty -six (186) feet to the point and place of Beginning, DWELLING KNOWN AS 328 S. OLD STONE I•IOUSE ItOAD, BOILING SPRINGS, PA 17007. IDENT1FiLD as TA)UPARCEL ID#: 094560 CIVIL TERN4 in the Deed Registry Office of Cumberland County, Pennsylvania. Being the same premises conveyed to Timothy F. Straub and Calvin W. Williams, III, as joint tenants with the tight of survivorship, by Deed of Gary J. Loper and Marjorie A. Loper, his wife, dated 2/28/2005 and recorded 3/2/2005 in Cumberland County Deed Book 267. page 3810. x �b, The same having been sold by me to the said grantee on the 2 " day of March Anno Domini Two Thousand and Eleven (2011) after due advertisement according to law, under and by Virtue of a Writ of Execution issued on the 16th of August Anno Domini 2010 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Nine (2009) Number 4560 at the suit of Citibank N.A., as Successor Trustee for the holders of MASTR Adjustable Mortgages Trust 2007 -HF2 in a SecuritizationTransaction Pursuant to Pooling and Servicing Agreement dated as of July 1, 2007 —vs- Timothy F. Straub And Calvin W. Williams, III In Witness Whereof, I have hereunto affixed my signature this 17th. day March Anno Domini Two Thousand and Eleven (2011) y . Anderson, Sheriff Commonwealth of Pennsylvania, ss. County of Cumberland Before the undersigned, David D. Buell, Prothonotary of the Court of Common Pleas of Cumberland County, Pennsylvania, personally appeared Ronny R. Anderson, Sheriff of Cumberland County aforesaid, and in due form of law declared that the facts Set forth in the foregoing Deed are true, and that he acknowledged the same in order that Said deed might be recorded. Witness my hand and seal of said Court, this 17th day of March Anno Domini Two Thousand and Eleven (2011) P th �1�`�t►�SrdE'J� �L,, rytktmhedend PA ........... ��. i� 0 4 eq*m the Flret of Js' 2014 I hereby certify th at fy at the residence ; And Post Office address of the Within Grantee is 1661 Worthington Road West Palm Beach, FL 33409 Richard W. Stewart Solicitor "1 ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE a CARLISLE, PA 17013 _ 717 - 240 -6370 ° s Instrument Number - 201109952 Recorded On 4/1/2011 At 9:53:31 AM * Total Pages - 5 * Instrument Type - DEED - SHERIFF'S Invoice Number - 84668 User ID - NSW * Grantor - STRAUB, TIMOTHY F * Grantee - MASTR * Customer - SHERIFF * FEES STATE WRIT TAX $0.50 Certification Page STATE JCS /ACCESS TO $23.50 JUSTICE DO NOT DETACH RECORDING FEES — $12.50 RECORDER OF DEEDS This a e is now art PARCEL CERTIFICATION $10.00 P g P FEES of this legal document. AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 CUMBERLAND VALLEY SCHOOL $0.00 DISTRICT MONROE TOWNSHIP $0.00 TOTAL PAID $63.00 I Certify this to be recorded in Cumberland County PA 4 y Op a / S $ ° RECORDER O D ED • - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 11 VK Ol lull I�Illl�li ICI I �I FORECLOSURE REPORT BY Premium Title Services, Inc. Loan No: 706311487 Premium's File No: 706311487 1 102910 PA Search Effective Date: 10/31/2010 Report Prepared For: Mancini & Assoc. Property Address: 328 S Old Stone House Road, Boiling Springs, PA, 17007 Lien Position: 1st Title is Vested in: TIMOTHY F. STRAUB AND CALVIN W. WILLIAMS, III, AS JOINT TENANTS WITH THE RIGHT OF SURVIVORSHIP, by that Warranty Deed dated 02/28/2005 and recorded on 03/02/2005 in Book 267 at Page 3840, of the Cumberland County, PA records. Mortgagors: TIMOTHY F. STRAUB AND CALVIN W. WILLIAMS, III, AS JOINT TENANTS The public records show the property subject to the following: Subject Mortgage: That Mortgage in favor of MERS, INC., AS NOMINEE FOR EVERBANK, dated 01/25/2007, and recorded on 02/08/2007, in Book 1981 at Page 4838, (given to secure the original principal amount of $167,400.00). That Assignment of mortgage from MERS, INC., AS NOMINEE FOR EVERBANK, FSA to CITIBANK, N.A., AS SUCCESSOR TRUSTEE FOR THE HOLDERS OF MASTR ADJUSTABLE MORTGAGES TRUST 2007 -HF2 A SECURITIZATION TRANSACTION PURSUANT TO POOLING AND SERVICING AGREEMENT, DATED AS OF JULY 1, 2007, recorded on 07/24/2009 as Document No. 200925821. Other Encumbrances: That Judgment in favor of ESHENAURS FUELS, INC., filed on 08/02/2010 as Document No. 2010 -05047 in the amount of $7,114.94, plus costs and interest, if any. That Judgment (MORTGAGE FORECLOSURE) in favor of CITIBANK, N.A., AS SUCCESSOR TRUSTEE FOR THE HOLDERS OF MASTR ADJUSTABLE ,/ MORTGAGES TRUST 2007 -HF2 IN A SECURITIZATION TRANSACTION PURSUANT TO POOLING AND SERVICING AGREEMENT, DATED AS OF JULY 1, 2007, filed on 07/08/2009 as Document No. 2009-04560 in the amount of $177,618.35, plus costs and interest, if any. That Judgment (CONFESSION OF JUDGMENT) in favor of SUSQUEHANNA BANK, filed on 09/08/2009 as Document No. 2009 -06114 in the amount of $120,364.70, plus costs and interest, if any. That Judgment (CONFESSION OF JUDGMENT) in favor of SUSQUEHANNA BANK, filed on 09/08/2009 as Document No. 2009 -06115 in the amount of $266,151.54, plus costs and interest, if any. That Judgment (CONFESSION OF JUDGMENT) in favor of SUSQUEHANNA BANK, filed on 09/08/2009 as Document No. 2009 -06120 in the amount of $127,987.15, plus costs and interest, if any. That Judgment (CONFESSION OF JUDGMENT) in favor of SUSQUEHANNA BANK, filed on 09/08/2009 as Document No. 2009 -06118 in the amount of $259,228.13, plus costs and interest, if any. That Judgment (CONFESSION OF JUDGMENT) in favor of SUSQUEHANNA BANK, filed on 09/08/2009 as Document No. 2009 -06119 in the amount of $153,887.06, plus costs and interest, if any. That Judgment (PRAECIPE TO SATISFY CONFESSION OF JUDGMENT) in favor of SUSQUEHANNA BANK, recorded on 07/09/2010 as Document No. 2009 -6121 That Judgment (CONFESSION OF JUDGMENT) in favor of SUSQUEHANNA BANK, filed on 09/08/2009 as Document No. 2009 -06125 in the amount of $355,751.62, plus costs and interest, if any. That Judgment (PRAECIPE TO SATISFY CONFESSION OF JUDGMENT) in favor of SUSQUEHANNA BANK, recorded on 07/09/2010 as Document No. 2009 -6124 That Judgment (CONFESSION OF JUDGMENT) in favor of SUSQUEHANNA BANK, filed on 09/08/2009 as Document No. 2009 -06126 in the amount of $260,310.51, plus costs and interest, if any. That Judgment (CONFESSION OF JUDGMENT) in favor of SUSQUEHANNA BANK, filed on 09/08/2009 as Document No. 2009 -06127 in the amount of $203,366.11, plus costs and interest, if any. That Judgment in favor of WILLIAMS APTS. AND CALVIN WILLIAMS, JR.., filed on 07/30/2009 as Document No. 2009 -05233 in the amount of $8,174.50, plus costs and interest, if any. That Final Judgment of Dissolution of Marriage, filed on 07/30/2007 as Document No. 2007 -04490 Homeowner's Association Lien: None Tax ID #: 22 -28- 2401 -017 (22 -28 -2401) Tax Information: COUNTY taxes for the year 2009 are Paid HOA or Condo Association interest, if any. N/A Legal Description: ALL THAT CERTAIN lot or piece of land situate In the Viltage of Churchtown, Monroe Township, Cumberland C;ounty, k'annsyrvania, Dmnoeo ano oescrow to accoroant:e win a aurvey ano Man wereot mace oy VynHarn u. Whitlock, Professional Engineer, dated May 29,1669, as follows: BEGINNING at a point on the western line of Main StroK sold point being one hundred thirty -fay (134) foot Southeast of the southeastern line of West Street; thence along the westom line of Main Street, South 24 degrees 30 minutes East, ninety --nine and forty hundredths (99.40) feet to the northern tine of a ten (10) feet wide allay; thence along the same, South 65 degrees 30 minutes West, forty-two and seventy -four hundredths (42.74) feet to an angle therein; thence ocntriving aloiV the same, South 38 dlrgrees 24 minutes 45 seconds West, one hundred forty -nine and seventy -nine hundredths (149.78) feet to a corner of land now or late of Sarah Liggett; thence along said land, North 27 degrees 40 minutes West, one hundred sixty -seven and fifty hundredths (187.50) feet to a comer of land now or late of Mrs. K. Lucas; them along said land, North 65 degrees 30 minutes East, one hundred eightysix (186) feet to the point and place of BEGINNING. HAVING thereon erected a two -story frame dwelling known as $18 Again Street, Box Number 91. End Of Report GERALD M. SHAPIRO _ Adatitted in IQinoii and Florida Only . DAVID S KREISMAN S HAPIRO & DENARDO LLC AdmittedinlllicoisOnly 1 CHRISTOPHER A. DeNARDO M ICHAEL L ATTORNEYS AT LAW MICHAEL J. CLARK + LESLIE RASE 3600 Horizon Drive, Suite 150, King of Prussia, Pennsylvania 19406 Ake Laxitaod to Flew tency Tel: (610) 278 -6800, Fax: (610) 278 -9980 90 DAY NOTICE PURSUANT TO PROTECTING TENANTS OF FORECLOSURE ACT, PUBLIC LAW 111 -22 TO: Tenants 328 S. Old Stone House Road Boiling Springs, PA 17007 AND ALL OTHER TENANTS IN POSSESSION: AT PREMISES KNOWN AS 328 S. Old Stone House Road Boiling Springs, PA 17007 NOTICE IS HEREBY GIVEN, that Citibank N.A., as Successor Trustee for the holders of MASTR Adjustable Mortgages Trust 2007 -HF2 in a Securitization Transaction Pursuant to Pooling and Servicing Agreement dated as of July 1, 2007 has purchased the above - described property at a foreclosure sale and is the record owner of the Property. NOTICE IS FURTHER GIVEN that, pursuant to the Protecting Tenants of Foreclosure Act, Public Law 111 -22, All Tenants are given ninety (90) day notice to vacate the premises. If you fail to vacate the premises within the ninety (90) day period, Citibank N.A., as Successor Trustee for the holders of MASTR Adjustable Mortgages Trust 2007 -HF2 in a Securitization Transaction Pursuant to Pooling and Servicing Agreement dated as of July 1, 2007 will proceed to have an eviction and lockout scheduled to have you removed from the Property. Pursuant to Protecting Tenants of Foreclosure Act, Public Law 111 -22, if you have a pre- existing lease extending beyond ninety (90) days from the date of receipt of this notice, you may choose to deliver a bona fide lease agreement to the attorney's office listed below. If you choose to produce your lease agreement, you will be expected to pay contractual rent monthly to the Citibank N.A., as Successor Trustee for the holders of MASTR Adjustable Mortgages Trust 2007 -HF2 in a Securitization Transaction Pursuant to Pooling and Servicing Agreement dated as of July 1, 2007 for the rest of the period of your lease agreement to the attorney's office listed below. If rent is not paid timely, Citibank N.A., as Successor Trustee for the holders of MASTR Adjustable Mortgages Trust 2007 -HF2 in a Securitization Transaction Pursuant to Pooling and Servicing Agreement dated as of July 1, 2007 will proceed with legal action for POSSESSION. ALL TENANTS ARE REQUIRED TO DELIVER POSSESSION of the premises at the scheduled end of said lease agreement. Enclosed herewith is a copy of the recorded Deed declaring Citibank N.A., as Successor Trustee for the holders of MASTR Adjustable Mortgages Trust 2007 -HF2 in a Securitization Transaction Pursuant to Pooling and Servicing Agreement dated as of July 1, 2007 as the lawful owner of said premises. I suggest you consult an Attorney or contact the undersigned to discuss the actual date you plan to vacate the premises or submit your lease agreement pursuant to Protecting Tenants of Foreclosure Act, Public Law 111-22. Li KASSIA FIALKOFF, Attorney for Purchaser Shapiro & DeNardo, LLC 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 (610)278 -6800 SHERIFF'S OFFICE OF CUMBERLAND-COUNTY Ronny R Anderson Sheriff HLED-uHICE THE PRO HONG tAR". Jody S Smith Chief Deputy 2013 MAY -3 AM10: 165 All, Richard W Stewart Solicitor OFF iQF C�F TK-,SYS R.I r CUMBERLAND COUNTY' PENNSYLVANIA Citibank, N.A. Case Number vs. 2013-2335 Timothy F Straub(et al.) SHERIFF'S RETURN OF SERVICE 05/01/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Occupant, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Ejectment as"Not Served"at 328 S. Old Stone House Road, Monroe Township, Boiling Springs, PA 17007. Reisdence is vacant. 05/01/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit:Timothy F Straub, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Ejectment as"Not Served"at 328 S. Old Stone House Road, Monroe Township, Boiling Springs, PA 17007. Residence is vacant. 05/01/2013 Sheriff Ronny R Anderson, being duly,sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Calvin W Williams, 111, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Ejectment as"Not Served"at 328 S. Old Stone House Road, Monroe Township, Boiling Springs, PA 17007. Residence is vacant. SHERIFF COST: $60.00 SO ANSWERS, May 01, 2013 RbNIW R ANDERSON, SHERIFF (C)CountySufte Sherifl,Toleosoft,111C, SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 r.., ,A , CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 (-- KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530 MOD -rt 'M LEONARD y, -- LEONARD J. MUCCI III, ESQUIRE, ATTORNEY I.D. NO. 92357 s nor-i C r- 3600 HORIZON DRIVE, SUITE 150 -<)> a� KING OF PRUSSIA, PA 19406 <..0:) TELEPHONE: (610)278-6800 �Z=x' S & D FILE NO. 12-041440 . N) Citibank N.A., as Successor Trustee for the COURT OF COMMON PLEAS ' holders of MASTR Adjustable Mortgages CIVIL DIVISION Trust 2007-HF2 in a Securitization CUMBERLAND COUNTY Transaction Pursuant to Pooling and Servicing Agreement dated as of July 1, 2007 NO: 13-2335 Civil PLAINTIFF VS. Timothy F. Straub, Calvin W. Williams, III and Occupants DEFENDANTS PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above-captioned matter SETTLED, DISCONTINUED AND ENDED, without prejudice. SHAPIRO & DeNARDO, LLC j_ Date: ✓ 2.1 1 BY: ---�' Attorneys for Plaintiff KASSIA FIALKOFF, ESQUIRE SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530 LEONARD J. MUCCI III, ESQUIRE, ATTORNEY I.D. NO. 92357 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 12-041440 Citibank N.A., as Successor Trustee for the COURT OF COMMON PLEAS holders of MASTR Adjustable Mortgages CIVIL DIVISION Trust 2007-HF2 in a Securitization CUMBERLAND COUNTY Transaction Pursuant to Pooling and Servicing Agreement dated as of July 1, 2007 NO: 13-2335 Civil PLAINTIFF VS. Timothy F. Straub, Calvin W. Williams, III and Occupants DEFENDANTS CERTIFICATE OF SERVICE I hereby certify that I have served a true and correct copy of the Praecipe to Settle, Discontinue and End on 15 2 13 to all parties named herein at their last known address or upon their attorney of record as below listed by regular mail, postage prepaid: Timothy F. Straub 328 S. Old Stone House Road Boiling Springs, PA 17007 Calvin W. Williams, III 328 S. Old Stone House Road Boiling Springs, PA 17007 SHAPIRO & DeNARDO, LLC � Z ( 3 BY: �- Date: Attorneys for Plaintiff KASSIA FIALKOFF, ESQUIRE