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HomeMy WebLinkAbout13-6137 Supreme Co ennsylvania COur Co%m,o _ leas For Prothonotary Use Only: J , Docket No: MCSTR C and County 2 All r / The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court. Commencement of Action: S El Complaint ® Writ of Summons [3 Petition ® Transfer from Another Jurisdiction 0 Declaration of Taking E C Lead Plaintiff s Name: Lead Defendant's Name: T Deutsche Bank National Trust Company Jimmy D. Stoey; Nichole R. Stoey Dollar Amount Requested: © within arbitration limits I Are money damages requested? ❑Yes No O (check one) ®x outside arbitration limits N Is this a Class Action Suit? © Yes 0 No Is this an MDJAppeal? ® Yes X No A Name of Plaintiff /Appellant's Attorney: V) F (' ; C K-51 bck U C�)ej E5 q u I' r e 1J a 13 Check here if you have no attorney (are a Self - Represented [Pro Se] Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS Intentional ® Buyer Plaintiff Administrative Agencies Malicious Prosecution ® Debt Collection: Credit Card J Board of Assessment l3 Motor Vehicle J Debt Collection: Other [] Board of Elections C3 Nuisance El Dept. of Transportation © Premises Liability Statutory Appeal: Other S ® Product Liability (does not include L'j mass tort) Employment Dispute: Slander/Libel/ Defamation Discrimination C M Other: Employment Dispute: Other © Zoning Board T 0 Other: I [3 Other: O MASS TORT l3 Asbestos N a Tobacco 0 Toxic Tort - DES k Toxic Tort -Implant Toxic Waste REAL PROPERTY MISCELLANEOUS © Other: ® Ejectment Common Law /Statutory Arbitration B Eminent Domain /Condemnation Declaratory Judgment Ground Rent © Mandamus ] Landlord/Tenant Dispute © Non- Domestic Relations Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY Mortgage Foreclosure: Commercial ® Quo Warranto Dental Partition Replevin Legal ® Quiet Title Other: Medical ❑ Other: Other Professional: Updated 1/1/2011 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE GAZZARA DOYLE, ESQUIRE - ID #34576 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 SALVATORE CAROLLO, ESQUIRE - ID #311050 HARRY B. REESE, ESQUIRE - ID #310501 ELIZABETH L. WASSALL, ESQUIRE - ID #77788 JOHN ERIC KISHBAUGH, ESQUIRE - ID #33078 NICOLE B. LABLETTA, ESQUIRE - ID #202194 '" y DAVID NEEREN, ESQUIRE - ID #204252', JORDAN DAVID, ESQUIRE - ID #311968 © °' AMANDA RAVER, ESQUIRE - ID #307028 7? v WOODCREST CORPORATE CENTER -A! 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ,08003 -3620 856- 669 -5400 Pleadings@udren.com Deutsche Bank National Trust Company, as Trustee COURT OF COMMON PLEAS for Soundview Home Loan Trust 2006- NLC1,Asset- CIVIL DIVISION Backed Certificates,Series 2006 -NLC1 CUMBERLAND County 1661 Worthington Road, Suite 100, West Palm Beach, FL 33409 qLoiD P laintiff NO. v V. Jimmy D. Stoey 11335 Mountain Road Orrstown, PA 17244 -9649 Nichole R. Stoey 11335 Mountain Road Orrstown, PA 17244 Defendant(s) ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the following counsel: Mark J. Udren, Esquire; Stuart Winneg, Esquire; Lorraine Gazzara Doyle, Esquire; Sherri J. Braunstein, Esquire; Harry B. Reese, Esquire; Salvatore Carollo, Esquire; Elizabeth L. Wassall, Esquire; John Eric Kishbaugh, Esquire; Nicole B. LaBletta, Esquire; David Neeren, Esquire, Jordan David, Esquire, and Amanda Rauer, Esquire on behalf of the Plaintiff, in the above - captioned matter. UDREN LAW OFFICES, P.C. BY .JOHN ERIC nsH& JQH, ESQUIRE UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE GAZZARA DOYLE, ESQUIRE - ID #34576 SHERRI J. BRAUNSTEIN, ESQUIRE - ID#90675 =; SALVATORE CAROLLO, ESQUIRE - ID #311050 HARRY B. REESE, ESQUIRE - ID #310501 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 -� JOHN ERIC KISHBAUGH, ESQUIRE - ID #33078 �y c� NICOLE B. LABLETTA, ESQUIRE - ID #202194 DAVID NEEREN, ESQUIRE - ID#204252 JORDAN DAVID, ESQUIRE - ID #311968 -,;M ;5 AMANDA RAVER, ESQUIRE - ID #307028' WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856 669 - 5400 pleadings @udren.com Deutsche Bank National Trust Company, COURT OF COMMON PLEAS as Trustee for Soundview Home Loan CIVIL DIVISION Trust 2006- NLC1,Asset- Backed CUMBERLAND County Certificates,Series 2006 -NLCl C/O Ocwen Loan Servicing, LLC 1661 Worthington Road NO. 1 3 , Suite 100 West Palm Beach, FL 33409 Plaintiff V. JIMMY D. STOEY 11335 MOUNTAIN ROAD ORRSTOWN, PA 17244 -9649 NICHOLE R. STOEY 11335 MOUNTAIN ROAD ORRSTOWN, PA 17244 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice S are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 -3620 (856) 669 -5400 1. Plaintiff is the entity designated in the caption on a preceding page. Plaintiff is the legal holder of the Mortgage that is the subject of this Action. Plaintiff is either the current mortgagee of record, is the legal holder of the Mortgage by virtue of being successor in interest to the current mortgagee of record, or is the legal holder of the Mortgage by virtue of Assignment of Mortgage. If Plaintiff is the legal holder of the Mortgage by virtue of Assignment of Mortgage, it is by the following Assignments of Mortgage, all of which have either been recorded or Plaintiff is in the process of formalizing the actual Assignment of Mortgage in Plaintiffs favor: Assignor: Mortgage Electronic Registration Systems, Inc. as nominee for First NLC Financial Services, LLC, DBA the Lending Center Assignee: Deutsche Bank National Trust Company, as Trustee for Soundview Home Loan Trust 2006 -NLC1, Asset - Backed Certificates, Series 2006 -NLCl Date of Assignment: 08/09/2012 Recorded Date: 09/07/2012 Book/Instrument #: Instrument# 201227292 Page: N/A 2. Upon information and belief Defendant(s) and/or their predecessor: Jimmy D. Stoey & Nichole R. Stoey (hereinafter "Defendants "), are the owners of property located at 102 Cleversburg Road, Shippensburg, PA 17257, by virtue of Deed dated 10/31/2002 and recorded 11/07/2002 in Official Records Book 254 at Page 2265 of the Public Records of Cumberland County, Pennsylvania (hereinafter the "Property"). 3. On 08/18/2006, Defendant(s) and/or their predecessor: JIMMY D. STOEY NICHOLE R. STOEY promised to pay to the order of First NLC Financial Services, LLC, DBA the Lending Center, the principal sum of $156,000.00 payable with interest thereon provided in the Note. 4. By Mortgage dated 08/18/2006, Defendant(s) and/or their predecessor: JIMMY D. STOEY NICHOLE R. STOEY to secure the Note, mortgaged to Mortgage Electronic Registration Systems, Inc. as nominee for First NLC Financial Services, LLC, DBA the Lending Center, the Property which is the subject of this action. The Mortgage was recorded on 08/28/2006 in Official Records Book 1963 at Page 3254. Said Mortgage is incorporated herein by referenced in accordance with Pa.R.C.P 1019(g). A legal description of the mortgage premises is attached hereto and made a part hereof. 5. Said mortgage is in default in that the payment due 09/01/2011, and all subsequent payments have not been made, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with the other charges authorized by said Mortgage and itemized below, shall be immediately due. 6. After demand, the Defendant(s) continues to fail or refused to comply with the terms of the Mortgage as follows: (a) By failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) By failing or refusing to pay other charges, if any, indicated below. The following amounts are due on the said Mortgage or modification agreement as of the date stated below Unpaid Principal Balance $150,996.26 Accumulated Interest $8,315.77 Accumulated Late Charges $181.10 Escrow Deficit /(Reserve) $4,372.52 Title Report $300.00 Attorney Fee $1,650.00 Bankruptcy Cost $176.00 Bankruptcy Fee $625.00 Property Maintenance $692.50 Property Inspection Fee $84.00 Property Valuation Fee -BPO $1,168.00 Grand Total $168,561.15 The above figures are calculated as of 06/19/2013: The interest rate is subject to adjustment if more fully described as such in the note and mortgage. The interest rate on the subject note is at 3.00000 %. The per diem interest accruing on this debt is $11.9300 and that sum should be added each day after the above date. The late charge is subject to adjustment if more fully described as such in the note and mortgage. The late charge rate on the subject note should be added in accordance to the terms of the note and mortgage charged monthly at $36.22. 7. Breach letters have been sent to Defendant(s) in accordance with the requirements of the subject mortgage and/or The Pennsylvania Act 6 of 1974 of the Commonwealth of Pennsylvania and, if applicable, Act 91 of 1983. Copies of the breach letters are attached hereto as Exhibit "A ". WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $ 168,561.15 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged premises. UDREN LAW OFFICES, P.C. BY: ' I Eric Kishbaugh, Esquire PA !D 33078 VERIFICATION Contract Management I am Dominique Sciullo , Coordinator r of Ocwen Loan Servicing, LLC ( "Ocwen ") the servicing agent (or servicer) for Deutsche Bank National Trust Company, as Trustee for Soundview Home Loan Trust 2006- NLC1,Asset- Backed Certificates,Series 2006 -NLCl ( "Plaintiff'), am authorized to make this verification on behalf of Ocwen and hereby certify that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. Except where otherwise stated and/or based upon public record, this verification is based upon a review of business records regularly created, kept and maintained in the course of Ocweri s mortgage servicing business conducted on Plaintiff s behalf. In making this verification, I understand that it is a crime under 18 PA C.S. Section 4904 to make a written statement to a public servant, or to invite a public servant's reliance upon a written statement or instrument, which I do not I 'eve to be true or which I know to be false Date: Name: Dominique Sciullo Title: Contract Management Coordinator Company: Ocwen Loan Servicing, LLC the servicing agent (or servicer) for Deutsche Bank National Trust Company, as Trustee for Soundview Home Loan Trust 2006-NLC1,Asset- Backed Certificates,Series 2006 -NLCl Borrower: JIMMY D. STOEY NICHOLE R. STOEY Property Address: 102 Cleversburg Road, Shippensburg, PA 17257 MJU #: 12020226 -1 "Ocwen loan servicing, LLC" First .A.rrmer can Ti=tle Insurance Company Commitment No. STOEY ScHECULE C All that certain lot or parcel of Sand situate in the Southampton Township, County of Cumberland, Commonwealth of Pennsylvania, and Iteing more particulatty described as follows: BEGINNING At a Stove In ttte caetxter of a public ragd. thaw. abono and In iha rniddla of ltt9 said m;?d ',vestwwdly 70 Net to an (rats pI n In the middle of the sold toad: thttnoe by lot naw or Tonnsrty of Jem em, - Snutf'r 1 i* foot to a comer In the middle of W Wey; th nM ekattp and Its the middle of The said alley aasfixarriiy 70 foGt; thsnce rtorthw by lot now or reamvfy of tiarvey +attisltalt, ISO Not to thg plaaet of IlVnninp. CONTAINING 48 potrhas moro ortesa. 50Nf3 known an d numMrad as 101. Cieversburg Road, ShIppensbury, F�erurayiverrin. To: Jimmy D. Stoey 11335 Mountain Road Orrstown, PA 17244 -9649 Re: Property Address: 102 Cleversburg Road Shippensburg, PA 17257 MJU #: 12020226 -1 "Ocwen loan servicing, LLC" Exhibit A To: Nichole R. Stoey 11335 Mountain Road Orrstown, PA 17244 -9649 Re: Property Address: 102 Cleversburg Road Shippensburg, PA 17257 MJU #: 12020226 -1 "Ocwen loan servicing, LLC" To: Jimmy D. Stoey 102 Cleversburg Road Shippensburg, PA 17257 Re: Property Address: 102 Cleversburg Road Shippensburg, PA 17257 MJU #: 12020226 -1 "Ocwen loan servicing, LLC" To: Nichole R. Stoey 102 Cleversburg Road Shippensburg, PA 17257 Re: Property Address: 102 Cleversburg Road Shippensburg, PA 17257 MJU #: 12020226 -1 "Ocwen loan servicing, LLC" June 21, 2013 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM ( HEMAP) may be able to help to save your home. This Notice explains how the program works_ To see if HEMAP can 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 NOTIFICACIO'N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIO'N OBTENGA UNA TRADUCCIO'N INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRE'STAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Jimmy D. Stoey ✓ Nichole R. Stoey PROPERTY ADDRESS: 102 Cleversburg Road, Shippensburg, PA 17257 LOAN ACCT. NO.: ORIGINAL LENDER: FIRST NLC FINANCIAL SERVICES, LLC, DBA THE LENDING CENTER CURRENT LENDER/SERVICER: Deutsche Bank National Trust Company, as Trustee for Soundview Home Loan Trust 2006- NLC1,Asset- Backed Certificates,Series 2006 -NLCl 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 temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face -to face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS ANA TTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (B) it up to date). NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender on your property located at: 102 Cleversburg Road, Shippensburg, PA 17257 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due:_ Monthly Payment of $855.30 For September 1, 2011 through June 1, 2013 $18,816.60 Late Charges $181.10 Other Charges (explainlitemize) Property Inspection Fees $84.00 Property Valuation FeesBPO $1,168.00 Escrow Advance $1,493.82 Property Maintenance $692.50 Total Amount Past Due $22,436.02 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, WHICH IS $22,436.02, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: Udren Law Offices, P.C. Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 -3620 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: ( Do not use if not applicable. ) IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the 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 /Servicer. Ocwen Loan Servicing, LLC Address: 1661 Worthington Road, Suite 100, West Palm Beach, FL 33409 Phone Number: 877- 596 -8580 Fax Number. 407 - 737 -5693 Contact Person: Customer Service E -Mail Address: EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You ®may or ❑ may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE 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. PLEASE SEE ATTACHED LIST OF CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY HEMAP Consumer Credit Counseling Agencies CUMBERLAND County Report last updated: 05/17/2013 01:52 PM Advantage Credit Counseling Service/CCCS of Western PA Community Action Commission of Capital Region 2000 Linglestown Road 1514 Deny Street Harrisburg, PA 17102 Harrisburg, PA 17104 888 -511 -2227 717 -232 -9757 Housing Affiance of York/Y Housing Resources Maranatha 290 West Market Street 43 Philadelphia Avenue York, PA 17401 Waynesboro, PA 17268 717 -855 -2752 717 - 762 -3285 PathStone Corporation PathStone Corporation 1625 North Front St 450 Cleveland Ave Harrisburg, PA 17102 Chambersburg, PA 17201 717- 234 -6616 717- 264 -5913 PA Interfaith Community Programs Inc PHFA 40 E High Street 211 North Front Street Gettysburg, PA 17325 Harrisburg, PA 17110 717- 334 -1518 717- 780 -3940 800 -342 -2397 f 7 r CERTIFIED AtA j 016H26519216 UDREN LAW OFFICES, P.C. 1 WOODCREST CORPORATE CENTER $06.312 111 WOODCREST ROAD 1 fA D6/2112013 CHERRY H!� L. NJ 08003 1 Waited From 98003 7012 1640 0000 9213 9292 { US POSTAGE 7012 1640 0000 9213 9292 Af � ✓ � 8 s' To: Jimmy D. 11335 Mo Orrsto' ' i � \ f . SENCIEW + SECTI 7ftwelve ■ Complete items 1, 2, and 3. Also compleW Item 4 if Restricted Dellvery is desired. O Agent ■ Print your name and address on the reverse p Addressee I that hi can return the card t you. y ( p�� Mare) C. Date of Dellvery. I ■ Attach this card to the back of the e mallpleoe, or on -the front if space permthL 1. Articfe Addressed to: D. is delivery address ditferent krn item 17 0 Yea I M YES, enter delivery addresa bekm ❑ No L I �7L"XA 31 Service TWO 4Q tified Ma ❑ EMn. Mail ❑ Registered $ Rehm I leeetpt f or Merchandise + ❑ Insured Malt 0 C.O.D. t 4. Restricted Delivery? {6rtra Fee) p Yes f 2. Article NurnW 7D12 1640 DDDD 921 9292 l i (transfer from aervrce label) P s Form 3611 February 2004 Domestic Return Receipt 1025V M4A -1640 l i3 G y g 5 aC, �o�cn � 1 JO ro g r a�m vau$r°a �- E k m Q 4Q 00 2� �n�' Sm �v a LL v 0 a■ i n ■ e 0 ■ a �' i I CERTIFIED MAILO UAREN LAW OFFICES, P.C. t 016H26519216 WOODCREST CORPORATE CENTER + 111 WOODCREST ROAD ar $06-310 _ CHERRY HILL, NJ 08003 ; i y = 06/21/2013 nbiW From 08003 7012 1,640 9000 9213 9308 � US POSTAGE 7012 1640 0000 9213 9308 To: Nichols . 11335 Ornto , { 1'zs�Z� 4 kd de, Y -- 4a ■ Complete Items 1. 2, and 3. Also complete A. 3lgnature Item 4 if Restricted Delivery is desired, p 1 ■ Print your name and address on the reverse X 0 A gent o I At that we can return the card to you. S. RwAOv= C. Date of oewery i ■Attach this card to the back of the maiipiece, ' or on the fron i f space p e r mits. 1. Article Addressed to; D. fr. � tem i? O Yes \ N If YES, enter delivery address below. No J �.LNCIJ 1kc t \335 Ut1��a�cl bcr P(A s Service Type I O C3 F,cpress PoteA i 1k Fletum.Fteceipt for Mmhwv*. 1 t ❑ Insured Mall 0 C.O.D. i 4. ResMoted Dellv" (aft Fee) ❑ Yes z ArWe Number 7012 1640 000 9213 93Q$ (irgrrsterhorn servke debeg r ` _]_ F'$ Form 3871. Fetx _!' t)orr�eetic Return riecaipt ti 4 � � � m -H - fl E. u� r UOREN LAW OFFICES, P.G. t WOODCREST C-0R PRATE CENTER 01 1POODCREST ROAD CHERR HILL, NJ 8003 �} V�� �� 06/2112013 7 012 1640 000D 9 213 9 315 E Maked From 08003 7012 1640 0000 9213 9315 i US POSTAGE a l y R F , n a r S 1p own v To: Jimmy D OF 102 Ciev Shippens (:_: Yzzz fin" o- t c ceps- G cz i SENDER-, COMPLETE THIS SECTioAr ` ■ Complete Rems 1, 2, and 3. Also complete �item 4 If Restricted Del Is desired. ❑ qq� ■ Print your name and - address on the reverse 0 Addressee So that we Can return tie card to you. by ( printed Name) C. Date of Delivery } ' ■ this card to the back of the mailpiece, or on the front if space permits. D. is delivery address different from Rem 1? ❑ Yes 1 Article Addressed to: If YES, enter delivery address below: ❑ No � \oz G J J ev��sbv�c j .J. �� Stn; C1 �j, i A 1'1 Z S�1 s. service type � Certtfled Mall 13 Express Md i ReVMred I Return Reoelpt for Merohandbe i i ❑ Insured Mal C O.D. 1 4. Re8hiCted Delivery? (Extra fee) ❑ Yes I 2. Article N u mber 7012 1640 0000 9213 9315 1 I (Transfer from service !abet) PS Form 3 811, Febr 2004 Domestic Ret Receip ta25V-oz -e, -1540 { at 0 1 E£ m t p� 21 M42ta Ca■■■ t o ■ ■ ■ ■ �a i r i � 01,17m, I 1lOREN LAW OFFICES, P.C. t wOacuRESr CORPORATE CENTER ()16"26519216 � z 7012 1640 0000 9213 9285 -' �� 8,3 0 US 7012 1640 0000 9213 9285 P OS T AGE �i ar �; 4 � C � • q waft To; Nichol 102 Cteversb � �• Shi PP ensbnr I M `"' m i f i r 1 a Complate items 1, 2, and 3. Also complete i item 4 If Restricted Delivery is desired. X M A ■ print your name and addrese on the reverse so that we can return the cans to you. B. Recelved by; PdnWf me) C. Data of DelNery i y a1 AttLch this card to the back of the mailpiece, Or on the front if space permits. D, Is deW" address different from hrn i " 19 Elves r 1. Artl Addressed tic: If YES, enter delivery Address below. C3 No 1tiZ. C.12,v�csbSs� Yr�d 4 s. servlos ve i Certified Mali ❑ Express Mao I i Registered 1# Return FlsceiPrtor MercherlocftO I I I7 Irmffed Mail ❑ C.O.D. 4. Restricted Ddlveyl (Dora Fee) O Yea z. MideMrnber 7012 1640 DDDD 9213 9285 {lt8rrsfer h+om service lsbeq . r i p5 Po r r n 3 811, February 2004 D omes t ic Retum ReW 102585 - 02M - i540� I � Ha g com� O 1�aaa ova 1$1H u°too =Q• O'�, FORM 1 IN THE COURT OF COMMON PLEAS OF a ,,� sy CUMBERLAND COUNTY, PENN SYLV ANIA GI R I ff( vs. J Defendangs) Civil NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DWERSION 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 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. I.f you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference- with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative ofyour lender in a;, atternpt to ti aril 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: rn Date gnature of Counsel for Plaintiff] -<> - jSi - c) I Eric Kishbaugh, Esquire ° PA i D 33078 o , CD C ., FORM 2 . Cumberland County Residential Mortgage Foreclosure Diversion Program Financial. Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, .your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: CUSTOWIER/PRIMARY APPLICANT Borrower name(s): Property Address: Cite: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied.? Yes ❑ No ❑ Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household.: How- long? INFORMATION' FINANCIAL First Mortgage Lender: Type of Loan: Loan Number.: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount:. $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ ....... ............. .........._..._......__..... ...... ....... .. ...... _ ..... ... .... ._.... ...... ... . . If yes, provide names, location of court, case number &attorney: Assets Amount Owed Value: Homer $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1.: Model: Year: Amount owed: Value: Automobile #2 : Model: Year: Amount owed: Value: Other transportation. (automobiles, boats, motorcycles ): .Model: Year: Amount owed: Value Monthiv Income Name of Employers: 1. J. Additional I.n.come Description (not wages): 1. monthly amount: 2 monthly_ amount: Borrower Pay Days: Co- Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT lV Ttgage Food 2 n Mortgage Utilities Car Payments Cundo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other prop. payment j Install. Loan Pa yment Cable TV Child S'.: port/Alim. Spending Money Da /Child Care/Tuit. Other Expenses i Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: _ ,...._......._........_. _._ ...... ... _ ...... _... -- ..... __ _— Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ❑ No ❑ If yes, please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: AUTHORIZA I/We, , authorize the above named to use /refer this information to my lender /servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I /we amiare under no obligation to use the services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: V Proof of income Past Z bank statements V .Proof of any expected income for the last 45 days V Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation �) (hardship letter) V Listing agreement (if property is currently on the market) FORM 3 e. xvi�' �� I : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA Plainfiff(s) vs Y Defendant(s) CIVIL REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated 2012. governing the Cumberland County Residential Mortgage f=oreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that Notice to be eligible to participate in a court- supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. 'Signature of Defendant's Counsel /Appointed Date Leval Representative Signature of Defendant Date Signature of Defendant Date i UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Company, COURT OF COMMON PLEAS ';12- as Trustee for Soundview Home Loan CIVIL DIVISION , Trust 2006-NLC1,Asset-Backed Cumberland County rn Certificates, Series 2006-NLC1 cf)r �, „ Plaintiff NO. 13-6137 Civil y f--, r. v. G • JIMMY D. STOEY; "F' NICHOLE R. STOEY Defendant(s) PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint on the above-captioned matter. DATE: I 1 i-7/13 UDREN LAW OFFICES, P.C. BY: At : ey for Plain ' f David Neeren, Esquire PA ID 204252 s � 11,7s) o� e_. of 56c'?ps SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson Sheriff k 4�tr of Como rr i Jody S Smith 'i l 3 ET C —2 AH I I • fi'v Chief Deputy Richard W Stewart ` CUMBERLAND COUNTY` Solicitor ,,P-1 E0. -1,ESt<R1FP PENNSYLVANIA Deutsche Bank National Trust Co. vs. Case Number Jimmy D Stoey (et al.) 2013-6137 SHERIFF'S RETURN OF SERVICE 10/22/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Nichole R. Stoey, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Franklin, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 10/22/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Jimmy D Stoey, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Franklin, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 10/24/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Nichole R. Stoey, 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 102 Cleversburg Raod, Southampton Township, Shippensburg, PA 17257. Residence is vacant. 10/24/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Jimmy D Stoey, 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 102 Cleversburg Raod, Southampton Township, Shippensburg, PA 17257. Residence is vacant. 11/12/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Jimmy D Stoey, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Centre, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 11/18/2013 02:45 PM -The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure served by the Sheriff of Centre County upon Jimmy D Stoey, personally, at SCI Benner Township, 301 Institution Drive, Bellefonte, PA 16823. Denny Nau, Sheriff, Return of Service attached to and made part of the within record. 11/21/2013 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure returned by the Sheriff of Franklin County, the within named Defendant Jimmy D Stoey, not found. Dane Anthony, Sheriff, Return of Service attached to and made part of the within record. 11/21/2013 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure served by the Sheriff of Franklin County upon Nichole R. Stoey, personally, at 1908 Powell Drive, Chambersburg, PA 17201. Dane Anthony, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $120.60 SO ANSWERS, November 25, 2013 RONNK ANDERSON, SHERIFF ;ountxSu o!Sheriff,'.e'..e osef. SHERIFF' S RETURN - REGULAR CASE NO: 2013-00330 T COMMONWEALTH OF PENNSYLVANIA: COUNTY OF FRANKLIN DEUTSCHE BANK NATIONAL TRUST VS JIMMY D STOEY ET AL RANDY D STROBLE , Deputy Sheriff of FRANKLIN County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE was served upon STOEY NICHOLE R the DEFENDANT , at 1100 : 00 Hour, on the 31st day of October , 2013 at 1908 POWELL DRIVE APT 1B CHAMBERSBURG, PA 17201 by handing to NICHOLE R STOEY a true and attested copy of NOTICE together with and at the same time directing Her attention to the contents thereof . Sheriff ' s Costs : So Answers : Docketing . 00 Service . 00 RANDY D STROBLE Affidavit . 00 t.-- Surcharge . 00 By V� . 00 Depu S eriff . 00 11/12/201 UDREN LAW OFFICES Sworn and Subscribed to before me this day of COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL A%"� c7/+/ A.D. RICHARD D. McCARTY, Notary Public Chambersburg Boro., Franklin County Ccit-A e I My Commission Expires Jan. 29, 2015 Notar ( / SHERIFF' S RETURN - NOT SERVED CASE NO: 2013-00330 T COMMONWEALTH OF PENNSYLVANIA COUNTY OF FRANKLIN DEUTSCHE BANK NATIONAL TRUST VS JIMMY D STOEY ET AL MATTHEW L COOPER , Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit : STOEY JIMMY D but was unable to locate Him in his bailiwick. He therefore returns the NOTICE NOT SERVED , as to the within named DEFENDANT , STOEY JIMMY D 11335 MOUNTAIN ROAD ORRSTOWN, PA 17244 DEFENDANT IS INCARCERATED SCI BENNER TOWNSHIP ROCKVIEW PA Sheriff ' s Costs : So answ Docketing . 00 Service . 00 69,6L-44— Affidavit . 00 MATTHEW L COOPER Surcharge . 00 . 00 . 00 UDREN LAW OFFICES 11/12/2013 Sworn and subscribed to before me COMMONWEALTH OF PENNSYLVANIA this day o f NOTARIAL SEAL RICHARD D. McCARIY, Notary Public 0?0/ .D� /� Chambersburg Boro., Franklin County G My Commission Expires Jan.29, 2015 Notary SHERIFF'S OFFICE Udren Law Offices P C CENTRE COUNTY Rm 101 Court House, Bellefonte, Pennsylvania, 16823 (814) 355-6803 SHERIFF SERVICE INSTRUCTIONS FOR SERVICE OF PROCESS:You must file one PROCESS RECEIPT, AND AFFIDAVIT OF RETURN Not detacsheet ny copies.ch defendant.please type or print legibly.Do 1 Plaintiff(s) 2.Case Number DEUTSCHE BANK NAT'L TRUST CO. 2013-6137 3.Defendant(s) 4.Type of Writ or Complaint: JIMMY D STOEY ETAL COMPLAINT IN M 513559 SERVE 5.Name of Individual,Company,Corporation, Etc.,to Serve or Description of Property to be Levied,Attached or Sold. - ....+ JIMMY D STOEY#KY6712 AT 6.Address(Street or RFD,Apartment No.,City, Boro,Two., State and Zip Code) 301 INSTITUTION DR, BELLEFONTE,PA 16823 7.Indicate unusual service:E. Reg Mail Certified Mail Deputize 1 Post [- Other Now, 20 . I SHERIFF OF CENTRE COUNTY, PA., do hereby deputize the Sheriff of __. County to execute this Writ and make return thereof according to law.This deputation being made at the request and risk of the plaintiff. . .'" Eu enff of Centre Coup 8.SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE NOTE ONLY APPLICABLE ON WRIT OF EXECUTION:N.B.WAIVER OF WATCHMAN—Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman,in custody of whomever is found in possession,after notifying person of levy or attachment.without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss,destruction or removal of any such property before sheriff's sale thereof. 9.Print/Type Name and Address of Attornev/Originator 10.Telephone Number 11.Date Udren Law Offices P C (856)669-5400 111 WOODCREST ROAD 12.Signature CHERRY HALL N J 08003 SPACE BELOW FOR USE OF SHERIFF ONLY • DO OT_ NRIIE BELOW TrIS LINE 13,1 acknowledge receipt of the writ' SIGNATURE of Authorized CCSt)Deputy of Clerk and Title 14.Date Filed 1 15.ExpirationfHearing Date or cornpiam as indicated above. TO BE COMPETED BY SH RIFF 16.Served and made known to JIMMY STOEY ,on the _-_ 18 November ..__... ._.,_day of --- - ' 2013 2:45 PM 301 INSTITUTION DR, BELLEFONTE, PA 16823 Coun of Centre 20 .._-._...._... ,at o'clock, m.,at __- __ -- Commonwealth of Pennsylvania,in the manner described below: 7 Defendant(s)personally served. DEFENDANT 1 T Adult family member with whom said Defendant(s)resides(s).Relationship is El Adult in charge of Defendant's residence. 17 Manager/Clerk of place of lodging in which Defendant(s)resides(s). • IT Agent or person in charge of Defendant's office or usual place of business. _— and officer of said Defendant company. Other ..-- On the__—_ day of _,20 ,at o'clock, -- M. Defendant not found because: IT Moved r Unknown r No Answer FT Vacant 7 Other Remarks: Advance Costs Docket Service Sur Charge Affidavit Mileage Postage Misc. Total Costs Costs Due or Refund 75.00 9.00 9.00 0.00 2.50 10.00 30.50 (44.50) 17.AFFIRMED and subscribed to before me this /? So Answer. 18.Signat a of D .Sh ri 19.Date 20.day of .. ... ..... ..__20 ._..r- �. • f�/06 v ✓3 i 4fr- ,f / 21.Signat re of S e fW 22.Date 23. A j`� - - �, c Yr,? ,�_ SHERIFF OF CENTRE COUNTY i BRA C dMMEL,P Amount Pd. Page My nimaiiiiiejoreamman 24.I CKNQ1p��l� � FF'I RETURN SIGNATURE 25. Date Received O AUIIMMLL�e LLII ik -hotel`i'ir :iW.i iy of January 2016 , r' y SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ow at Clor4bet, Sheriff Jody S Smith Chief Deputy `, 2013 DEC -3 PH 2: ' I Richard W Stewart .�l�iSt_F�LtE COUNTY Solicitor '� PENNSYLVANIA Deutsche Bank National Trust Co. vs. Case Number Jimmy D Stoey(et al.) 2013-6137 SHERIFF'S RETURN OF SERVICE 10/22/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Nichole R. Stoey, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Franklin, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 10/22/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Jimmy D Stoey, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Franklin, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 10/24/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Nichole R. Stoey, 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 102 Cleversburg Raod, Southampton Township, Shippensburg, PA 17257. Residence is vacant. 10/24/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Jimmy D Stoey, 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 102 Cleversburg Raod, Southampton Township, Shippensburg, PA 17257. Residence is vacant. = The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure returned by the Sheriff of Franklin County, the within named Defendant Jimmy D Stoey, not found. Dane Anthony, Sheriff, Return of Service attached to and made part of the within record. The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure served by the Sheriff of Franklin County upon Nichole R. Stoey, personally, at 1908 Powell Drive, Chambersburg, PA 17201. Dane Anthony, Sheriff, Return of Service attached to and made part of the within record. 11/12/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Jimmy D Stoey, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Centre, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 11/18/2013 02:45 PM -The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure served by the Sheriff of Centre County upon Jimmy D Stoey, personally, at SCI Benner Township, 301 Institution Drive, Bellefonte, PA 16823. Denny Nau, Sheriff, Return of Service attached to and made part of the within record. uf11Y;U ^r `GOfi 111G. • SHERIFF COST: $120.60 SO ANSWERS, 2- November 25, 2013 e R ANDERSON, SHERIFF UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadings @udren.com Deutsche Bank National Trust Company, COURT OF COMMON PLEAS as Trustee for Soundview Home Loan CIVIL DIVISION Trust 2006-NLC1,Asset-Backed Cumberland County Certificates,Series 2006-NLC1 1661 Worthington Road MORTGAGE FORECLOSURE Suite 100 West Palm Beach, FL 33409 , , Plaintiff NO. 13-6137 Civil ,.J 4 JIMMY D. STOEY c..., SCI SCI BENNER TOWNSHIP301 Cc� �-'"w;< INSTITUTION DRIVE INMATE , #KY6712 BELLEFONTE, PA 16823 ` `1 NICHOLE R. STOEY 1908 POWELL DRIVE CHAMBERSBURG, PA 17201 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s),JIMMY D. STOEY; NICHOLE R. STOEY; for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: FROM TO Unpaid Principal Balance $150,996.26 Interest Per Complaint $8,315.77 Additional Interest 06/20/2013 01/28/2014 $2,660.39 Late Charges Per Complaint $181.10 Additional Late Charges 06/20/2013 01/28/2014 $253.54 Escrow Per Complaint $4,372.52 Title Report $300.00 Attorney Fee $1,650.00 Bankruptcy Cost $176.00 Bankruptcy Fee $625.00 Property Maintenance $692.50 Property Inspection Fee $84.00 Property Valuation Fee-BPO $1,168.00 Grand Total $171,475.08 cs14.s(xxi ili cto tst.Ct4-k%i0? . LEES () W)Cx I hereby certify that(1)the addresses of the Plaintiff and Defendant are as shown above,and(2)that notice has been given in accordance with Rule 237.1,a copy of which is attached hereto. UDREN LAW_OFFTCES,P.C. �� �� Attorney for Plain tg_IZABETH L WA ALL, ESQ PAID7 8 DAMAGES ARE HEREB ASSESSED AS INDICATED DATE: 3 I PRO PROW/ "4 MJU#: 12020226 CASE#: 12020226-1 "Ocwen loan servicing,LLC" IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: CHAPTER 7 Nichole R. Stoey, Debtor(s) CASE NO. 1:13-bk-01149-RNO Ocwen Loan Servicing, LLC servicer for Deutsche Bank National Trust Company,as Trustee for Soundview Home Loan Trust 2006 - NLC 1 , Asset - Backed Certificates,Series 2006-NLC1, Movant, vs. Nichole R. Stoey, Debtor(s)/Respondent(s), and John P Neblett, Trustee/Respondent. ORDER GRANTING MOTION FOR RELIEF FROM AUTOMATIC STAY Upon consideration of the Motion of Ocwen Loan Servicing, LLC servicer for Deutsche Bank National Trust Company, as Trustee for Soundview Home Loan Trust 2006-NLC1,Asset- Backed Certificates,Series 2006-NLC1 for Relief from Automatic Stay, it is hereby ORDERED AND DECREED THAT: The 11 U.S.C. §362 Automatic Stay is hereby modified with respect to premises: 102 Cleversburg Road Shippensburg,PA 17257 as to allow the Movant to foreclose on its mortgage and allow the purchaser of said premises at Sheriffs Sale (or purchaser's assignee) to take any legal action for enforcement of its right to possession of said premises; and it is further Case 1:13-bk-01149-RNO Doc 20 Filed 05/03/13 Entered 05/03/13 14:42:39 Desc Main Document Page 1 of 2 ORDERED THAT: The relief granted by this order shall survive the conversion of this bankruptcy case to a case under any other Chapter of the Bankruptcy Code. By the Court, Dated: May 3, 2013 Opel,II,Bankruptcy Judge' Case 1:13-bk-01149-RNO Doc 20 Filed 05/03/13 Entered 05/03/13 14:42:39 Desc Main Document Page 2 of 2 • UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF • BY:MARK J.UDREN,ESQUIRE-W4184302 STUART WINNEG,ESQUIRE-ID#45362 r�. LORRAINE GAZZARA DOYLE,ESQUIRE-ID#34576 SHERRI J.BRAUNSTEIN,ESQUIRE-ID#90675 G r SALVATORE CAROLLO,ESQUIRE-ID#311050 .0-65 rtA HARRY B.REESE,ESQUIRE-ID#310501 CS)ELIZABETH L.WASSAIL,ESQUIRE-ID#77788 Z f N JOHN ERIC KISHBAUGH,ESQUIRE-ID#33078 - p' NICOLE B.LABLETTA,ESQUIRE-ID#202194 y,c� °f�• DAVID NEEREN,ESQUIRE-ID#204252 v, JORDAN DAVID,ESQUIRE-ID#311968 �'�+ c.? r: AMANDA RAUER,ESQUIRE-ID#307028 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 plcadinas@udren.con4 Deutsche Bank National Trust Company, COURT OF COMMON PLEAS as Trustee for Soundview Home Loan CIVIL DIVISION Trust 2006-NLC1,Asset-Backed CUMBERLAND County Certificates,Series 2006-NLC1 C/O Ocwen Loan Servicing,LLC 1661 Worthington Road NO. Suite 100 West Palm Beach,FL 33409 PIaintiff v. JIMMY D.STOEY 11335 MOUNTAIN ROAD ORRSTOWN,PA 17244-9649 NICHOLE R.STOEY 11335 MOUNTAIN ROAD ORRSTOWN,PA 17244 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty(20) days after this Complaint and Notice are served,by entering a written appearance personally or by attorney and filing in writing with SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff xr of esraet,,,4 Jody S Smith 0. Chief Deputy Richard W Stewart "0'4 ° - Solicitor OFFICE OF THE SFiERIFF Deutsche Bank National Trust Co. Case Number vs. Jimmy D Stoey(et al.) 2013-6137 SHERIFF'S RETURN OF SERVICE 10/22/2013 Sheriff Ronny R Anderson, being duly sworn according to law,states he made diligent search and inquiry for the within named Defendant to wit Nichols R. Stoey,but was unable to locate the Defendant in the Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of Franklin,Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 10/22/2013 Sheriff Ronny R Anderson,being duly sworn according to law,states he made diligent search and inquiry for the within named Defendant to wit:Jimmy D Stoey,but was unable to locate the Defendant in the Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of Franklin, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 10/24/2013 Ronny R Anderson,Sheriff,being duly sworn according to law,states he made diligent search and inquiry for the within named Defendant to-wit Nichole R. Stoey, 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 102 Cleversburg Raod, Southampton Township,Shippensburg, PA 17257. Residence is vacant. 10/24/2013 Ronny R Anderson, Sheriff, being duly sworn according to law,states he made diligent search and inquiry for the within named Defendant to wit:Jimmy D Stoey, 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 102 Cleversburg Raod, Southampton Township,Shippensburg, PA 17257. Residence is vacant. 11/12/2013 Sheriff Ronny R Anderson, being duly sworn according to law,states he made diligent search and inquiry for the within named Defendant to wit:Jimmy D Stoey,but was unable to locate the Defendant in the Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of Centre, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 11/18/2013 02:45 PM-The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure served by the Sheriff of Centre County upon Jimmy D Stoey,personally,at SCI Benner Township, 301 Institution Drive,Bellefonte,PA 16823. Denny Nau,Sheriff, Return of Service attached to and made part of the within record. 11/21/2013 The requested Notice of Residential Mortgage.Foreclosure Diversion Program and Complaint in Mortgage Foreclosure returned by the Sheriff of Franklin County,.the within named Defendant Jimmy D Stoey,not found. Dane Anthony,Sheriff,Return of Service attached to and made part of the within record. 11/21/2013 The requested Notice of Residential Mortgage,Foredosure Diversion Program and Complaint in Mortgage Foreclosure served by the Sheriff of Franklin County upon Nichole R.Stacy, personally,at 1908 Powell Drive,Chambersburg, PA 17201. Dane Anthony,Sheriff, Return of.Service attached to and made part of the within record. (cl CountySulte Sheriff,Teloosolt,Inc. SHERIFF COST: $120.60 SO ANSWERS, ‘...!'s:(02.a.---------- November 25,2013 RONR ANDERSON, SHERIFF tr.)CountySulte Shoe.TWeosof,Inc. SHERIFF'S RETURN - REGULAR CASE NO: 2013-00330 T COMMONWEALTH OF PENNSYLVANIA: COUNTY OF FRANKLIN DEUTSCHE BANK NATIONAL TRUST VS JIMMY D STOEY ET AL RANDY D STROBLE , Deputy Sheriff of FRANKLIN County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE was served upon STOEY NICHOLE R the DEFENDANT , at 1100:00 Hour, on the 31st day of October , 2013 at 1908 POWELL DRIVE APT 1B CHAMBERSBURG, PA 17201 by handing to NICHOLE R STOEY a true and attested copy of NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing . 00 Service . 00 RANDY D STROBLE Affidavit .00 Surcharge . 00 By . 00 Depu S eriff . 00 11/12/201 UDREN LAW OFFICES Sworn and Subscribed to before me this day of COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL 02,/ A A.D D. RICHARD D.McCARTY, Notary Public Chambersburg Boro., Franklin County Caiot My Commission E Aires Jan.29, 2015 Nota / SHERIFF'S RETURN - NOT SERVED CASE NO: 2013-00330 T COMMONWEALTH OF PENNSYLVANIA COUNTY OF FRANKLIN DEUTSCHE BANK NATIONAL TRUST VS JIMMY D STOEY ET AL MATTHEW L COOPER , Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: STOEY JIMMY D but was unable to locate Him in his bailiwick. He therefore returns the NOTICE NOT SERVED , as to the within named DEFENDANT , STOEY JIMMY D 11335 MOUNTAIN ROAD ORRSTOWN, PA 17244 DEFENDANT IS INCARCERATED SCI BENNER TOWNSHIP ROCKVIEW PA Sheriff's Costs: So ans Docketing . 00 Service . 00 Ce Affidavit .00 MATTHEW L COOPER Surcharge .00 . 00 . 00 UDREN LAW OFFICES 11/12/2013 Sworn and subscribed to before me this /Q day of )1ii ,COMMONWEALTHOFPENNSYLVANIA, N 'ARIAL SEAL o Q 1 RICHARD D.McCARTY,Notary Public • = Chambersburg Som., Franklin County i My Commission Expires Jan.29,2015 Notary SHERIFF'S OFFICE Udren Law Offices P C CENTRE COUNTY Rm 101 Court House, Bellefonte, Pennsylvania, 16823 (814)355-6803 SHERIFF SERVICE INSTRUCTIONS FOR SERVICE OF PROC SS:Ybu must file one Instruction sheet for each defendant.please type or print legibly.Do PROCESS RECEIPT AND AFFIDAVIT OF RETURN Not detach any copies. 1.Plaintiff(s) 2.Case Number DEUTSCHE BANK NAIL TRUST CO. 2013-6137 3.Defendant(s) 4.iype of Writ or Complaint: • JIMMY D STOEY ETAL COMPLAINT IN M 513559 SERVE 5.Name of Individual.Company.Corporation.Etc..to Serve or Description of Property to be Levied,Attached or Sold. JiMMY D STOEY#KY6712 AT 6.Address(Street or RFD,Apartment No.,City.Boro.lwp.,State and Zip Code) 301 INSTITUTION DR,BELLEFONTE,PA 16823 7.Indicate unusual service:❑ Reg Mall ❑" Certi ied Mall ❑-: Deputize ❑':: Post ❑' Other Now, 20 . I SHERIFF OF CENTRE COUNTY, PA., do hereby deputize the Sheriff of County to execute this Writ and make return thereof according to law.This deputation being made at the request and risk of the plaintiff. shame cents c nu - B.SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE NOTE ONLY APPLICABLE ON WRIT OF EXECUTION;N.B.WAIVER OF WATCHMAN-My deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman,in custody of whomever Is found in possession,atter notifying person of levy or attachment without lability on the part of such deputy or the sheriff to any plaintiff herein for any loss,destruction or removal of any such property before sherfff's sale thereof. 9. n ype ame and rasa o orneV otnator 10.Telephone Number 11.]sate Udren Law Offices P C (856)669-5400 111 WOODCREST ROAD 12.Signature CHERRY HALL N J 08003 13.I.snow effir t I . SIGNATURE of Authorized COSO Deputy of Clerk and Title 14.Data tied 15.Expiration/Hearing Date i = a7e • i - 16.Served and made known to JIMMY STOEY on the 18 day of November 20 2013 ,at 2:45 PM o'clock, m..at 301 INSTITUTION DR,BELLEFONTE,PA 18823 ,County of Centre Commonwealth of Pennsylvania,in the manner described below: 0 Defendant(s)personally served. DEFENDANT Adult family member with whom said Defendant(s)resides(s).Relationship is ❑ Adult in charge of Defendan(e residence. ❑ Manager/CIerk of place of lodging in which Defendant(s)resides(s). Cl Agent or person In charge of Delertdant's office or usual place of business. and officer of said Defendant company. Other On the . day of 20 ,at o'clock, _ _ - M. Defendant not found because: 171' Moved ❑ Unknown Cl No Answer ❑ Vacant ❑ Other Remarks: Advance Costs Docket Service Sur Charge Affidavit Mileage Postage Misc. Total Costs Costs Due or Refund 75.00 9.00 , 9.00 0.00 2.50 10.00 30.50 (44.50) 17.AFFIRMED and subscribed to before me this 19 So Answer. 18.Signs of .Sh 1g.Date) 20.day of �./' za .2_ /i6 v/3 , � Sign re of S ff 22.Date 23. '�/MA�.",i4'.C:QatLL� SHERIFF OP CENTRE COUNTY pt .& Amount Pd. Page My C51fn 24.1 aC Y. ;. -. r , ; FF1 RETURN SIGNATURE 25.Date Received OI __•.RO iltbs_tilkxatC of January 2016 ..,.. .. ...• UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Company,as ' COURT OF COMMON PLEAS Trustee for Soundview Home Loan Trust CIVIL DIVISION 2006-NLC1,Asset Backed Certiflcates,Series Cumberland County 2006-NLC1 Plaintiff MORTGAGE FORECLOSURE v. Jimmy D.Stoey,Nichole R.Stoey NO. 13-6137 Civil Defendant(s) TO: Nichole R.Stoey 1908 Powell Drive Chambersburg,PA 17201 Date of Notice: January 17,2014 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ(10)DIAS DE ESTA NOTIFICACION,EL TRIBUNAL PODRA,SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA,USTED PUEDE PERDER BIENES Y OTROS DERECHOS,IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO,0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO,VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT,THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT.ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. UDREN LAW'OFFICES,PC. BY: ~~' Attorney for Plaintiff SALVATORE CAROLLO,ESQUIRE PA ID 311050 Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill,New Jersey 08003-3620 MJU#: 12020226 CASE#: 12020226-1 "Ocwen loan servicing,LLC" UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Company, as COURT OF COMMON PLEAS Trustee for Soundview Home Loan Trust CIVIL DIVISION 2006-NLC1,Asset Backed Certificates,Series Cumberland County 2006-NLC1 Plaintiff MORTGAGE FORECLOSURE v. Jimmy D.Stoey,Nichole R. Stoey NO. 13-6137 Civil Defendant(s) TO: Jimmy D.Stoey SCI Benner Township 301 Institution Drive Inmate#KY6712 Bellefonte,PA 16823 Date of Notice: January 17,2014 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ(10)DIAS DE ESTA NOTIFICACION,EL TRIBUNAL PODRA,SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, ,DICTAR SENTENCIA EN SU CONTRA,USTED PUEDE PERDER BIENES Y OTROS DERECHOS,IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO,0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO,VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA,CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 NOTICE:PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT,THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT.ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. UDREN OFFICES,PC. BY: Attorney for Plaintiff SALVATORE CAROLLO, ESQUIRE PA ID 311050 Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill,New Jersey 08003-3620 MJU#: 12020226 CASE#: 12020226-1 "Ocwen loan servicing,LLC" UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 I leadin s ' udren.com COURT OF COMMON PLEAS Deutsche Bank National Trust Company,as CIVIL DIVISION Trustee for Soundview Home Loan Trust 2006- Cumberland County NLC1,Asset-Backed Certificates,Series 2006- NLC1 MORTGAGE FORECLOSURE Plaintiff v. NO. 13-6137 Civil JIMMY D. STOEY,NICHOLE R. STOEY, Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE UNDER Pa.R.C.P 76 THE UNDERSIGNED states based upon a search of the Department of Defense Manpower Data Center for the Defendant(s),that the Defendant(s),JIMMY D. STOEY,NICHOLE R. STOEY, who/each of whom is over 18 years of age is/are not in active military service as defined in the Servicemembers' Civil Relief Act. The Military Status Report(s)is/are attached hereto as Exhibit "A". The Affiant lacks sufficient information to be able to determine whether any other Defendants in this action are in active military service because Plaintiff cannot provide date(s)of birth and/or Social Security number(s) for said Defendant(s)to enable a search. This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Dated: January 27,2014 At orney for Plaintiff ELIZABETH L WASSALL, ESQ PA ID 77788 MJU#: 12020226 CASE#: 12020226-1 "Ocwen loan servicing,LLC" Department of Defense Manpower Data Center Results as of:Jan-27-2014 12:44:14 PM SCRA 3.0 Report 410 Status Pursuant to Service Civil Relief Act Last Name: STOEY First Name: JIMMY Middle Name: D Active Duty Status As Of: Jan-27-2014 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. 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: 07ZCV670K061OE0 Department of Defense Manpower Data Center Results as of:Jan-27-2014 12:45:20 PM SCRA 3.0 4110 Status Report Purguaat to Servicemembers Civil Relief Act Last Name: STOEY First Name: NICHOLE Middle Name: R Active Duty Status As Of: Jan-27-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status - Service Component NA NA. ; NA This response reflects the individuals'active duty status based on the Actihe'Ddly etatus 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. *Mt • 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/PCO9SLDR.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: 67W7K6201063220 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 .leadin s • udren.com Deutsche Bank National Trust Company, COURT OF COMMON PLEAS as Trustee for Soundview Home Loan CIVIL DIVISION Trust 2006-NLC1,Asset-Backed Cumberland County Certificates,Series 2006-NLC1 Plaintiff MORTGAGE FORECLOSURE v. Jimmy D. Stoey NO. 13-6137 Civil Nichole R. Stoey , Defendant(s) m r- E__ Cn PRAECIPE TO ISSUE WRIT OF EXECUTION �-- ..Y TO THE PROTHONOTARY: _' ± c Issue Writ of Execution in the above matter: Amount due $ 171,475.08 Interest From 1/29/2014 $ 1,515.11 to Date of Sale 6/4/2014 Ongoing Per Diem of$11.93 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN LAW OFFICES, P.C. nnII c�- wvk- - 1 DD. o1) C O E Attorney for L Plaintiff ,, ELIZABETH L WASSAIL, ESQ t, PA ID 77788 )O3. ; S 11 g6 (I MJU#: 12020226 CASE#: 12020226-1 "0 en loan servicing,LLC" g Q s,1. 10 Pd a as�> 0. Ciu'& i' s7) 3olla a, / UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 leadin s ' udren.com Deutsche Bank National Trust Company, COURT OF COMMON PLEAS as Trustee for Soundview Home Loan CIVIL DIVISION Trust 2006-NLC1,Asset-Backed Cumberland County Certificates,Series 2006-NLC1 Plaintiff MORTGAGE FORECLOSURE v. Jimmy D. Stoey NO. 13-6137 Civil ►-' _ Nichole R. Stoey Defendant(s) < , cp CERTIFICATE OF ACT 91 ' " I hereby state that as the attorney for the Plaintiff in the above-captioned matter: El Act 91 procedures have been fulfilled fl Premises is not subject to the provisions of Act 91 as this is an FHA insured mortgage This statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. BY: Attorney for Plaintiff ELIZABETH L WASSALL, ESQ PA ID 77788 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 leadin•s ' udren.com Deutsche Bank National Trust Company, COURT OF COMMON PLEAS as Trustee for Soundview Home Loan CIVIL DIVISION Trust 2006-NLC1,Asset-Backed Cumberland County Certificates, Series 2006-NLC1 Plaintiff MORTGAGE FORECLOSURE v. Jimmy D. Stoey NO. 13-6137 Civil Nichole R. Stoey Defendant(s) rn AFFIDAVIT OF LAST KNOWN ADDRESS teror3.. UNDER RULE 76 "'� c_ mac} The Defendant(s)last known address is as follows: JIMMY D. STOEY SCI BENNER TOWNSHIP -< ' 301 INSTITUTION DRIVE INMATE#KY6712 BELLEFONTE,PA 16823 NICHOLE R. STOEY 1908 POWELL DRIVE CHAMBERSBURG,PA 17201 This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. Attorney for Plaintiff ELIZABETH L WASSALL, ESQ PA ID 77788 UDT EN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 leadin•s ' udren.com Deutsche Bank National Trust Company, COURT OF COMMON PLEAS as Trustee for Soundview Home Loan CIVIL DIVISION ,T;w c„_ Trust 2006-NLC1,Asset-Backed Cumberland County Certificates,Series 2006-NLC1 cn ca Plaintiff MORTGAGE FORECLOSURE o - Jimmy D. Stoey NO. 13-6137 Civil -E Nichole R. Stoey - Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 Deutsche Bank National Trust Company, as Trustee for Soundview Home Loan Trust 2006-NLC1,Asset- Backed Certificates,Series 2006-NLC1,Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 102 Cleversburg Road, Shippensburg, PA 17257 1. Name and address of Owner(s) or reputed Owner(s): Jimmy D. Stoey SCI Benner Township 301 Institution Drive Inmate#KY6712 Bellefonte, PA 16823 Nichole R. Stoey 1908 Powell Drive Chambersburg, PA 17201 2. Name and address of Defendant(s) in the judgment: Jimmy D. Stoey SCI Benner Township 301 Institution Drive Inmate#KY6712 Bellefonte, PA 16823 Nichole R. Stoey 1908 Powell Drive Chambersburg, PA 17201 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Jr Lien Holders -None 4. Name and address of the last recorded holder of every mortgage of record: Deutsche Bank National Trust Company, as Trustee for Soundview Home Loan Trust 2006-NLC1,Asset- Backed Certificates,Series 2006-NLC1 1661 Worthington Road Suite 100 West Palm Beach, FL 33409 Sr Mortgage Holders - None CitiFinancial,Inc 208 S Conestoga Drive Shippensburg,PA 17257 5. Name and address of every other person who has any record lien on the property: Sr lien Holders -None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Tenants/Occupants 102 Cleversburg Road Shippensburg, PA 17257 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Federal Tax Lien Holders-None Condo/Homeowners Association- None I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: UDREN LAW-oFEICES, P.C. BY: Attorney for P1aiitfABETH L WASSALL, ESQ PA ID 77788 MJU#: 12020226 CASE#: 12020226-1 "Ocwen loan servicing,LLC" UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 leadin•s ' udren.com Deutsche Bank National Trust Company, COURT OF COMMON PLEAS as Trustee for Soundview Home Loan CIVIL DIVISION Trust 2006-NLC1,Asset-Backed Cumberland County Certificates,Series 2006-NLC1 Plaintiff MORTGAGE FORECLOSURE v. JIMMY D. STOEY,NICHOLE R. STOEY NO. 13-6137 Civil r , Defendant(s) f- mu, C-- - ... ` NOTICE OF SHERIFF'S SALE OF REAL PROPERTY ;T, cn� w w .� — . TO: Jimmy D. Stoey SCI Benner Township R..' 301 Institution Drive , Inmate#KY6712 Bellefonte, PA 16823 Your house (real estate) at 102 Cleversburg Road, Shippensburg, PA 17257 is scheduled to be sold at the Sheriffs Sale on June 4, 2014 at 10:00 A.M. at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of$171,475.08, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale,you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment,late charges,costs and reasonable attorney's fees. To find out how much you must pay,you may call: (856)669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened,you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale.This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after Schedule of Distribution is filed. 7. You may also have other rights and defenses,or ways of getting your home back,if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 e leadin•s ' udren.com Deutsche Bank National Trust Company, COURT OF COMMON PLEAS as Trustee for Soundview Home Loan CIVIL DIVISION Trust 2006-NLC1,Asset-Backed Cumberland County Certificates,Series 2006-NLC1 Plaintiff MORTGAGE FORECLOSURE ' ' v. - rn LD _ _ .. JIMMY D. STOEY,NICHOLE R. STOEY NO. 13-6137 Civil co ca r= Defendant(s) —c �"' --+C. xpro NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Nichole R. Stoey crl 1908 Powell Drive Chambersburg, PA 17201 Your house (real estate) at 102 Cleversburg Road, Shippensburg, PA 17257 is scheduled to be sold at the Sheriffs Sale on June 4,2014 at 10:00 A.M. at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of$171,475.08, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale,you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment,late charges,costs and reasonable attorney's fees. To find out how much you must pay,you may call: (856)669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened,you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale.This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after Schedule of Distribution is filed. 7. You may also have other rights and defenses,or ways of getting your home back,if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-6137 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 SOUNDVIEW HOME LOAN TRUST 2005-NLC1,ASSET-BACKED CERTIFICATES,SERIES 2006-NLC1 Plaintiff(s) From JIMMY D. STOEY,NICHOLE R.STOEY (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: $171,475.08 L.L.: $.50 Interest 1/29/2014 TO DATE OF SALE 6/4/2014 ONGOING PER DIEM OF$11.93 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE-$1,515.11 Atty's Comm: Due Prothy: $2.25 Atty Paid: $281.10 Other Costs: Plaintiff Paid: Date: 1/31/2014 David D.Bu-11,Prothonotary (Seal) - 21; - Deputy REQUESTING PARTY: Name: ELIZABETH L. WASSALL,ESQUIRE Address: UDREN LAW OFFICES,P.C. 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003 Attorney for: PLAINTIFF Telephone: 859-669-5400 Supreme Court ID No. 77788 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsAudren.com Deutsche Bank National Trust Company, as Trustee for Soundview Home Loan Trust 2006- NLC1, Asset -Backed Certificates, Series 2006- NLC1 Plaintiff v. .TIMMY D. STOEY, NICHOLE R. STOEY, Defendant(s) ATTORNEY FOR PLAINTIFF c`) 3 COURT OF COMMON PLEAS`}) CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE •�7 A NO. 13-6137 Civil AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: 1. A copy of the Notice of Sheriffs Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriffs Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. Dated: 31 ?-1/ MJU#: 12020226 CASE#: 12020226-1 LAW OFFIC BY: Attorne o ' aintiff David Neeren, Esquire PAID 204252 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 eutsche Bank National Trust ompany, as Trustee for Soundview Home Loan Trust 2006-NLC1, Asset -Backed Certificates, Series 2006-NLC1 Plaintiff v. JIMMY D. STOEY; NICHOLE R. STOEY; Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-6137 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S): JIMMY D. STOEY; NICHOLE R. STOEY; PROPERTY: 102 Cleversburg Road, Shippensburg, PA 17257 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on 06/04/2014 at 10:00 AM, at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013. Our records indicate that you may hold a mortgage or judgment on the property, which will be extinguished by the sale. You may wish to attend the sale to protect your interests. The Sheriff will file a Schedule of Distribution on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. MJU#: 12020226 CASE#: 12020226-1 Eff'n,r,), Name and Address of Sender Henrietta Crommarty UDREN LAW OFFICES P.C. , 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 ❑ Registered ❑ Insured ❑ COD ❑ Certified Return Receipt for p Merchandise ❑ Int' l Recorded Del. ❑ Express Mail Check appropriate block for Registered Mail: ❑ With Postal Insurance Withoutpostal Insurance Affix stampats here if issued as certificate of mailing or for additional copies of this bill. Postmark and Date of Receipt Line Article Number Name of Addressee, Street, and Post Office Address Postage Fee Handling Charge Act. Value (If Regis.) Insured Value Due Sender If COD R.R. Fee S.D. Fee S.H. Fee Rst. Del. Fee Remarks 1 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 2 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 3 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 4 13-6137 Tenants/Occupants 102 Cleversburg Road Shippensburg, PA 17257 g.r e+ U.S. POSTAGE »»PITNE}•BOWE; - • cf. .0.--rae,„...1..,mar •F1 . • ZIP 08003 Q Ors! ,, 4 L 02 18 $ 004.01 0001387090 APR. 14. 2014. 5 CitiFinancial, Inc 208 S Conestoga Drive Shippensburg, PA 17257 " Is N '7��y wry oog0 �10p 6 06/04/2014 4 w U J s® 8 t70oM te=1.- 04 9 UNI 10 11 12 13 14 15 Total number of Pieces Listed by Sender 5 Total Number of Pieces Receiv at P t Office/ Postmaster, Per (Name of Receiving Employee) The full declaration of value is required on all domestic and intemational registered mail. The maximum indemnity payable for the reconstruction of nonnego table documents under Express Mail document reconstruction insurance is $50,000 per p ece subject to a limit of $500,000 per occurrence. The maximum indemnity payable on Express Mail merchandise is $500. The maximum indemnity payable is $25,000 for registered mail, sent with optional postal insurance. See Domestic Mail Manual R900, 5913, and 5921 for limitations of coverage on insured and COD mail. See International Mail Manual for limitations of coverage on international mail. Special handling charges apply only to third and forth class parcels. rillir PS Form 3877, February 1994 Form Must be Completed by Typewriter, Ink or Ball Point Pen Jimmy D. Stoey - MJU# 12020226-1 (Cumberland County) Nichole R. Stoey - MJU# 12020226-1 (Cumberland County) UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Company, as Trustee for Soundview Home Loan Trust 2006-NLC1, Asset -Backed Certificates, Series 2006-NLC1 Plaintiff v. JIMMY D. STOEY; NICHOLE R. STOEY; et al ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 13-6137 Civil Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: c( David Neeren, Esquire PAID 204252 �tt�a�oti D Deutsche Bank Nation11 Trust Company. as Trustee, et. al., Plaintiffs) A. Jimmy D. Stoey, et. al., Defendant(s) UDREN LAW OFFICES Ms. Henni Crommarty 111 Woodcrest Rd., Ste. 200 Cherry Hill, NJ 08003-3620 Service of Process by APS International, Ltd. o "I 1-800-328-7171 APS INTERNATtoN41. APS International Plaza 7800 Glenroy Rd. Minneapolis. MN 55439-3122 APS File #: 128695-0002 AFFIDAVIT OF SERVICE -- Individual 1 Service of Process on: --Nichole R. Stoey Court Case No. Cumberland Co 13 -6137 -Civil State of: C'Wm Sy \i9,16.; a. ,ss. — — — — — — — — — — — — County of t"Y2v1 )CA ) r �� Name of Server: ewe--(--, �WC1, v" , undersigned. being duly sworn, deposes and says that at the time of ser ice,Ohe as o legal age and was not a party to this action: that on the Ji day of v' . 20 J . at //, 'clock kM Date/Time of Service: Place of Service: Documents Served: at 1908 Powell Drive the undersigned served the documents described as: Notice of Sheriffs Sale of Real Property In Chambersbrg, PA 17201 Service of Process on: A true and correct copy of the aforesaid document(s) was served on: Nichole R. Stoey Person Served, and Method of Service: By personally delivering them into the hands of the person to be served. By delivering them into the hands of . a person of suitable age. who verified, or who upon questioning stated, that he/she resides with Nichole R. Stoey at the place of service, and whose relationship to the person is: Description of Person The person receiving doc/uI�e is described as folio 1 Receiving Documents: Sex F,: Skin Color (/vt� V : Hair Color ' C` Aprox. Age 3,5 : Approx. Height ,� Signature of Server: 000 f ; Facial Hair ! L5 : Approx. Weight /TOI To the best of my knowledge and belief. said person was not engaged in the US Military at the time of service. Undersi • . d-clares under penal that lig is true an Signature of Server APS International, Ltd. Subscribed and sworn to before me this /6--,4 day of Notary Public , 20 / L //- 30 -is- ommission Expires) NOTARIAL SEAL LUCILLE H CARTY Notary Public LETTERKENNY TWP., FRANKLIN COUNTY My Commission Expires Nov 30, 2015 SHERIFF'S OFFICE CENTRE COUNTY CIVIL ACTION GROUP LTD/ A Rm 101 Court House, Bellefonte, Pennsylvania, 16823 (814) 355-6803 SHERIFF SERVICE PROCESS RECEIPT, AND AFFIDAVIT OF RETURN INSTRUCTIONS FOR SERVICE OF PROCESS:You must file one instruction sheet for each defendant. please type or print legibly. Do Not detach any copies. 1. Plaintiff(s) DEUTSCHE BANK NAT'L TRUST CO 2. Case Number 13 -6137 -CIVIL 3. Defendant(s) JIMMY D STOEY, NICHOLE R STOEY SERVE: JIMMY D STOEY KY6 4. Type of Writ or Complaint: OUT OF STATE N 514273 SERVE AT 5. Name of Individual. Comoany. Corporation. Etc., to Serve or Description o1 Properly to be Levied. Attached or Sold. JIMMY D STOEY KY6712 6. Address (Street or RFD. Apartment No., City, Boro, Twp., State and Zip Code) SCI BENNER 301 INSTITUTION DR, BELLEFONTE, PA 16823 7. Indicate unusual service: E Reg Mail 7 Certified Mail n Deputize IT- Post C Other Now. 20 . I SHERIFF OF CENTRE COUNTY. PA., do hereby deputize the Sheriff of County to execute this Writ and make return thereof according to law. This deputation being made at the request and risk of the plaintiff. Sheriff of Cane County 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B.WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman. in custody of whomever is found in possession. after notifying pe son of levy or attachment. without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction or removal of any such property before sheriff's sate thereof. 9. Print/Tyoe Name and Address of Attorney/Oriainator CIVIL ACTION GROUP LTD/ APS NAT'L DEVISION 7800 GLENROY RD MINNEAPOLIS, MN 55439-3122 10.Telephone Number 11. Date 12. Signature SPACE BELOW FOR USE OF SHERIFF ONLY - DO QJ WB[IE BELOW TJIIS LINL 13. i ad novel� a rete ppt of m writ 1 SIGNATURE o1 Authorized CCSO Deputy of Clerk and Tdle 14. Date Filed or comprainfas'ndicawn abova. 1 l 15. Expiration/Hearing Date TO BE COMPLETED BY SH RIFF 16. Served and made known to JIMMY STOEY , on the 23 day of April 20 2014 at 10:35 AM o'clock, m., at SCI BENNER 301 INSTITUTION DR, BELLEFONTE, PA 16823 County of Centre Comoro ealth of Pennsylvania, in the manner described below: Delendant(s) personally served. DEFENDANT Adult family member with whom said Defendant(s) resides(s). Relationship is Adult in charge of Defendant's residence. E Manager/Clerk of place of lodging in which Defendant(s) resides(s). C Agent or person in charge of Defendant's office or usual place of business. and officer of said Defendant company. Other On the day of . 20 , at o'clock. M. Defendant not found because: 1- Moved E Unknown IT No Answer 7 Vacant 7 Other Remarks: Advance Costs 75.00 Docket 9.00 Service 9.00 Sur Charce 10.00 Affidavit 2.50 Mileage 10.00 Postage Misc. Total Costs 40.50 Costs Due or Refund (34.50) 17. AFFIRMED and subscribed to before me this.23 So Answer. 20. day of ��'�., , 2Ge/ :. Sigre of Dep. Sh 19. Dale � / y 21. Signature of (riff 22. Date Division of Common Pisa SHERIFF OF CENTRE COUNTY My Commission rt of Cent County, PA Ex Iran T'h" Amount Pd. Page 24.E AKUNOWL E "Q "YF{� EIFF t ,�N= GNATURE 25. Date Received Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY oFFicE Deutsche Bank National Trust Co. vs. Jimmy D Stoey (et al.) Case Number 2013-61{37 • SHERIFF'S RETURN OF SERVICE 03/28/2014 12:28 PM - 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 102 Cleversburg Road, Southampton - Township, Shippensburg, PA 17257, Cumberland County. SHERIFF COST: $964.24 S0 ANSWER'S, ti April 16, 2014 RONNY R ANDERSON, SHERIFF r (c) CountySuite Sheriff, Teleosoft, Inc. UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust Company, as Trustee for Soundview Home Loan Trust 2006-NLC1,Asset-Backed Certificates,Series 2006-NLC1 Plaintiff v. JIMMY D. STOEY NICHOLE R. STOEY Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County c=. MORTGAGE FORECLOSURE' �o `= NO. 13-6137 Civil NOTICE OF THE DATE OF CONTINUED SHERIFF'S SALE The Sheriffs Sale scheduled for June 4, 2014 at 10:00 AM in the above -captioned matter has been continued until July 2, 2014 at 10:00 AM. Date: co 1411(4 MJU#: 12020226 CASE#: 12020226-1 BY: Attorney or Plaintiff AMANDA L. RATER, ESQUIRE IIS, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 (856) 669-5400 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust Company, as Trustee for Soundview Home Loan Trust 2006-NLC1,Asset-Backed Certificates,Series 2006-NLC1 Plaintiff v. JIMMY D. STOEY NICHOLE R. STOEY Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-6137 Civil NOTICE OF THE DATE OF CONTINUED SHERIFF'S SALE The Sheriffs Sale scheduled for July 2, 2014 at 10:00 AM in the above -captioned matter has been continued until September 3, 2014 at 10:00 A.M.. Date: MJU#: 12020226 CASE#: 12020226-1 BY: I Attorney for Plaintiff UDREN LAW OFFICES, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 (856) 669-5400 SAI, YF:'Mi ij =REM LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadingortudren.com Deutsche Bank National Trust COURT OF COMMON PLEASc, Company, as Trustee for Soundview CIVIL DIVISION Home Loan Trust 2006-NLC1, Asset- CUMBERLAND County r-r-ic% u) Backed Certificates, Series 2006- NLC1 r- rN) NO. 13-6137 CIVIL Plaintiff V. Jimmy D. Stoey , Nichole R. Stoey Defendant (s) PETITION FOR POSTPONEMENT OF SHERIFF'S SALE Plaintiff, by its counsel, petitions the Court for a 2 (two) month postponement of the Sheriff ' s sale scheduled in the above captioned matter and in support thereof avers the following: 1. A Sheriff ' s sale of the mortgaged property involved herein, located at 102 Cleversburg Road, Shippensburg, PA 17257, was originally scheduled for June 4, 2014, then postponed to July 2, 2014, to allow Plaintiff to review the pending Home Affordable Modification (HAMP) application, then postponed to September 3, 2014 . 2. The Plaintiff seeks the postponement of the Sheriff ' s sale 2 (two) month(s) to review the pending (HAMP) application. 3 . Pursuant to local rule the defendant (s) is unrepresented by counsel and plaintiff has no manner in which to seek concurrence except by mail. 4 . No Judge has been assigned to this matter. WHEREFORE, Plaintiff respectfully prays and requests that the Sheriff's sale of the mortgaged property be postponed to the November 5, 2014 Sheriff' s sale. Respectfully submitted, UDREN LAW OTFICES, P.C. BY: V\ I —OL 4Plit5C Nath- , C. olf, Esquire Attorney for Plaintiff Loc-' nsel " „ 4 WREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadingo udren.com Deutsche Bank National Trust COURT OF COMMON PLEAS Company, as Trustee for Soundview CIVIL DIVISION Home Loan Trust 2006-NLC1, Asset- DELAWARE County Backed Certificates, Series 2006- NLC1 NO. 13-6137 CIVIL Plaintiff v. Jimmy D. Stoey Nichole R. Stoey Defendant (s) PLAINTIFF'S MEMORANDUM OF LAW Pennsylvania R.C.P. 3129.3 (b) allows for the postponement of a Sheriff's sale. In the present matter, the sale has been previously postponed. Plaintiff now seeks an additional postponement in order to review the (HAMP) application. Therefore, in order for the Plaintiff to be able to properly conduct itself at the Sheriff's sale, a postponement of the sale is necessary. Pa.R.C.P. 3129.3 (a) allows the postponement of the sale more than once, and without new notice, by Special Order of Court. Accordingly, for the reasons hereinabove stated, and as more particularly set forth in the Motion, Plaintiff respectfully requests continuance of the Sheriff 's Sale of the mortgaged premises, located at 102 Cleversburg Road, Shippensburg, PA 17257, to the November 5, 2014, Sheriff's sale as set forth in the Motion. Respectfully submitted, UDREN LAW OFFICES, P.C. BY: 4-110t16 Nath.s. . Wolf, Esquire Attorney ; ar Pjaintif€ ,. Local Counsel UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadings@udren.com Deutsche Bank National Trust COURT OF COMMON PLEAS Company, as Trustee for Soundview CIVIL DIVISION Home Loan Trust 2006-NLC1, Asset- DELAWARE County Backed Certificates, Series 2006- NLC1 NO. 13-6137 CIVIL Plaintiff v Jimmy D. Stoey Nichole R. Stoey Defendant(s) CERTIFICATE OF SERVICE The undersigned certifies that true and correct copies of the attached Petition for Postponement of Sheriff' s Sale was served upon the following person(s) named herein at their last known address or their attorney of record by: xxxx Regular First Class Mail Certified Mail Other Date Served: August 29, 2014 TO: Jimmy D. Stoey 102 Cleversburg Road Shippensburg, PA 17257 Nichole R. Stoey 102 Cleversburg Road Shippensburg, PA 17257 UDREN LAW OFFICES, P.C. y.� BY: Nathn Wolf, Esquire Attorney for Plaintiff Loca Counsel IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Deutsche Bank National Trust Company, as Trustee for Soundview Home Loan Trust 2006-NLC1, Asset - Backed Certificates, Series 2006- NLC1 Plaintiff v Jimmy D. Stoey Nichole R. Stoey Defendant(s) ORDER NO. 13-6137 CIVIL AND NOW, this V' day of :; 2014, after consideration of Plaintiff's Petition for Postponement of Sheriff's Sale of the mortgaged property located at 102 Cleversburg Road, Shippensburg, PA 17257, it is hereby ORDERED that the said Sale currently scheduled for September 3, 2014, is extended 2 (two) month (s) to the regularly scheduled CUMBERLAND County Sheriff's Sale scheduled for November 5, 2014. No further advertising or additional notice to lienholders or Defendant(s) is required provided the postponement is announced at the September 3, 2014 Sheriff ¢'s Sale,. To: immy D. Stoey 102 Cleversburg Road Shippensburg, PA 17257 ichole R. Stoey 102 Cleversburg Road Shippensburg, PA 17257 Sheriff of Cumberland County -wren Law Offices, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08,003 jQS /Vat pike-s4b.A cn rrn n.- -o UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust Company, as Trustee for Soundview Home Loan Trust 2006-NLC1,Asset-Backed Certificates,Series 2006-NLC1 Plaintiff v. JIMMY D. STOEY NICHOLE R. STOEY Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-6137 Civil NOTICE OF THE DATE OF CONTINUED SHERIFF'S SALE C) "-7 f+.1 %s) (.0 rn r The Sheriffs Sale scheduled for September 3, 2014 at 10:00 AM in the above -captioned matter has been continued until November 5, 2014 at 10:00 A Date: etiq IL( MJU#: 12020226 CASE#: 12020226-1 BY: Atto AMANDAL. AUER. ES01.1:PF UBEAS, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 (856) 669-5400 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadingeftdren.com Deutsche Bank National Trust Company, as Trustee for Soundview Home Loan Trust 2006-NLC1, Asset - Backed Certificates, Series 2006- NLC1 Plaintiff v. Jimmy D. Stoey Nichole R. Stoey Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION 2 CUMBERLAND County c= -L- -1D NO. 13-6137 CIVIL =7'3 u-) ca r -- >C) Z rN) PETITION FOR POSTPONEMENT OF SHERIFF'S SALE Plaintiff, by its counsel, petitions the Court for a 2 (two) month postponement of the Sheriff's sale scheduled in the above captioned matter and in support thereof avers the following: CAD 1. A Sheriff's sale of the mortgaged property involved herein, located at 102 Cleversburg Road, Shippensburg, PA 17257, was originally scheduled for June 4, 2014, then postponed to July 2, 2014, to allow Plaintiff to review the pending Home Affordable Modification (HAMP) application, then postponed to September 3, 2014, then postponed to November 5, 2014. 2. The Plaintiff seeks the postponement of the Sheriff's sale 2 (two) month(s) to review the pending (HAMP) application. 3. Purbuant to local rule the defendant(s) is unrepresented by counsel and plaintiff has no manner in which to seek concurrence except by mail. 4. The Honorable Kevin A. Hess (P.J.) was assigned to this matter and granted Plaintiff's prior petition to postpone sheriff sale.. rn cD -11 WHEREFORE, Plaintiff respectfully prays and requests that the Sheriff's sale of the mortgaged property be postponed to the January 7, 20/5 Sheriff's sale. BY: Respectful UDR or Plain David Neeren, Eaciu PA ID 204252 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadings@udren.com Deutsche Bank National Trust Company, as Trustee for Soundview Home Loan Trust 2006-NLC1, Asset - Backed Certificates, Series.2006- NLC1 Plaintiff v. Jimmy D. Stoey Nichole R. Stoey Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. 13-6137 CIVIL PLAINTIFF'S MEMORANDUM OF LAW Pennsylvania R.C.P. 3129.3(b) allows for the postponement of a Sheriff's sale. In the present matter, the sale has been previously postponed. Plaintiff now seeks an additional postponement in order to review the (RAMP) application. Therefore, in order for the Plaintiff to be able to properly conduct itself at the Sheriff's sale, a postponement of the sale is necessary. Pa.R.C.P. 3129.3(a) allows the postponement of the sale more than once, and without new notice, by Special Order of Court. Accordingly, for the reasons hereinabove stated, and as more particularly set forth in the Motion, Plaintiff respectfully requests continuance of the Sheriff's Sale of the mortgaged premises, located at 102 Cleversburg Road, Shippensburg, PA 17257, to the January 7, 2015, Sheriff's sale as set forth in the Motion. Nathan C Wolf, Esquire Local Counsel Respectfully submi UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadings@udren.com Deutsche Bank National Trust Company, as Trustee for Soundview Home Loan Trust 2006-NLC1, Asset - Backed Certificates, Series 2006- NLC1 Plaintiff v. Jimmy D Stoey Nichole R. Stoey Defendant (s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. 13-6137 CIVIL CERTIFICATE OF SERVICE The undersigned certifies that true and correct copies of the attached Petition for Postponement of Sheriff's Sale was served upon the following person(s) named herein at their last known address or their attorney of record by: Regular First Class Mail Certified Mail Other Date Served: November 3, 2014 TO: Jimmy D. Stoey 102 Cleversburg Road Shippensburg, PA 17257 Nichole R. Stoey 102 Cleversburg Road Shippensburg, PA 17257 than /Wolf, Esquire Local !•unset BY: A or Plaintiff �a irk + eeren, Esquire PA t) 204252 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Deutsche Bank National Trust Company, as Trustee for Soundview Home Loan Trust 2006-NLC1, Asset - Backed Certificates, Series 2006- NLC1 Plaintiff v. Jimmy D. Stoey Nichole R. Stoey Defendant(s) ORDER NO. 13-6137 CIVIL AND NOW, this Y. day of November, 2014; after consideration of Plaintiff's Petition for Postponement of Sheriff's Sale of the mortgaged property located at 102 Cleversburg Road, Shippensburg, PA 17257, it is hereby ORDERED that the said Sale currently scheduled for November 5, 2014, is extended 2 (two) month (s) to the regularly scheduled CUMBERLAND County Sheriff's Sale scheduled for January 7, 2015. No further advertising or additional notice to lienholders or Defendant(s) is required provided the postponement is announced at the November 5, 2014 Sheriff's Sale. To --"1-1-_y D. Stoey 102 Cleversburg Road Shippensburg, PA 17257 Nichole R. Stoey 102 Cleversburg Road Shippensburg, PA 17257 10/Sheriff of Cumberland County ren Law Offices, P.C. 111 Woodcrest Road, Suite Cherry Hill, NJ 08003 )1.1t.:,) L7 E 200 BY THE COURT: /kg Cr! UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin s@udren.com Deutsche Bank National Trust Company, as Trustee for Soundview Home Loan Trust 2006-NLC1,Asset-Backed Certificates,Series 2006-NLC1 Plaintiff v. JIMMY D. STOEY NICHOLE R. STOEY Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE p NO. 13-6137 Civil NOTICE OF THE DATE OF CONTINUED SHERIFF'S SALE The Sheriffs Sale scheduled for November 5, 2014 at 10:00 AM in the above -captioned matter has been continued until January 7, 2015 at 10:00 AM. Date:111q/4 MJU#: 12020226 CASE#: 12020226-1 BY: Attorney or Plaintiff UDREN LAW OFFICES, P.C. 111 Woodcrest Road, Suite 200 Cherry. Hill, NJ 08003 (856) 669-5400 :`cote LaB'i'a, PA ID 202194