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Home My WebLink About13-3975 Supreme Court of ' Pennsylvania Cour(6f Comm6n. Pleas 0%' l `1 8S E'i' IIC'et for Prorhonotan use 0111t': >, Culinberland i Cotlntv � oet�Ir: 7S _A_ The information collected 'on this form is used solely for court administration purposes. This form does not Su lernent or replace the filing and service o leadin s or other papers as required bylaw or rules o court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from another Jurisdiction ❑ Declaration of Takin E Lead Plaintiff Name: Lead Defendant's Name: DEUTSCHE BANK NATIONAL TRUST COMPANY, AS DAVID A. NOREIKA TRUSTEE FOR LONG BEACH MORTGAGE LOAN SHELLEY M. NOREIKA T TRUST 2006 -2 I Dollar Amount Requested within arbitration limits O Are money Damages requested ?: ❑ Yes ® No (Check one) X outside arbitration limits 1 A Is this a Class Action Suit? ❑ Yes ® NO Is this an MDJ Appeal? 11 Yes ® NO Name of Plaintiff/appellant's Attorney: KML Law Group. P.C. ❑ Check here if you 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 (do not include judgments) CIVIL APPEAL ❑ 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 S ❑ Premises Liability ❑ Zoning Board ❑ Product Liability (does not include ❑ Statutory Appeal: Other E mass tort) ❑Employment dispute: ❑ Slander/Libel Defamation Discrimination C ❑ Other 11 Employment Dispute: Other T ❑Other: I a MASS TORT ❑ Other ❑ Asbestos `' ❑ Tobacco ❑ Toxic Tort - DES REAL PROPERTY MISCELLANEOUS • Toxic Tort -Implant ❑ Ejectment ❑ Common Law /Statutory • Toxic Waste 11 Eminent Domain/Condemnation Arbitration ❑Other ❑ Ground Rent ❑ Declaratory Judgment ❑ Landlord/Tenant Dispute ❑ Mandamus ® Mortgage Foreclosure: Residential ❑ Non - Domestic Relations PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial Restraining Order • Dental ❑ Partition ❑ Quo Warranto • Legal ❑ Quiet title ❑ Replevin ❑ Medical ❑ Other Professional: ❑ Other ❑ Other Pa.R.C.P. 205.5 Updated 1/1/2011 KML LAW GROUP, P.C. SUITE 5000 — BNY MELLON INDEPENDENCE CENTER r - f , !... 701 MARKET STREET L. -' ' ±� ..' , 4 :' ,� iil,_ l a 1 1 ' - ] ' PHILADELPHIA, PA 19106 (866) 413 -2311 llj�! ji�_i`�Ii� �'w '.KPTLI.AW .RO 7P. oM DEUTSCHE BANK NATIONAL TRUST COMPANYCk,1$Jb L AHD ' , • OURT OF COMMON PLEAS TRUSTEE FOR LONG BEACH MORTGAGE TRUST P E f i S Y LVA 3 i I A 2006 -2 c/o 3415 Vision Drive OF Cumberland COUNTY Columbus, OH 43219 Plaintiff CIVIL ACTION - LAW DAVID A. NOREIKA vs. ACTION OF MORTGAGE FORECLOSURE SHELLEY M. NOREIKA Mortgagor(s) and Record Owner(s) 7 I 3_ 1806 Centerville Road No. 3� l- Newville, PA 17241 'CFVLL ACTION: MORTGAGE Defendant(s) FORECLO"E 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 the 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 claim in the Complaint of 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. 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717- 243 -9400 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME (�n ��- agagg3 POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717- 243 -9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. RESOURCES AVAILABLE FOR HOMEOWNERS IN FORECLOSURE ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243 -9400. 2). Call the Consumer Credit Counseling Agency at 1- 800 - 989 -2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners .Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http : / /www.nhfa ora /consumers /homeowners /real aspx 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: hqp: / /www.phiIadelphiafed orc/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1 -866- 413 -2311 or via email at homeretention@lu Call Seth at 215- 825 -6329 or fax 215- 825 -6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825 -6318 or Fax: 215- 825 -6418. Please reference our Attorney File Number of 103177FC. Para informacion en espanol puede communicarse con Loretta a1215- 825 -6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE I. Plaintiff is DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2006 -2, 3815 South West Temple, Salt Lake City, UT 84115 2. The name(s) and address(es) of the Defendant(s) is /are DAVID A. NOREIKA, 1806 Centerville Road, Newville, PA 17241 and SHELLEY M. NOREIKA, 1806 Centerville Road, Newville, PA 17241, who is /are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On January 13, 2006 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to LONG BEACH MORTGAGE COMPANY, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on January 17, 2006 as Book 1937 Page 3541. A loan modification agreement was recorded on January 16, 2007 as Book 733 Page 2784. The mortgage has been assigned to: DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2006 -2 by assignment of Mortgage recorded on December 11, 2007 as Instrument # 200745901. The Mortgage and Assignment(s) (if any) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. Plaintiff and defendant entered into a loan modification agreement on September 1, 2008 a true and correct copy is attached as Exhibit C. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ( "Property "). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for October 01, 2008 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ...................... .......$140,028.03 Interest from 09/01/2008 through 06/18/2013 at 6.8340 % ..................... $45,203.12 Per Diem interest rate at $25.37 Monthly Escrow amount $209.25 Suspense...................................................................... ............................... ($683.15) Escrow.......................... ............................... ............ $9,672.24 .. ............................... Reasonable Attorney's Fee .................. ............................... ............ ..........$1,100.00 $195,320.24 7. If the Mortgage is reinstated prior to a Sheriffs Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. Plaintiff reserves the right to request additional attorney's fees if the complexity of the action results in fees in excess of the amount demanded. Further, Plaintiff will request recovery of all costs incurred in this action including, but not limited to, costs of suit, process serving and skip tracing, title searches, recording costs and any other costs of the action in accordance with the mortgage documents and applicable law. 8. Plaintiff is not seeking a judgment of personal liability (or an " personam judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re- establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit `B ". The Defendants have not had the required face -to -face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $193,975.24, together with interest, costs, fees and charges collectible under the Note and Mortgage including but not limited to attorney's fees and costs, and for the foreclosure and sale of the mortgage property. By: KML LAW G OUP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. ID 205047 Jill P. Jenkins Pa. ID 306588 ndrew F. Gornall Pa. ID 92382 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Attorneys for Plaintiff VERIFICATION Document Control Officer Diana Memmott ,hereby states that he /she is of Se ec or o io ervicing, Inc. as Attorney in Fact Al 11DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE TRUST 2006 -2 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 knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. Date: \AAA Select Portfolio Servicing, Inc. as Attorney in Fact Name: Diana Memmott Title: Document Control Officer #103177FC DAVID A. NOREIKA and SHELLEY M. NOREIKA E..xhi6itA ALL that certain piece of ground with improvements thereon situate in Cook Township, Cumberland County, Pennsylvania, more particularly described as follows, to wit: BEGINNING at a nail in the centerline of Centerville Road S.R. 233; thence South 59 degrees 00 minutes 00 seconds East a distance of 364.07 feet to a nail; thence along lands now or formerly of the Commonwealth of Pennsylvania `Michaux State Forest" South 72 degrees 31 minutes 15 seconds West a distance of 226.69 feet to a stone pile; thence continuing along lands now or formerly of Commonwealth of Pennsylvania "Michaux State Forest" North 61 degrees 00 minutes 00 seconds West a distance of 204.34 feet to a iron pin set; thence along lands now or formerly of Ann Marie Sutton North 27 degrees 54 minutes 00 seconds East a distance of 171.12 feet to the place of BEGINNING. CONTAINING a total area of 1.1246 acres as shown on the attached survey prepared by James C. Hockenberry, PLS and dated 11125/05. Exhibit *Exhibit has been redacted to remove all personally identifiable information or non-public information Chase Home Finance LLC FLS -7730 PO BOX 44090 Jacksonville, FL 32231 -4090 January 14, 2010 CHASE! i 000874 DAVID A NOREIKA 1806 CENTERVILLE RD NEWVILLE PA 17241 PLEASE REVIEW THE DEBT VALIDATION NOTICE ENCLOSED NOTICE OF COLLECTION ACTIVITY RE: ACCOUNT# _0250 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgao on your home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached Rages The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM HEMAP m9Y be able to help to save your home. This Notice explains how the program works To see if HEM-AP can help you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE_ Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions_ you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717 ) 780 -1869 This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATEMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. SP999 Chase Home Finance LLC FL5 -7730 PO BOX 44090 Jacksonville, FL 32231 -4090 January 14, 2010 CHASE 0 000675 SHELLEY M NOREIKA 1806 CENTERVILLE RD NEWVILLE PA 17241 PLEASE REVIEW THE DEBT VALIDATION NOTICE ENCLOSED NOTICE OF COLLECTION ACTIVITY RE: ACCOUNT# _0250 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgagg on your home is in default and the lender intends to foreclose. S12ecific information about the nature of the default is provided in the attached pages The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM HEMAP maY be able to help to save your home. This Notice explains how the program works To see if HEMAP can help you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WTrMN 33 DAYS OF THE DATE OF THIS NOTICE. Take thLs Notice with you when you meet with the Counseling: Agency. The name_ address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780 -1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA UWPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATEMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO " HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. SP999 HOMEOWNER'S NAME(S): David A. Noreika PROPERTY ADDRESS: 1806 Centerville Rd Newville PA 17241 LOAN ACCT. NUMBER: _ 0250 ORIGINAL LENDER: Lbm CURRENT LENDER /SERVICER: Chase Home Finance LLC HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL. • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face -to- face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF THIS NOTICE IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses, and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice It is only necessary to schedule one face -to -face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program, and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To stop the lender from filing a foreclosure action your application MUST be forwarded to PHFA and received within thirty (30) days of your face -to -face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE ". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICA77ON IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you, if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.) 000874/SP999 HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 1806 Centerville Rd Newville PA 17241 IS SERIOUSLY IN DEFAULT BECAUSE: Non - payment A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Installments: 10/01/2008 $1074.26 11/01/2008 $1074.26 12/01/2008 $1074.26 01/01/2009 $1074.26 02/01/2009 $1074.26 03/01/2009 $1074.26 04/01/2009 $1074.26 05/0112009 $1074.26 06/01/2009 $1074.26 07/01/2009 r $1074.26 08/01/2009 $1074.26 09/01/2009 $1074.26 1.0/01/2009 $1074.26 11/01/2009 $1074.26 12/01/2009 $1049.1.8 01/01/2010 $1049.18 Other charges (explain/itemize): Uncollected Late Charges $467.10 Uncollected Fees: $150.95 Corporate advances: $10.85 Less Credits $0.00 TOTAL AMOUNT PAST DUE: $17756.05 B_ YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WINCH IS $17756.05, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: Chase Home Finance LLC Attn: 0114 -7311 3415 Vision Drive Columbus, OH 43219 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Not applicable): IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt This means that the entire outstanding balance of this debt will be considered due immediately, and you may lose the the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged Dropedy. *IF THE MORTGAGE IS FORECLOSED UPON The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (301 DAY_ period you will not be required to pay attorney's fees OTHER LENDER REMEDIES - The lender may also sue you personally for the upaid principal balance and all other sums due under the mortgage. SP999 RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale You may do so by paying the total amount then past due plus any late or other charges then due. reasonable attorneys fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 9 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Chase Home Finance LLC Address: Mail Code FL5 -7317 PO Box 41275 Jacksonville, FL 32203 -1275 Phone Number: (904) 886 -1308 Toll Free: (800) 848 -9380 Contact Person: Kimberly Smith Email: kimberly.brown@ehase.com EFFECTS OF SHERIFF'S SALE: - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _ may or X may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale, and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THE DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR_) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED An important reminder for all our customers: As stated in the "Questions and Answers for Borrowers about the Homeowner Affordability and Stability Plan" distributed by the Obama Administration, "Borrowers should beware of any organization that attempts to charge a fee for housing counseling or modification of a delinquent loan, especially if they require a fee in advance." Chase offers loan modification assistance free of charge (i.e., no modification fee required). Please call us immediately at (800) 848 -9380 to discuss your options. The longer you delay the fewer options you may have. Sincerely, We may report information about your account to credit bureaus. Late payments, missed payments or other defaults on your account may be reflected in your credit report. WE ARE A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. SP999 E ifiit *Exhibit has been redacted to remove all personally identifiable information or non-public information PREPARED BY: JQN 1 Rn 10 00 MOSS CODILIS, L.L.P. Two Greenwood Plaza 6560 Greenwood Plaza Boulevard, Suite 100 Englewood, CO 80111 Preparer: Aubrie Woods Loan No. 0697390250 SPACE ABOVE THIS UNE FOR RECORDER'S USE 2-Q�i 5R t °I LOAN MODIFICATION AGREEMENT This Loan Modification Agreement ("Agreement') is effective made this 5' day of December 2006, ( "Effective Date ") between David A. Noreika and Shelley M. Noreika, (hereinafter, "the Borrower"), and Deutsche Bank National Trust Company, as Trustee for Long Beach Mortgage .Loan Trust 2006 -2, the Note holder and mortgagee. Together, the Borrower and the Trust are referred to herein as "the Parties ". RECITALS The Parties enter into this Agreement with reference to the following stipulated facts: A. On January 13, 2006, Borrower purchased, re- financed or otherwise obtained an interest in a certain real property in Cumberland County, Pennsylvania. In connection with the acquisition of the real property the Borrower delivered a certain promissory note dated January 13, 2006, in the original principal amount of $110,320.00 ("Note"). B. The Note was and is secured by a deed of trust, mortgage, applicable riders, addenda or other security instrument ( "Security Instrument"), dated January 13, 2006, and recorded January 17, 2006, in Book 1937, Page 3541 in the official records of Cumberland County as a lien against the real property described in the Security Instrument, and located at 1806 Centerville Road, Newville, Pennsylvania 17241 (the "Subject Property"), and is more particularly described as: SEE EXHIBIT "A "ATTACHED HERETO AND MADE A PART HEREOF TAX ID #: 07372569008A C. Borrower is the current owner of record of the Subject Property. No other persons or business entities have ownership, management or control of the Subject Property. Borrower has not assigned, transferred, mortgaged or hypothecated the Subject Property, or any fee estate therein, nor the rents, income and profits of the Subject Property as may be described in the Security Instrument, except as set forth in these recitals. BK0733PG2784 D. Borrower has requested that the terms of the Note and Security Instrument be modified. The Parties have agreed to do so pursuant to the terms and conditions stated in this Agreement. AGREEMENT NOW, THEREFORE, In consideration of the mutual promises and agreements exchanged, the Parties hereto agree as follows: 1. Incorporation of Recitals. The Recitals are an integral part of this Agreement and are incorporated by reference herein. 2. Unpaid Principal Balance. The Parties agree that as of December 1, 2006, the unpaid principal balance of the Note and the Security Instrument is $110,219.93 (the "Unpaid Principal Balance"). 3. Capitalization. The Borrower acknowledges that interest on the Unpaid Principal Balance has accrued but has not been paid and the Trust, or the servicer on behalf of the Trust, has incurred, paid or otherwise advanced taxes, insurance premiums and other expenses necessary to protect or enforce the interest of the Note holder or mortgagee and that such . accrued and unpaid interest, costs and expenses in the total amount of $13,019.74 (the "Capitalized Amount") has been added to the indebtedness under the terms of the Note and Security Instrument, as of December 1, 2006. 4. Modified Principal Balance. When payments resume on January 1, 2007, the new balance due on the loan will be $123,239.67 ( "Modified Principal Balance'), which consists of $110,219.93 plus $13,019.74. 5. Reamortization. The Modified Principal Balance will be reamortized over 350 months. 6. Payment and Interest Adjustments. Interest will be charged on the Modified Principal Balance at the interest rate of 8.000% per cent per annum from December 1, 2006 until February 1, 2036. The following terns and provisions of the original Note and Security Instrument are forever canceled, null and void, as of the date of this agreement: a. all terms and provisions of the Note and Security Instrument (if any) providing for or relating to any change or adjustment in the rate of interest payable under the note; and b. all terns and provisions of any adjustable rate rider or other instrument or document that is affixed to or wholly or partially incorporated into, or is a part of, the Note or Security Instrument and that contains any such terms or provision as those referred to in (a) above. BK0733PG2785 7. Maturity Date. If on February 1, 2036, ("Maturity Date'), Borrower still owes any amounts under the Note, Security Instrument or this Agreement, the Borrower shall pay these amounts in full on the Maturity Date. 8. Payments; Delivery of Payments. The Borrower promises to pay the Modified Principal Balance, plus interest, to the order of Washington Mutual. Borro wer(s) shall make the Monthly Payments described as follows, or at such other place that Washington Mutual may designate: Washington Mutual 19850 Plummer Avenue, Mail Stop N070206 Attention: Default Alternatives Chatsworth, CA 91311 9. Acceleration Upon Unauthorized Transfer. The acceleration terms under the Note and Security Instrument are incorporated herein by reference. 10. Effect of this Agreement. Except to the extent that they are modified by this Agreement, the Borrower(s) hereby reaffirm all of the covenants, agreements and requirements of the Note and Security Instrument, including without limitation, the Borrower's covenants and agreements to make all payments of taxes, insurance premiums, assessments, escrow items, impounds, and all other payments that the Borrower is obliged 'to make under the Security Instrument. Borrower(s) further agree to be bound by the terms and provisions of the Note and Security Instrument, as modified hereby. 11. No Release. . Nothing in this Agreement shall be understood or construed to be a satisfaction or release in whole or in part of the Note and/or Security Instrument. Except as expressly provided in this Agreement, all of the terms, covenants agreements and the Note and Security Instrument will remain unchanged and the Parties will be bound by, and comply with, all of the terms and provisions of the instruments, as amended by this Agreement. 12. Warranties. Borrower does hereby state and warrant that the above described Nate is valid and enforceable in all respects and is not subject to any claims, defenses or right of offset or credit except as herein specifically provided. Borrower does further hereby extend all liens and security interests on all of the Subject Property and any other rights and interests which now or hereafter secure said Note until said Note as modified hereby has been fully paid, and agree that this modification and extension will in no manner impair the Note or any of the liens and security interests securing the same and that all of the liens, equities, rights, remedies and security interests securing said Note shall remain in full force and effect and shall not in any manner be waived. Borrower further agrees that all of the terms, covenants, warranties and provisions contained in the original Note and Security Instrument are now and shall be and remain in full force and effect as therein written, except as otherwise expressly provided herein, until the Note is paid in full and all other obligations under the Security Instrument are fulfilled. BK0733PG2786 13. Further Assurances. Borrower does further state and warrant that all of the recitals, statements and agreements contained herein are true and correct and that Borrower is the sole owner of the fee simple title to all of the Subject Property securing the Note. 14. Acknowledgment by Borrower. As part of the consideration for this Agreement, Borrower agrees to release and waive all claims Borrower might assert against the Trust and or its agents, and arising from any act or omission to act on the part of the Trust or it's agents, officers, directors, attorneys, employees and any predecessor -in- interest to the Note and Security Instrument, and which Borrower contends caused Borrower damage or injury, or which Borrower contends renders the Note or the Security Instrument void, voidable, or unenforceable. This release extends to any claims arising from any judicial foreclosure proceedings or power of sale proceedings if any, conducted prior to the date of this Agreement. Borrowers have and claim no defenses, counterclaims or rights of offset of any kind against Lender or against collection of the Loan. 15. Bankruptcy Considerations. Notwithstanding anything to the contrary contained in this Agreement, the Parties hereto acknowledge the effect of a discharge in bankruptcy that may have been granted to the Borrower prior to the execution hereof and that the Note holder may not pursue the Borrower for personal liability. However, the Parties acknowledge that the mortgageelbeneficiary retains certain rights, including but not limited to the right to foreclose its lien against the Subject Property under appropriate circumstances. The Parties agree that additional consideration for this Agreement is the Trust's forbearance from presently exercising the rights and remedies of the Note holder and mortgagee under the Security Instrument. Nothing herein shall be construed to be an attempt to collect against the Borrower personally or an attempt to revive personal liability, if the Borrower has obtained a discharge of that liability from a United States Bankruptcy Court. [signature pages follow] 8K0733PG2787 i BMROWER(S): Date: — l� O David A. Noreika SbeileyXftieika j vW j q j t n s r �� i ature Print Name Print Name COMMONWEALTH OF )ss: COUNTY OF k)P O , before me, the undersigned, a Notary Public in and for said Commonwealth, personally appeared David A. Noreika and Shelley M. Noreika. [ ] personally known to me - OR - [ ] proved to me on the basis of satisfactory evidence to be the person(s) whose names) is /are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her /their authorized capacity(ies), and that by his/her /their signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument. WITNESS my hand and official seal. Notarial Seel Cathy E. Fry. Notary Public Signature of South Middlleton Twp., Cumberland County My Omission Expires July 30, 2010 My commission expires: BKO733PG2788 �i I Deutsche Bank Nation st Company, as Trustee for Long Beach Mortgage Loan Trust 2006 -2 i . By: Washington Mu B its A ey -in -Fact (tee) R (title) DEN 9 2006 Date: Wi a Si to ` �� r4 Print Name Witness iguature Print Name STATE OF California ) )ss: COUNTY OF Los AnQOWS DEC 2 9 Zoos O , before me, the undersigned, a Notary Public in and fox said State, personally appeared xn I Q*>C- t- f(CC IC Del personally known to me - OR — [ ] proved to me on the basis of satisfactory evidence to be the person(s) whose name(s) is/arKsubscribed to the within instrument and acknowledged to me that he/gi�e/0k6y executed the same in hisA;efhhe+lauthorized capacity(ies), and that by hisUieV tr signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument. WITNESS my hand and official seal. c COMM ? a� i 159 'j, i'lohry Public - CaWenre � S Anoeles Cou* as hm. Signature of Notary 8K0733PG2789 t � Exhibit A j kl L that csrtain ptem of ground with WVMVetneats tkereatz astnata w Cook To unship, Combertand County. Petensyhroida, more partieubulY d as follows. to �vJt: BEG�NIN at a Rail fu th centerline o f Ceatcr�rits8 Road S.R 233; cbm►ee South 59 degrees 00 minutes go sew"dx Fast a distance of 364.07 f l to x Rai[: tht"CO "bug land$ now or formerly of the Comritattwealtb of ptft jvavU mWch"x State Forst" South 72 degrtes 31 minutes 16 seconds West a distaoce. of 226.69 feet to A stone pllr theute contiaatRg aloug Wads Holt or forxwrly otCommearne"ttfr of PeRoxyhrwda "MJchaux State Forest" Nortb 61 de$rtos 8o minaw stood& West a durance of 244.34 feet to a iron{ pin act: lbpt►ce along Inn& Row or formers) at Ann M Sutton North Z9 de;rccs 54 minutes 00 seconds East a distance of 171.3 feet to the place of BEGINNING. CONT.U1 a total area of I.1246 acres as shown on tiro attacltod survey prepared by 3a mes C. HocicQRberry►, PLS and dated iai?N85. P(Nj og3ga�s i.,goo$A 3 j 7 . I Certify this to be recorded . In C uzkty PA Recorder of Deeds BK0733PG2790 Recbcd'sii`�ltequt "sled?]'3;y a�(1`: i�i?licri Recoriied IVf a5l `To' �cl `eci�Potfol�o <Seivc�ile"�rie= I';U�Bo%�G525.0' Sa[t;Isalcc`G tyj�;U T .R165, 11:25:0 All 1. DocinenfGoiitfoi ._ ._ , Space�bo�Te fof RECOrclfng�int6rma``l`ic�n' !I;IM3TED 3'O�?dER Ol~ 'ATTQRN�Y' �KI�Q ,A A , . 1 BY TH$SE I'R1✓SENTS, ihat'Jl?hrlorganrCh s6'$ nk,,. at onal,Associalio l "(herE na" ter "Mastcr� Ser��tcer "�); faj r3atio�lal; mank-1n and eaMg6n SundEr`}the laves Ot "Am'ut hied, Sfatds; and having its principal,place'vf business ai 1 l 11 Polaris Parkways Columbus, P % pursuaxi4l" lo= authority ,graatied'tc i Jaster. ervtcers } �n c�eFlain _agreemEOt �dcscrFbed hire iE�. — uall ans ., t hi ., -y'r q rAgre�Bment and ilie Agrezents and nrthcWliimited Power of Aftorncv granteil�by lDett�sche tBankhatYOmal gust `Cori�pany,as fruslce { "Trusfee" atiacl�ed ' ., P "s a °frue and corrE`ci'�copy ; as'Gallrb�t" 1, hcrcb }�' consl�tuies ;anr� , appoints �elec¢� ;Pa�9fol�o Servicing, `'Inc tlrere�na�.eg "Sub��En�icer "�) b }�� ands through �itsxofficers,,asTMaster Scrvrcer S��tru and Iavv�ful Inaci �c� actin the narrie, dace and„ ' n `S`ert�tccr`, ° in tconiiectoii vr+ithF all {mortgage car `i�i[hcr loam serviced by tlaste`r SEruicer' stead t n 47T'> ^' 3 t 1 R .y K. .Y "i;•. "' tr n C C� dcxcc §•Y pursuanllo the Agreement, sole3y for #]te PurposE ofp aGts'anitng�such docurne7its 1n the riameyofiYl\fias(iri SEr��cer �n its capacti }� as�Afiorney �n ] acf�for the Tn7stce �� - - Tliis':appintnat�nt'sall apply only io thoseziuixicratcd transactions for r�zch th "e Irus i�as appomed then Master Seruicer as °_its Attorney to Fact,pursuant"tahibitfB {Ivlaastcr"Ser�r�ccr heeb}4raifies eves• act th`at�. f�u`b';Ser�ficer �ay,�la�ulull }r pc.rform�iri exerc�sxng,�hasEupowers r�irt�e,her�gi � ... _. ZN Vi',.ITNESS`�3EREOFs 1•!Iaster�Ser..uc,er'h s cxccvtfd this Limited Powrerof 1tort�cythis'tdayaof MayT ,. JPI V10�t�AI� ;;C,H''A�'F!- 13AI�iK,,N,A �``= �C�'�•�'�`r'�1�ui�t'y'r�'jji;,' Y s p 6 �.a e3ii'rZEb1Ii< S . �8z4 zs t Title enior�ice?resiilnt � . rV ,slYiy 3,�20�, Ueorc mc Notaryiililic iii aid for said Statie�ipersoiral }J appeared SeaniGr�elin,Y :l.nov�rn to naedo be a senior �7icell'iesideiit of»1'Morgan Bank, 3�lational v�ssociation that. sex ecufied` theabo�,e instruii�cnt, ian kno�x�n me be they person u�lYO+ ex�eculed lsaid instrument on'behalfof sachycarporatin ana'aacl.nmWledgdo nee ;liat;cl� coi:pora {io caeutird" h'Eiritln inst�umett' flTNESSVVEIZ]✓'Ol~ t havehereurito setiny hand and army a#fcial "seal il3e'day hand year t4userfifcait` first ahOVE�yrttCn; ofary' °ubtr, �i; oo ♦ : ,� +i A , g9 r d Exhibit. A Pooling and .Servicing Agreement dated as of November 1, 2002 for Long Beach Mortgage Loan Trust 2002 -5 Asset - Backed Certificates, Series 2002 -5 between Long Beach Securities Corp., Depositor, Long Beach Mortgage Company, Master Servicer, Federal National Mortgage Association, Guarantor .(with respect to the Class A -I Certificates and the Class S -1 Certificates) and Deutsche Bank National Trust Company, 'Trustee. Pooling and Servicing Agreement dated as of February 1, 2003 for Long Beach Mortgage Loan Trust 2003 -1 Asset- Backed Certificates, Series 2003 -1 between Long, Beach Securities Corp., Depositor, Long Beach .Mortgage Company, Master 96fvlcer, Federal National Mortgage .Association, Guarantor (with respect to the Class A -I Certificates and the CIa "ss S -I Certificates) and Deutsche Bank National Trust Company,. Trustee. Pooling and Servicing. Agreement dated as of April. I, 2003 for Long Beach Mortgage Loan Trust 20.03 -2 Asset - Backed Certificates, Series 2003 -2 lbet v en Long Beach Securities Corp., Depositor, Long Beach ,Mort_ gage Company, Master Servicer, and Deutsche Batik National Trust Coritpany,'Trustee. Pooling and Servicing Agreement, dated as of June :1, 2003 for Long Beach Mortgage Loan Trust 2003 -3 Asset - Backed Certificates, Series .2003 3 behveeti Long Beach Securities Corp., Depositor, Long Reach Mortgage Company, Mastcr Servicer, and Deutsche Bank National Trust Company, Trustee. Pooling and Servicing Agreement dated as of July 1, 2003 for Long Beach Mortgage Loan Trust 2003-4 Asset- Backed Certificates, Series 2003 -4 between' Lang Beach Securities Corp., .Depositor, .Loeig Beach Mortgage Company, Master Servicer, and Deutsche Bank National Trust Company, Trustee. Pooling and Servicing Agreement dated as of February. 1, 2004 for Long Beach Mortgage Load Trust 2004 -I .Asset- Backed Certificates, Series 2004 -1 between Long Beach Securities Corp., Depositor, Long Beach Mortgage. Company, Master Servicer, and Deutsche Bank National Trust Company, Trustee. Po6ling.and Servicing Agreement dated as of May 1,, 2004 for Long Beach Mortgage Loan. Trust 20042 Asset-. 'Backed Certificates, Series .2004.2 between Long Beach 'Securities Corp., Depositor, Long, Beach .Mortgage_ Comoairy, Master Servicer, and Deutsche Batik National Trust Company, Tnistee. Pooling and Servicing Agreement dated as of June 1,:2004 for bong Beach Mortgage Loan Trost 2004-3 Assct- Backed Certificates, Series 2004 -3 between Long Beach Securities Corp., Depositor, Long Beach Mortgage Company, Master Servicer, and Deutsche Bank National Trust Company, Trustee. Pooling and Servicing Agreement dated as of June 1, for Long Beach Mortgage Loan Trust 2004 -3 Asset - Backed Certificates,, Series 2004 -3 between Long Beach Securities Corp,, Depositor, Long Beach Mortgage Company, Master Servicer, and Deutsche Bank National Trust Company, Trustee. Pooling and Servicing Agreement dated as of.August 1, 2004 for Long Beach.Mortgagc °Loan Trust 2004 -5 Assct- Backed Certificates, Series 2064 -5 between Long. Beach Securities Corp., Depositor, Long Beach Mb tgage. Company,, Master Servicer; and Deutsche Bank. National Trust Company, Trustee. Pooling and Servicing Agreement dated as of September 1, 2004 for Long Beach Mortgage Doan Trust 2004 -4 Asset - Racked Certificates, Series 2004 -4 between Long Beach Securities Corp., Depositor, Long Beach Mortgage Company,:Master Servicer, and Deutsche Bank National Trust. Company, Trustee. Pooling and Servicing Agreement dated as October 1, 2004 for Long Beach Mortgage Uan Trust 2004 -5 Asset= Backed Certificates; S eries 2004 -G between .Fang Beach. Securities Corp., .Depositof, Long Beach Mortgage Company, Master Servicer, and Deutsche Bank National Trust Company, Trustee. Pooling and Servicing Agreement dated as of January I, 2005 for Long Beach Mortgage Loan Trust 2005 -1 Asset - Backed Certificates, Series 2005 -1 betNvecn Long Beach Securities Corp., Depositor, Long Beach Mortgage Coinpany, Master Servicer, and Deutsche Bank National Trust Company, Trustee. R Alzzbzt't R Offi e� -d)' {< Poolrn and $en�zcrtag Agreement datcl as o7anuaz��r i, 20QS .Sfor�LonigBeae}tortgageLoii Trus12005 l /ssei 13ac3�eil Cczlzfi Serz s f +b t�teet I ong �3each Sccurittcs Corp,:, Dei�osi €zzr, r T 6ng ,Brach�Norigagc, C�"mpany, 11'�actez $er�,zccrw and Deutsche Batik`1`ational.Tzvst�Company, Trastec., - _ Pooling ati'S'enzczng.lAgr mcnEdatcd s of l,}�iil �, 2UOSfort}>ong Beachhozigage Loan >tTrustry20Q5 [ssef : Bacl.ed Certieafies genes 2gt1S 2et�� een Tong 13e�eh?ecurz[zes r CozTr ; Depositor, Thong fReacll,�h�zortgage Camzau , lasier,.Servicer DeutscheBai�kl�atlonalTzust ,�oni au Prus€ee " Pool`u�g and S8zvzcing >Agreemcnt dated as `oflJuly i,4Q� for' bong i3each T9origagc ^I,oanIrust 2005 �b�i 'i�sseE, Backed Ccrtzficafcs, tSezzcs X005 �rI lib twee "n I ong`3cach'Securzttea Cozp, bcpositor, Longl3eacft 7�garQgage, CoznparI asCer Scrvicer iicl lleiiisehe_B zil� at3o'r al l rust �onipariy, �i rusice 'Pooliizg a nd; A `Sezvzczng,geenicnt, dated as o1 August',G2005for�izg Beach lvrortgage LoanTrustUQS`VVl,2t sscx t3aci.ed ;Ccrizaates, ;Sciies 2E3®5 ��'1s2 bcecnlotig Beach `Securtzes Cflip, d Deposztor; c Lorig, f3teach Ahortg ge Cflnip_ y Master S rvzcer nd- l3euische Ban ::1\'ational pnz'st Caznpany � `ivstee ,A �''oolrrig and �ez�zczng of �eptrrn�ber 7, 2gU53�'or Long Beachrlvioz I.oa� +Triist 20.05 3 sset Bacl.ed Certificates; Seizes'20g5 3' beCwccn T:oig Beacl Secuntzes Corp , Depo`sztvr, `I ozig 13eacli Afiartgage -- "Cozr�arr }r, A+iaster aid Deutsche Banl V TrustCor�tpaz'y, 7"rustee - . 'Pnoltng and Servicing Agreczaaentdated ' as ofNnveznler l,!2005�for T:or€g Beach T��ortgage F.oan'Pust`2005 -�L3` ? Asst' Bact,ed p,Cer�t`z�ZCates, S.d�rzes 2005` \►�'1�f35 lie €�x�en= sT,bng� Beach Securities Clip, 'D poszto� �T;ong��leaclr Y10 tfigagezConlpany „$CIier 1astcz�Senzcr, F aztd, .eutsc}ie33ank Goinpany,TrusEee..; Poolizig�and� Ser�nctngs [�,greeznc»E as of 7ano�ry, sl °20662'ftzr Long Beach' Jvfortgage ; F:aan�Trutfi�20Q6- ��y�2� "s ., :Assef Back <.Certzreates,* Serzesa 20D6 �'dI`2 b °tv�een $ong Beach Securities Coip beposifar, 'l.ong;,Bcach - �Aiartgage'"Goznian }, fSe�lezyanci RSaster SczrPr, and Deutsche Batcalzoai Trust Coinpan }+ T rus#ce :Poolnig and Scrvzcrng Agr eczn'eait' dated as o Jarivazpr g gag 7 � 2006 `for Lon 13cach at t I.oan�Trwsi�2Q06 W3= Asset ;Backed Ccrtifi Series' 200Ci ti'VI 3 Uetkk�een Yong Beach SECUrzizcs Corp , Dcposztbr, wLbt�g,. Beae t Mort ae Company,= Seller, azdi�lasterSei��icr, ll T-ust1Cozrtpany,`Trusie .Po41 and ScrYZCZZZgrAgreeriacnt dated as of tarzuaty %L,�200.6z$oL Long Beachvor[gage tan 7iast i0Q6;VJ1 1. Elssct Hacked Gertzficates;� Seites 20(!6 lzr!' 1 �be�t�veen iozig,73each, Secuntzes� Cazp„ Dopostioz; , T OfttageCoznpat�y, Seller_aziinlVfasterSeri =zeer, ands 3eiatsclze,I3anlcNaizonal I'sysf Coznpan };,;Trustee + Pooling afid�Se�iczng;A'�"�ree¢iiint datea�as of,+Pc'brua'ry'i l:,ozig $eac15 A =tgage Loan Tzust�`�Q�6�iuf�ssct�R Baeled, Cert`zfca�es, $cries 20Q6 1' r`het�eezrZong�;BeaCh Securttics Co��;, D,a;posito., Long_ I3cach� Moz4tgage;� ;Cbmp�fr}�,,�eller and.Iv_ faster; 5ervzcer ;Farid�i�eal"sche�l�anl. National xru� Cotnpaziy,�Trustee �� _ Pooling and 86,' ng Agreement dated as�o"fA4arcli i,�2006vfor Long i3 act Mortg ,c Iz�zst 006 2�f ssel 13acl.ed �GerLz�fcates,� Set zes 2000 2 tiot�i%�n +?song 03eadh "tSecurzE�es Cozp 3 Depositor , T ong Beach? Mortgage; Company,Sellcr and�lt�laster SCrvzcer ,and.I3euische33Ankfiiitiional TriistCoznpany Trustee zPooh anci ez�'tczng lgreen en fdated�aSaoi przl 1 2006�fdr "1;ong Beach, l�kbrt age Loan_ TrizsE,2ggG 3 AsseE _= 8acl.ed Cerfzi5caies ,,Series20g6 3 . bteera �1 QngI3each Securities Corpi, Depositor, Lui3g kortgage Coniapy 'Selier�and!lasrcrScrvz end lleutcli,]3ankNat6 ital ItigE Coii}iany, TiisCec ,'aoizi Servi0"'g Agrccinent dateil�as of A�`ay i t20UG for Lbzig B ac i, <IR4arf a e, &ii Trust 20Q.6.,A ; ssct =: d�actct� Cert�Crcates, ,Series `200��'A fie�u }cen;iang 3�each �ecurtt *e "s'i Corp ,�Doposifor, I,ori�x'Beach Mortgage`. `Company, SellerYaiid�Mastcr S`rvzez and ] eiitsclie:Aankha'tionai'Tz1i "st C�mtiany,s frtzstoe ,,._._.w a F Exltibit,A (Continued) fooling and Servicing Agreement "dated as - of b4ay 1, 2006 for Long Beach Mortgage Loan Trust 2006 -4 ,Asset- Backed Certificates, Series 2006 -4 between Long Beach Securities Corp.; Depositor, Long Beach. Mortgage Company, Seller and Master Servicer, and Deutsche Bank National Trust Company, Trustee._ Pooling and Servicing Agreement dated .as of Tune 1, 2006 for Long Beach Mortgage Loan Trust 2006 -5 Asset Backed Certificates, Scries 1006 -5 between .Tong Beach Securities Corp. Depositor; Fong Beach Mortgage. Company, Seller and Master. Servicer, and Deutsche Bank National Trust Company, Trustee. Fooling and Servicing Agreement dated as oP. July 1, 2006 for Long Beach . Mortgage 'Liian. Trust 2006 -6 Asset Backed Certificates, Series 2006 -6 beiNveen'Long Beach Securities Corp. Depositor, Washington Mutual Bank, Se'ller.and Scrvicer; and Deutsche Bank Trust.Company Delaware, Trustee: Pooling and Servicing Agreement dated as of 'August 1, 2 Long beach Mortgage Loan Trust 2006 -7 Asset - Backed Certificates, Series 2006 -7 between Long Beach Securities Corp., Depositor, Washington Mutual 73ank, Sellefiind Servicer; and Deutsebe Bank Trust Company Delaware, Trustee. Pooling and Senricing Agreeffi6t dated as of September 1, 2606 for Long Beach Mortgage. Loan Trust 2006 -8 Asset- Backed Certificates, Series 1006 -8 bctNvicen Long Beach Securities Corp., Depositor, Washington Mutual bank,:Seller and Sery k Tr icer; and Deutsche Banust Company Delaware, Trustee. P6olicig and Servicing Agreement dated as ofoctober ],'2006' for Long Beaeb Mortgage Loan Trust'2006 -9 Asset - Backed Certificates, Series 2006 -9 behveen tong Beach' each 'Securities Cori}., Depositor, 1�iJashington A4ittuaI Bank; Seller and Scrvicer, and Deutsche Bank Trust Company Dela- are, Trustee. P6oling.and Servicing Agreement dated as of November ;1, 2066 for Long Beach Mortgage Loan 'Trust 2006 -10 Asset- Backed Certificates, Series 2006 -10 between Long beach 'Securities Corp., Depositor, lwTashington Mutual Bank, Seller aud. Scrvicer, and Deutsche Bank Trust Company Delaware, Trustee. Pooling and Servicing Agreement dated a§ of December 1, 2006 for Long 13eac:h MoAgage Loan Trust 2006 -1.1 Asset - Backed Certificates, Series 2006 -11 between Long Beach Securities Corp., Depositor, Avas_hington Mutual Barak, Seller and Servicer, and Deutsche Bank Trust Company Dclaw %are, Trustee. 0 56 BBC,.,t3BD, BB F, BBF, 1313(3, BBl,13BL, BRM, 8131; t3BQ,13BR . W3 RBU, BMV, BBX: BBY, BCA, BCC, BCD, BCB, BCF, BCfi, F3 1301, C4t 80 , t3CM, BCA, BCl . BCQ, BCR, BCS, Ki, Y i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA n 3 v o �r DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN 2q 7 Cn TRUST 2006 -2 Case No.'� ' ✓ I ` -C t_ r Plaintiff VS. °w DAVID A. NOREIKA { '_ SHELLEY M. NOREIKA Defendant(s) NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) 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 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. Respectfully submitted: gnatur of Counsel for Plaintiff) 7/1.0/2013 Date s Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Late Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To compiet&your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the fallowing information to the best of your knowledge: Ct.jST Borrower name(s): Property Address: City= State:_ Zip: Is the property for sale? Yes Ej No El Listing date: Price. $ . Realtor Name: Realtor Phone: Borrower Occupied? Yes l+so Mailing Address (if different): City: State: Zip: Phone plumbers: Home: Office: Cell: Other: Email: of people in household: flow long? Mailing Address; City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email; #,t ofpeople in household: How ]one? FINANCIAL INFORNIATION: First Mortgage Lender: Type of Loan: Loan. Number: Bate You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: I'dma[y Reason for Default. Is the loan in Bankruptcy? Yes No � If yes, ,provide names, location of court, cast, number & attorney: Assets Amount Owed: Value: Horner _— Other Real Estate: Retirement Funds: Investments: $ $ Checking: Savings: $ $ Other: $ $ Automobile #l: Model: Year :. Amount owed: Value: Automobile #2 : Model: Year: Amount owed: Valve: Other transoartation (autornobiles boats moto=cles): Model: Year. Amount owed: Value Monthiv Income Marne of Employers: 1, 2. 3. Additional Income Description (not wages): 1. monthly amount: 2. montl}ly amount: Borrower Pay Days: Co- Borrower Pay bays: 1VM011thlY Emioenser. (Please only include expenses you are currently paying) EXPENSE FWOUN EXPENSE AMOUNT Mo, a Food 2` Mortgage Utilities Cyr 1'a ens Condo/Nei Fees Auto insurance Med. not covered Auto fuel /re irs Other e roe. PM menu Install. Loan Payment . I Cable TV Child Su ort/Al1m, ------ Spe nd ing Mone Da /Child Care/Tuit. Other Ex uses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes El No If yes, please provide the following informlation: C€ tinseling Agency: Counselor: Phone.(Offjce): Fax: . Email: Have you made applicati for Homeowne Emergency Mortgage Assistance Prog (HEMAP) assistance? Yes - 0 No ED If yes, please indicate the stat o f the application: Have you had any prior negotiatio with your tender or lender's l oan serv company to resolve your delinquency? Yes No If Yes, Please indicate the status of those negotiations: Please provide the follow information, if know, regarding your lender or leader's loan servicing company: Lender's Contact (Marne): Phone. Servicing Company (Name): Contact: Phone: AUJ 14ORIZATION I/We, authorize the above named to use/refer this information to my londe for the sole purpose of evaluating my financial situation for Possible mortgage options. We understand that I/we am/are under no obligation to use the services provided by the above named Borrower Signature Date Co-Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel, Proof of inco 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 a any supporting documentation (bardship letter) Listing agreement (if property is currentl y on the market) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson F Is L E J-O :F I ,E Sheriff ` T fY . n 'Cl t arty€ie . L a tt� iP€t( TT JO.N t.f,I'i I' Jody S Smith Chief Deputy ;; 2013 JUL 26 AM 10: 30 Richard W CUMBERLANO Solicitor r xl PENNSYLVANIA Deutsche Bank National Trust Company Case Number vs. David A Noreika (et al.) 2013-3975 SHERIFF'S RETURN OF SERVICE 07/16/2013 03:54 PM -Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Shelley Marie Noreika, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"_Not Found"at 1806 Centerville Road, Cooke Township, Newville, PA 17241. Residencea appears to be vacant. 07/16/2013 03:54 PM -Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: David A Noreika, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 1806 Centerville Road, Cooke Township, Newville, PA 17241. Residence appears to be vacant. 07/22/2013 01:37 PM - Deputy William Cline, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Katie Noreika, Daugh r, ho accepted as"Adult Person in Charge"for David A Noreika at 512 Middle Road, Upper Mifflin Newvill 17241. "WILLIAM CLINE, DEPUTY 07/22/2013 01:39 PM - Deputy William Cline, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Katie Noreika, Daughter,who accepted as"Adult Person in Charge"for Shelley Marie Noreika at 512 Middle Road, Upper fi P, Newville, PA 17241. %ILILTAM d LINE, DEPUTY SHERIFF COST: $71.12 SO ANSWERS, July 24, 2013 RbNW R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosoft,Inc. In the Court of Common Pleas of Cumberland County DEUTSCHE BANK NATIONAL TRUST COMPANY,AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2006-2 c/o 3415 Vision Drive No. 13-3975 Columbus,OH 43219 Plaintiff , vs. r`_ ..r DAVID A.NOREIKA "13 -- SHELLEY M.NOREIKA (Mortgagor(s)and Record Owner(s)) �}-'~ L 1806 Centerville Road l Newville,PA 17241 �s Defendant(s) PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against DAVID A.NOREIKA and SHELLEY M.NOREIKA by default for want of an Answer. Assess damages as follows: $195,320.24 Debt Interest from 6/19/2013 to Date of Sale per diem at$25.37 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record,if any,after the default occurred and at least ten days prior to the date of the filing of this praecipe.A copy of the notice is attached.R.C.P. 23 .1 By: KML LAW GROUP,P.C. Michael McKeever Pa.ID 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Krishna Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F.Gomall Pa.ID 92382 / C z,eZ, Attorneys for Plaintiff AND NOW / ,Judgment is entered in favor of DEUTSCHE BANK NATIONAL TRUST COMPANY,AS TRUSTEE FOR LO&G BEACH MORTGAGE LOAN TRUST 2006-2 and against DAVID A.NOREIKA and SHELLEY M.NOREIKA by deft for NRtakt of acrAps,wer and damaaei assessed in the sum of$195,320.24 as per the above certification. ?, e Pr'a`tonot'igry C1411 ��611,.5b� 4� \\)Dwi Rule of Civil Procedure No. 236—Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY,PENNSYLVANIA CIVIL ACTION-LAW DEUTSCHE BANK NATIONAL TRUST COMPANY,AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2006-2 do 3415 Vision Drive Columbus,OH 43219 Plaintiff No. 13-3975 vs. DAVID A.NOREIKA SHELLEY M.NOREIKA (Mortgagors and Record Owner(s)) 1806 Centerville Road Newville,PA 17241 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. David D.Buell Prothonotary of Cumbnd County k 4 1 Courthouse Square Carlisle,PA 17013 Prothonotary By: Deputy If you have any questions concerning the above,please contact: KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 103177FC L THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: January 30,2014 TO: DAVID A.NOREIKA NOREIKA,DAVID A. 1806 Centerville Road Newville,PA 17241 In the Court of DEUTSCHE BANK NATIONAL TRUST COMPANY,AS TRUSTEE FOR Common Pleas LONG BEACH MORTGAGE LOAN TRUST 2006-2 of Cumberland County do 3415 Vision Drive • Columbus,OH 43219 Plaintiff CIVIL ACTION-LAW vs. DAVID A NOREIKA Action of SHELLEY M NOREIKA Mortgage Foreclosure (Mortgagor(s)and Record Owner(s)) 1806 Centerville Road No. 13-3975 NewvilIc,PA 17241 Uefendani(s) TO: DAVID A.NOREIKA 1806 Centerville Road Newville,PA 17241 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR O13JECIIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN(10)DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. 1F 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 EI.,1GIJ3LE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 I..EGAI.SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 By: KML LAW ROUP,P.C. Michael McKeever Pa.ID 56129 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Jill P.Jenkins Pa.ID 306588 ITAlyk L.Oflazian Pa.ID 312912 Salvatore Filippello Pa.ID 313897 Michael J.Coskey Pa ID 311835 215-627-1322 Attorneys for Plaintiff ,._.....:_. - ------------- ::.,.----, ,-------- - -, ...- - 1-- _ - .-- 1 ------- • 103177FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: January 30,2014 TO: SHELLEY M.NOREIKA NOREIKA,SHELLEY M. - 1806 Centerville Road Nevvville,PA 17241 In the Court of DEUTSCHE BANK NATIONAL TRUST COMPANY,AS TRUSTEE FOR Common Pleas LONG BEACH MORTGAGE LOAN TRUST 2006-2 of Cumberland County do 3415 Vision Drive Columbus,OH 43219 Plaintiff CIVIL ACTION-LAW vs. DAVID ANOREIKA Action of SHELLEY M NOREIKA Mortgage Foreclosure (Mortgagor(s)and Record Owner(s)) 1806 Centerville Road No. 13-3975 Newvillc,PA 17241 Defendants) TO: SHELLEY M.NOREIKA 1806 Centerville Road Newville,PA 17241 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRIT[EN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WI'11I THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN(10)DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. '11IIS 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 Will INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL. SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SFRVICE S INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 By: KML LAW GR UP,P.C. Michael McKeever Pa.ID 56129 • Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Jill P.Jenkins Pa.ID 306588 pAlyk L.Oflazian Pa.ID 312912 Salvatore Filippello Pa.ID 313897 Michael J.Coskey Pa ID 311835 215-627-1322 Attorneys for Plaintiff 103177FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: January 30,2014 TO: DAVID A NOREIKA NOREIKA,DAVID A. 512 Middle Road Newville,PA 17241 In the Court of DEUTSCHE BANK NATIONAL TRUST COMPANY,AS TRUSTEE FOR Common Pleas 1 LONG BEACH MORTGAGE LOAN TRUST 2006-2 of Cumberland County do 3415 Vision Drive Columbus,OH 43219 Plaintiff CIVIL ACTION-LAW vs. DAVID A NOREIKA Action of SHELLEY M NOREIKA Mortgage Foreclosure (Mortgagor(s)and Record Owner(s)) 1806 Centerville Road No. 13-3975 Newville,PA 17241 Defendant(s) TO: DAVID A NOREIKA 1 512 Middle Road Newville,PA 17241 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WTITIIN TEN(10)DAYS FROM THE DATE OF TI-US NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 /fl By: KML LAW GROUP,P.C. Michael McKeever Pa.ID 56129 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Jill P.Jenkins Pa.ID 306588 x1 Alyk L.Oflazian Pa.ID 312912 Salvatore Filippello Pa.ID 313897 Michael J.Coskey Pa ID 311835 215-627-1322 Attorneys for Plaintiff ! 103177FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: January 30,2014 TO: SHELLEY M NOREIKA NOREIKA,SHELLEY M. 512 Middle Road Newville,PA 17241 In the Court of • DEUTSCHE BANK NATIONAL TRUST COMPANY,AS TRUSTEE FOR Common Pleas LONG BEACH MORTGAGE LOAN TRUST 2006-2 of Cumberland County do 3415 Vision Drive Columbus,OH 43219 Plaintiff CIVIL ACTION-LAW vs. �I DAVID A NORF_1KA Action of SHELLEY M NOREIKA Mortgage Foreclosure (Mortgagor(s)and Record Owner(s)) 1806 Centerville Road No.13-3975 Newvillc,PA 17241 • Defendant(s) 10: SHELLEY M NOREIKA 512 Middle Road Newville,PA 17241 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FIT:F.IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACC WITHIN TEN(10)DAYS FROM TI IF DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGI cis. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SF:I'FORTH BELOW. ThIS OFFICE CAN PROVIDE YOU WITI-I 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 By: i l•� KML LAW GROUP,P.C. Michael McKeever Pa.ID 56129 F Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Jill P.Jenkins Pa.ID 306588 'Alyk L.011azian Pa.ID 312912 Salvatore Filippello Pa.ID 313897 Michael J.Coskey Pa ID 311835 215-627-1322 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY,AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2006-2 Plaintiff vs. NO. 13-3975 DAVID A.NOREIKA SHELLEY M.NOREIKA Defendant(s) VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter,does hereby state to the best of his/her information and belief,as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense (https://www.dmdc.osd.mil/appj/scra/scraHome.do) for the following individual(s): DAVID A. NOREIKA, has a last known residence of 512 Middle Road, Newville,PA 17241. The following information was used to search the DMDC (check all that apply): X Last Name X First Name X Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A.4904 relating to unsworn falsification to authorities. Date a2 o 1 Y By: KML LAW GROUP,P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313897 Jill P.Jenkins Pa. ID 306588 70 Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff • Department of Defense Manpower Data Center Results as of:Feb-26-2014 08.36:04 AM SCRA 3.0 `y ,t tpl 1,41114,4*,z r�J'.. c _ : Status R Oft 1744' .�. . Pursuant to S icemembers Civil Relief Act a Last Name: NOREIKA First Name: DAVID Middle Name: A. Active Duty Status As Of: Feb-26-2014 On Active Duty On Active Duly Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals'active duty status based on the Active Duly Status Date Left Active Duty Within 367.Days of Active Duty Status Date Active Duty Start Date. Active Duty End Date - Status - Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date - Order Notification End Date Status Service Component NA NA ` No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. .. , .....4(4441,13/4.... )4v:ill AL r Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARS),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 370CA1 FCNO20E20 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY,AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2006-2 Plaintiff vs. NO. 13-3975 DAVID A.NOREIKA SHELLEY M.NOREIKA Defendant(s) VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter,does hereby state to the best of his/her information and belief,as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense (https://www.dmdc.osd.miUappj/scra/scraHome.do) for the following individual(s): SHELLEY M. NOREIKA, has a last known residence of 512 Middle Road, Newville, PA 17241. The following information was used to search the DMDC (check all that apply): X Last Name X First Name X Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. n/ C Y By: , Date v� v� /J / � I KML LAW GROiUP,P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313897 Jill P.Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff Department of Defense Manpower Data Center Results as of:Feb-26-2014 08:38:02 AM SCRA 3.0 S ti A dp8 V'J status Report Pursuant to Servicemembers Civil Relief Act Last Name: NOREIK ■ First Name: SHELLEY Middle Name: M. Active Duty Status As Of: Feb-26-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA "NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. ANA" )4te Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARS),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 1724P1BCT021ZBO KML Law Group, P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE IN THE COURT OF COMMON PLEAS LOAN TRUST 2006-2 do 3415 Vision Drive of Cumberland County Columbus,OH 43219 Plaintiff vs. CIVIL ACTION LAW DAVID A.NOREIKA SHELLEY M.NOREIKA ACTION OF MORTGAGE FORECLOSURE (Mortgagor(s)and Record owner(s)) 1806 Centerville Road Newville,PA 17241 No. 13-3975 Defendant(s) ORDER FOR JUDGMENT Please enter Judgment in favor of DEUTSCHE BANK NATIONAL TRUST COMPANY,AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2006-2,and against DAVID A.NOREIKA and SHELLEY M.NOREIKA for failure to file an Answer in the above action within(20)days from the date of service of the Complaint,in the sum of $195,320.24. By: �f KML LAW GROUP,P.C. Michael McKeever Pa.ID 56129 Jay E. Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I. Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 /91 .,L Z, 4/4Z dc& Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff - J� /i//' I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is DEUTSCHE BANK NATIONAL TRUST COMPANY,AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2006-2 c/o 3415 Vision Drive Columbus,OH 43219 and that the name(s)and last known address(es)of the Defendant(s) is/are DAVID A.NOREIKA, 512 Middle Road Newville,PA 17241 and SHELLEY M.NOREIKA,512 Middle Road Newville,PA 17241; • By: KML LAWGROUP,P.C. Michael McKeever Pa.ID 56129 Jay E. Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa. 205047 Jill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff l ) / ' ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $140,028.03 Interest from 09/01/2008 through $45,203.12 06/18/2013 Reasonable Attorney's Fee $1,100.00 Suspense ($683.15) Escrow $9,672.24 $195,320.24 By: KML LAW GROUP,P.C. Michael McKeever Pa.ID 56129 Jay E. Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa. ID 92382 Attorneys for Plaintiff 's 31'0�cp �, AND NOW,this day of r1/11• ,2014 damages asses as a Pro Prothy 13-3975/103177FC PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 KML Law Group,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2006-2 IN THE COURT OF COMMON PLEAS do 3415 Vision Drive Columbus,OH 43219 of Cumberland County Plaintiff vs. CIVIL ACTION—LAW DAVID A.NOREIKA ACTION OF MORTGAGE FORECLOSURE SHELLEY M.NOREIKA Mortgagor(s)and Record Owner(s) 1806 Centerville Road No. 13-3975 Newville,PA 17241 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION - rn TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: r" Amount Due t? $195,320.24 = --- Interest from t" 6/19/2013 to Date of Sale per diem at $25.37 (Costs to be added) 6.) a3-.)56 pd a t6d, V�"� .y. a 3 By: LAW GROUP,P.C. Michael McKeever Pa.ID 56129 ` , Jay E. Kivitz Pa.ID 26769 1 4 v) u Lisa Lee Pa.ID 78020 I a Kristina Murtha Pa.ID 61858 lq ( David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Co. Andrew F.Gornall Pa.ID 92382 CS so ( Attorneys for Plaintiff elcii )59,C;ey., f4r- 224,N/ 2 L! d' ( ALL THAT CERTAIN piece of ground with improvements thereon situate in Cook Township, Cumberland County, Pennsylvania, more particularly described as follows, to wit: BEGINNING at a nail in the centerline Road of Centerville Road S.R. 233; thence South 59 degrees 00 minutes 00 seconds East a distance of 364.07 feet to a nail; thence along lands now or formerly of the Commonwealth of Pennsylvania "Michaux State Forest" South 72 degrees 31 minutes 15 seconds West a distance of 226.69 feet to a stone pile; thence continuing along lands now or formerly of Commonwealth of Pennsylvania "Michaux State Forest" North 61 degrees 00 minutes 00 seconds West a distance of 204.34 feet to a iron pin set; thence along lands now or formerly of Ann Marie Sutton North 27 degrees 54 minutes 00 seconds East a distance of 171.12 feet to the place of BEGINNING. CONTAINING a total area of 1.1246 acres as shown on the attached survey prepared by James C. Hockenberry, PLS and dated 11/25/05. IMPROVEMENTS consist of a residential dwelling. MUNICIPALITY Cook Township BEING PREMISES: 1806 Centerville Road Newville PA 17241 SOLD as the property of David A. Noreika and Shelley M. Noreika, husband and wife TAX PARCEL#07-37-2569-008A BEING the same premises which Allen P. Sutton and Stephanie L. Sutton, husband and wife by deed dated 12/22/2005 and recorded 1/17/2006 in Cumberland County in Deed Book Volume 272 at Page 3985 granted and conveyed unto David A. Noreika and Shelley M. Noreika, husband and wife. KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 .;�•p q FEB 2Q Attorney for Plaintiff , J { v 1 2: / €7 DEUTSCHE BANK NATIONAL TRUST ?t `)4S V MI }tT r' COMPANY, AS TRUSTEE FOR LONG BEACH IN THE COURT OF COMMO PLEAS MORTGAGE LOAN TRUST 2006-2 do 3415 Vision Drive of Cumberland County Columbus, OH 43219 Plaintiff vs. CIVIL ACTION-LAW DAVID A.NOREIKA SHELLEY M.NOREIKA ACTION OF MORTGAGE FORECLOSURE (Mortgagor(s)and Record Owner(s)) 1806 Centerville Road Newville,PA 17241 Defendant(s) No. 13-3975 AFFIDAVIT PURSUANT TO RULE 3129 DEUTSCHE BANK NATIONAL TRUST COMPANY,AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2006-2,Plaintiff in the above action,by counsel,KML Law Group,P.C.,sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 1806 Centerville Road Newville,PA 17241 1.Name and address of Owner(s)or Reputed Owner(s): DAVID A.NOREIKA 512 Middle Road Newville,PA 17241 SHELLEY M.NOREIKA 512 Middle Road Newville,PA 17241 2.Name and address of Defendant(s)in the judgment: DAVID A.NOREIKA 512 Middle Road Newville,PA 17241 SHELLEY M.NOREIKA 512 Middle Road Newville,PA 17241 3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE-Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O.Box 2675 Harrisburg,PA 17105-2675 4.Name and address of the last recorded holder of every mortgage of record: ALLAN P. SUTTON 100 River Road Dauphin,PA 17018 STEPHANIE L. SUTTON 100 River Road Dauphin,PA 17018 5.Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6.Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. TENANTS/OCCUPANTS 1806 Centerville Road Newville,PA 17241 I verify that the statements made in this affidavit are true and correct to the best of my information and belief.I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. DATED: Vt,;-2 o/y By: y KML LAW GROUP,P.C. Michael McKeever Pa.ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F. Gornall Pa.ID 92382 Attorneys for Plaintiff /3' 3/c) o 13-3975 KML Law Group,P.C. t , Suite 5000-BNY Independence Center 'x 701 Market Street ``i pL,( Philadelphia,PA 19106 1 1 f 2: I (215)627-1322 try( °€ Attorney for Plaintiff 'E 1.3 •UIJ r T i DEUTSCHE BANK NATIONAL TRUST COMPANY,AS TRUSTEE FOR LONG BEACH IN THE COURT OF COMMON PLEAS MORTGAGE LOAN TRUST 2006-2 do 3415 Vision Drive of Cumberland County Columbus, OH 43219 Plaintiff CIVIL ACTION -LAW vs. ACTION OF MORTGAGE DAVID A. NOREIKA FORECLOSURE SHELLEY M.NOREIKA Mortgagor(s)and Record Owner(s) 1806 Centerville Road Newville,PA 17241 Docket No. 13-3975 Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: NOREIKA,DAVID A. DAVID A. NOREIKA 512 Middle Road Newville,PA 17241 Your house at 1806 Centerville Road,Newville,PA 17241 is scheduled to be sold at Sheriffs Sale on Wednesday,June 04,2014,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$195,320.24 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2006-2 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: 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2006-2,the back payments,late charges,costs and reasonable attorney's fees due.To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment,if the judgment was improperly entered.You may also ask the Court to postpone the sale for good cause. A 13-3975 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights.The sooner you contact one,the more chance you will have of stopping the sale. (See notice below 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 NOT 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 price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened,you may call the Sheriff of 717-240-6390. 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 house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty(30)days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money.The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after the schedule of distribution is filed. 7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 13-3975 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention @kmllawgroup.com.com. Call Seth at 215-825-6329 or fax. 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 103177FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 13-3975 KML Law Group,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106 ` i FEB ,° �".a (215)627-1322 f, l Attorney for Plaintiff p'3 f r r'`t'j� co , /4 DEUTSCHE BANK NATIONAL TRUST COMPANY,AS TRUSTEE FOR LONG BEACH IN THE COURT OF COMMON PLEAS MORTGAGE LOAN TRUST 2006-2 c/o 3415 Vision Drive of Cumberland County Columbus, OH 43219 Plaintiff CIVIL ACTION-LAW vs. ACTION OF MORTGAGE DAVID A. NOREIKA FORECLOSURE SHELLEY M.NOREIKA Mortgagor(s) and Record Owner(s) 1806 Centerville Road Newville,PA 17241 Docket No. 13-3975 Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: NOREIKA,SHELLEY M. SHELLEY M. NOREIKA 512 Middle Road Newville,PA 17241 Your house at 1806 Centerville Road,Newville,PA 17241 is scheduled to be sold at Sheriff's Sale on Wednesday,June 04,2014,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$195,320.24 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2006-2 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2006-2,the back payments,late charges,costs and reasonable attorney's fees due.To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment,if the judgment was improperly entered.You may also ask the Court to postpone the sale for good cause. 13-3975 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights.The sooner you contact one,the more chance you will have of stopping the sale. (See notice below 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 NOT 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 price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened,you may call the Sheriff of 717-240-6390. 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 house.A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty(30)days from the date of the Sheriffs Sale.This schedule will state who will be receiving that money.The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after the schedule of distribution is filed. 7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 13-3975 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention @kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 103177FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-3975 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2006-2 Plaintiff(s) From DAVID A.NOREIKA,SHELLEY M.NORIEKA (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: $195,320.24 L.L.: $.50 Interest FROM 6/19/2013 TO DATE OF SALE PER DIEM AT$25.37 Atty's Comm: Due Prothy: $2.25 Atty Paid: $219.87 Other Costs: Plaintiff Paid: Date: 2/28/14 )63/"..e.44..;1 . David D. Bu- 1,Prothonota (Seal) I • 4! _ Deputy REQUESTING PARTY: Name: ALYK L.OFLAZIAN,ESQUIRE Address: KML LAW GROUP,P.C. SUITE 5000-BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA,PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No.312912 ICMIL LAW GROUP, P.C. Suite 5000 BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2006-2 c/o 3415 Vision Drive Columbus, OH 43219 vs. DAVID A. NOREIKA SHELLEY M. NOREIKA Mortgagor(s) and Record Owner(s) 1806 Centerville Road Newville, PA 17241 Plaintiff Defendant(s) ril 8� R " " • .f� j pEN�ysYAfG) C171s�. , . INTIM- C "URT OF COMMON PLEAS 103177FC CF: 07/11/2013 SD: 06/04/2014 $195,320.24 of Cumberland County CIVIL ACTION — LAW ACTION OF MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Term No. 13-3975 Veronica Cosme, an employee of KML Law Group, P.C., counsel of Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: Personal Service by the Sheriffs Office/competent adult (copy of return attached). Certified mail by KML Law Group, P.C. (copy of green Postal return receipt attached). Certified mail by Sheriffs Office. Ordinary mail by KML Law Group, P.C. to Attorney for Defendant(s) of record (proof of mailing attached). Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by KML Law Group, P.C. (copy of receipt(s) for Certified Mail attached). ( ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail KML Law Group, P.C. (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 Pa. C.S.A. Section 4904. Respectfully submitted, 13Y: Veronica Cosme Legal Assistant UNITED STATES POSTAL SERVICE Date: March 14, 2014 kalilah osei: The following is in response to your March 14, 2014 request for delivery information on your Certified MailTM item number 9171999991703360112115. The delivery record shows that this item was delivered on March 13, 2014 at 9:51 am in NEWVILLE, PA 17241. The scanned image of the recipient information is provided below. Signature of Recipient : Address of Recipient : r/ U L)) 2- At 1 L/c/Ie del Thank you for selecting the Postal Service for your mailing needs. If you require additional assistance, please contact your local Post Office or postal representative. Sincerely, United States Postal Service UNITED STATES POSTAL SERVICE. Date: March 14, 2014 kalilah osei: The following is in response to your March 14, 2014 request for delivery information on your Certified MaiITM item number 9171999991703360112108. The delivery record shows that this item was delivered on March 13, 2014 at 9:51 am in NEWVILLE, PA 17241. The scanned image of the recipient information is provided below. ure Signature of Recipient : Address of Recipient : _13)2_ A11 L/;1ie r�c� Thank you for selecting the Postal Service for your mailing needs. If you require additional assistance, please contact your local Post Office or postal representative. Sincerely, United States Postal Service Name and Address of Sender •OLDBECK(If .0 ITE 5000 01 MARKET STREET 'HILADELPHIA, PA 9106-1532 Check type of mail or service: L1 Certified ❑Recorded Delivery (international) ❑ COD ❑ Registered ❑ Delivery Confirmation ❑ Return Receipt for Merchandise ❑ Express Mail ❑ Signature Confirmation ❑ Insured Affix Stamp Here issued as a certificate of mailing, - or for additional copies of this bill) Postmark and Date of Receipt Article Number Addressee (Name, Street, City, State, & ZIP Code) Postage Fee Handling Charge Actual Value if Registered Insured Value Due Sender if COD DC Fee SC Fee SH Fee RD Fee RR Fee 1 . DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 ALLAN 100 River Dauphin, P. SUTTON Road PA 1701€ 2 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O Box 2675 S l EF'HANIE 100 River Dauphin, L. 5U Road PA 1701E I I UI'U 1 y4. POS% i/ Bim, . a1• �.� • {4r ' . PITNEY BOWES .�:1..r�:�_ $ 02.300 j..... V.::#1 ` 0 2 1 M 0004285957MAR11 2014 Ir { MAILED FROM ZIP CODE 19106 Tt� 3. Harrisburg, PA 17105-2675 TENANTS/OCCUPANTS 1806 Centerville Newville Road PA 17241 4. 5. 6. 7. 8. Total Number of Pieces Listed by Sender Total Number of Piece Received at Post Office / Postmaster r ( e ceiving employee) See Privacy Act Statement on Reverse PS Form 3877, February 2002 (Page 1 of 2) Complete by Typewriter, Ink, or Ball Point Pen 103177FC Cumberland County Sale Date: 06/04/2014 DAVID A. NOREIKA & SHELLEY M. NOREIKA SSS KML LAW GROUP, P.C. Suite 5000 — BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2006-2 c/o 3415 Vision Drive Columbus, OH 43219 vs. DAVID A. NOREIKA SHELLEY M. NOREIKA Mortgagor(s) and Record Owner(s) 1806 Centerville Road Newville, PA 17241 Defendant(s) Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 13-3975 AFFIDAVIT PURSUANT TO RULE 3129 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2006-2, Plaintiff in the above action, by and through an authorized employee of its attorneys, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 1806 Centerville Road Newville, PA 17241 1.Name and address of Owner(s) or Reputed Owner(s): DAVID A. NOREIKA 512 Middle Road Newville, PA 17241 SHELLEY M. NOREIKA 512 Middle Road Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: DAVID A. NOREIKA 512 Middle Road Newville, PA 17241 • SHELLEY M. NOREIKA 512 Middle Road Newville, PA 17241 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: ALLAN P. SUTTON 100 River Road Dauphin, PA 17018 STEPHANIE L. SUTTON 100 River Road Dauphin, PA 17018 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. TENANTS/OCCUPANTS 1806 Centerville Road Newville, PA 17241 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. DATED: May 20, 2014 KML Law Group, P.C. BY: Veronica Cosme Legal Assistant I , SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff CZUflOrt Jody S Smith IS Chief Deputy ` ` -'- 17 i,1 2: Richard W Stewart " ti i Solicitor - P E ILI 3 Y Deutsche Bank National Trust Company vs. Case Number David A Noreika (et al.) 2013-3975 SHERIFF'S RETURN OF SERVICE 03/24/2014 11:39 AM - Deputy William Cline, 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 1806 Centerville Road, Cooke-Township, Newville, PA 17241, Cumberland County. 06/04/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse 1 Courthouse Square Carlisle Pa, 17013 at 1000 am on June 4, 2014. He sold the same for the sum of$1.00 to Attorney Michael McKeever, on behalf of Deutsche Bank National Trust Company, As Trustee For Registered Holders of Long Beach Mortgage Loan Trust 2006-2, Asset-Backed Certificates, Series 2006-2, being the buyer in this execution, paid to the Sheriff the sum of SHERIFF COST: $777.93 SO ANSWERS, June 20, 2014 RONNK R ANDERSON, SHERIFF `V •0O rdel - pd. t- s LL_pd' /al 364 xnzr•rSu:::S...ar!fP. 41�scf;. .,. • On March 3, 2014 the Sheriff levied upon the defendant's interest in the real property situated in Cooke Township, Cumberland County, PA, Known and numbered as 1806 Centerville Road, Newville, as Exhibit "A" filed with this Writ and by this Reference incorporated herein. Date: March 3, 2014 By: C Lri Real Estate Coordinator 1 LXIII 16 CUMBERLAND LAW JOURNAL 04/18/14 Writ No. 2013-3975 Civil Term Deutsche Bank National Trust Company vs. David A. Noreika Shelley Marie Noreika Atty.: Michael McKeever IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 1806 Center- ville Road, Newville, PA 17241. SOLD as the property of DAVID A. NOREIKA and SHELLEY M. NOREIKA. TAX PARCEL#07-37-2569-008A. 87 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 18, April 25 and May 2, 2014 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. t. ,-,-„-...__ ri,....- ----- Lisa Marie Coyne, E itor SWORN TO AND SUBSCRIBED before me this 2 da of May, 2014 _ / i / � / , Notary COMMONWEALTH OF PENNSYLVANIA —NOTARIALSEAL DEBORAH A COLLINS Notary Public CARLISLE BORO..CUMBERLAND CNTY My Commission Expires Apr 28.2018 The Patriot-News Co. 2020 Technology Pkwy 4 hePatriotNews Suite 300 Mechanicsburg, PA 17050 Now you know Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s)shown below: 04/13/14 • 04/20/14 2013.3975 ChM Term . 04/27/14 Deutsche Bank National 'est Company Vs David A Norelka Shelley Marie Norelka Swo n t• a '• subscribed before jot • 02 day of May, 2014 A.D. Atty: Michael McKeever IMPROVEMENTS consist of' a di& _ . , tit (' residential dwelling. BEING PREMISES:1806 Centerville = :ry Public I ad Newville,PA 17241 •LD as the property of DAVID OREIKA and SHELLEY M. r orrr E+CF Dl SY€• 'ARCEL#07-37-2569-008A i COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Deutsch Bank,NA as Trustee for Registered Holders of Long Beach Mortgage Loan Trust 2006-2, Asset Backed Cert Series 2006-2 is the grantee the same having been sold to said grantee on the 4th day of June A.D., 2014, under and by virtue of a writ Execution issued on the 28th day of February, A.D., 2014, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 3975, at the suit of Deutsch Bank National Trust Co as Trustee for Long Beach Mortgage Loan Trust 2006-2 against David A. Noreika& shelley M. Noreika is duly recorded as Instrument Number 201415524. IN TESTIMONY WHEREOF, I have hereunto set my hand and al of said office this ! 7 day of , A.D. r.- 6/r , c• AAp , , IV ecorder of Deeds Decor.7 . Deeds,Cumberland County,Carlisle,PA My C ission Expires the First Monday of Jan.2018