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Home My WebLink About14-2574 Supreme Court of Pennsylvania Cour ,, f Common Pleas A IV1t.cover Sheet For Prothonotary Use Only: C ER�LAND ' COUnty Docket No: 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 ® Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking E Lead Plaintiffs Name: Deutsche Bank National Trust Company as Lead Defendant's Name: Sean E. Martin C Trustee for Morgan Stanley Loan Trust 2006 -NC2 T Are money damages requested ?: ❑ Yes ® No Dollar Amount Requested: within arbitration limits I (Check one) X outside arbitration limits O N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJ Appeal? ❑ Yes ® No Name of Plaintiff /Appellant's Attorney: Scott A. Dietterick, Esq. c/o Zucker, Goldberg & Ackerman, LLC A ❑ 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 ❑ Board of Assessment ❑ -Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other S F1 Product Liability (does not include mass tort) ❑ Employment Dispute: E ❑ Slander /Libel /Defamation Discrimination ❑ Other: ❑ Employment Dispute: Other C ❑ Zoning Board T ❑ Other: I MASS TORT ❑ Other: O El Asbestos ❑ Tobacco N ❑ Toxic Tort- DES ❑ Toxic Tort- Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste F1 Other: [:1 Ejectment [:1 Common Law /Statutory Arbitration ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment B ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations PROFESSIONAL LIABILITY ® Mortgage Foreclosure: Residential Restraining Order ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 111112011 Zucker, Goldberg & Ackerman, LLC 062-PA-V4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY CIVIL DIVISION AS TRUSTEE FOR MORGAN STANLEY LOAN TRUST 2006 -NC2 , NO.: Plaintiff, TYPE OF PLEADING vs. CIVIL ACTION - COMPLAINT Sean E. Martin; Amy Martin; IN MORTGAGE FORECLOSURE Defendants. FILED ON BEHALF OF: Deutsche Bank National Trust Company as TO: DEFENDANTS Trustee for Morgan Stanley Loan Trust 2006 - YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS NC2 FROM SERVICE HEREOF OR DEFAULT JUDGMENT MAY BE ENTERED AGAINST YOU. COUNSEL OF RECORD FOR THIS PARTY: I HEREBY CERTIFY THAT THE ADDRESS OFTHE PLAINTIFF IS: ZUCKER GOLDBERG & ACKERMAN, LLC 3476 Stateview Blvd. Ft. Mill, SC 29715 Scott A. Dietterick, Esquire- Pa. I.D. #55650 AND THE DEFENDANT: Kimberly A. Bonner, Esquire- Pa. I.D. #89705 339 Bobcat Road Joel A. Ackerman, Esquire- Pa I.D. #202729 Newville, PA 17241 Ashleigh Levy Marin, Esquire- Pa I.D. #306799 Ralph M. Salvia, Esquire- Pa I.D. #202946 CERTIFICATE OF LOCATION Jaime R. Ackerman, Esquire- Pa I.D. #311032 1 HEREBY CERTIFY THATTHE LOCATION OF Jana Fridfinnsdottir, Esquire- Pa I.D. #315944 THE REAL ESTATE AFFECTED BY THIS LIEN IS Brian Nicholas, Esquire- Pa I.D. #317240 339 Bobcat Road (a /k /a 339 Bob Cat Road), Newville PA 17241 Denise Carlon, Esquire- Pa I.D. #317226 Municipality: Upper Frankford r 200 Sheffield Street, Suite 101 F r _ ATTORNEY FOR PLAINTIFF Mountainside, NJ 07092 (908) 233 -8500 ATTY FILE NO.: XCP 153950 (908) 233 -1390 FAX office @zuckergoldberg.com `_`� :�� CO - File No.: XCP- 153950/rbo U - CD c o� C� �Ll 3a� IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Deutsche Bank National Trust Company as CIVIL DIVISION Trustee for Morgan Stanley Loan Trust 2006 -NC2 Plaintiff, NO.: VS. Sean E. Martin; Amy Martin; Defendants. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990 -9108 Phone (800) 990 -9108 (717) 249 -3166 (717) 249 -3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Deutsche Bank National Trust Company as CIVIL DIVISION Trustee for Morgan Stanley Loan Trust 2006 -NC2 Plaintiff, NO.: VS. Sean E. Martin; Amy Martin; Defendants. AVISO LISTED HA SIDO DEMANDADO /A EN CORTE. Si usted desea defenderse de la demanda establecida en las siguientes paginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dias despues de la notificaci6n de esta Demanda y Aviso respondiendo personalmente o por medio de un abogado una comparecencia esc rita y radicando en la Corte por escrito sus defensas y objeciones a las demandas establecidas en su contra. Se le advierte de que si usted falla en tomar accion como se describe anteriormente, el caso puede proceder sin usted sin previo aviso y un fallo por cualquier suma de dinero reclamada en la demanda 0 cua Iquier otra reclamaci6n o remedio solicitado por el demandante, puede ser dictado en contra suva por la Corte. Usted puede perder dinero o propiedades u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO 0 NO PUEDE PAGAR LINO, LLAME 0 VAVA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990 -9108 Phone (800) 990 -9108 (717) 249 -3166 (717) 249 -3166 .Y: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Deutsche Bank National Trust Company as CIVIL DIVISION Trustee for Morgan Stanley Loan Trust 2006 -NC2 c/o Wells Fargo Bank, NA. NO.: 3476 Stateview Blvd. Ft. Mill, SC 29715 Plaintiff, VS. Sean E. Martin 339 Bobcat Road Newville, PA 17241; Amy Martin 339 Bobcat Road Newville, PA 17241; Defendants. CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And now comes Deutsche Bank National Trust Company as Trustee for Morgan Stanley Loan Trust 2006 -NC2, by its attorneys, Zucker, Goldberg & Ackerman, LLC, and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is Deutsche Bank National Trust Company as Trustee for Morgan Stanley Loan Trust 2006 -NC2 , (hereinafter "plaintiff ") c/o Wells Fargo Bank, NA, with its place of business located at 3476 Stateview Blvd., Ft. Mill, SC 29715. 2. The Defendant(s) is /are Sean E. Martin, with a last known address of 339 Bobcat Road, Newville, PA 17241. 3. The Defendants) is /are Amy Martin, with a last known address of 339 Bobcat Road, Newville, PA 17241. 4. In order to protect the borrower's privacy, certain personal information of the borrower (such as loan account, Social Security numbers and birth dates), may have been partially or completely redacted on the exhibits to this complaint. Zucker, Goldberg & Ackerman, LLC 062 -PA -V4 . 1 h 5. Deutsche Bank National Trust Company as Trustee for Morgan Stanley Loan Trust 2006 -NC2, directly or through an agent, has possession of the Promissory Note. Deutsche Bank National Trust Company as Trustee for Morgan Stanley Loan Trust 2006 -NC2 is either the original payee of the Promissory Note or the Promissory Note has been duly indorsed. A copy of said Promissory Note is marked Exhibit A, attached hereto and made a part hereof. 6. On or about November 28, 2005, Sean E. Martin and Amy Martin, husband and wife made, executed and delivered to New Century Mortgage Corporation a Mortgage in the original principal amount of $88,900.00 on the premises described in the legal description marked Exhibit B, attached hereto and made a part hereof. Said mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on December 5, 2005, in Mortgage Book \Volume 1933, Page 620. The mortgage is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g) which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 7. The aforesaid Note and /or Mortgage was modified pursuant to a Loan Modification Agreement, dated June 17, 2009. A true and correct copy of said Modification Agreement is marked Exhibit C, attached hereto and made a part hereof. 8. Plaintiff is the current Mortgagee. By Assignment of Mortgage recorded July 17, 2008, the mortgage was assigned to Deutsche Bank National Trust Company as Trustee for Morgan Stanley Loan Trust 2006 -NC2 which assignment is recorded in the Office of the Recorder of Deeds for Cumberland County, Instrument #200824313. The Assignment is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 9. Sean E. Martin and Amy Martin, husband and wife are the record and real owners of the aforesaid mortgaged premises. 10. Defendants are in default under the terms of the aforesaid Mortgage for, inter alia, failure to pay the installments of principal and interest due February 1, 2011. Zucker, Goldberg & Ackerman, LLC 062 -PA -V4 11. As of 04/16/2014 the amount due and owing Plaintiff on the mortgage is as follows; Principal $96,148.18 Interest $25,314.71 From 01/01/2011 to 04/16/2014 Late Charges $112.14 Escrow Advance $10,897.81 Property Inspections $442.76 Property Preservation $0.00 BPO /Appraisals $85.00 Escrow Balance $0.00 Corporate Advance Credit $(5.00) Total $132,995.60 plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania Law, actually and reasonably incurred by Plaintiff, including but not limited to, costs (including escrow advances) and Plaintiff's attorneys' fees and expenses. Plaintiff reserves the right to file a motion in the above - captioned action to add such additional sums authorized under the Mortgage and Pennsylvania Law to the above amount due and owing when incurred. 12. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and /or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s). 13. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is Rot seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so in a separate legal action if such right exists. If Defendants) have received a discharge of personal liability in a bankruptcy proceeding, this action is in no way an attempt to re- establish such liability. Zucker, Goldberg & Ackerman, LLC 062 -PA -V4 WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of $132,995.60 with interest thereon plus additional costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. ZUCKER, GOLDBERG & A,ICKEERM�}A/N, LLC BY: Dated: I�� 4 "� Scott A. Diette i Esquire; PA I.D. # q 55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Attorneys for Plaintiff XCP- 153950/rbo 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233 -8500; (908) 233 -1390 FAX Email: Office @zuckergoldberg.com THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Zucker, Goldberg & Ackerman, LLC 062 -PA -V4 EXHIBIT A Zucker, Goldberg & Ackerman, LLC 062 -PA -V4 ORIGINAL ADJUSTABLE RATE NOTE (LIBOR Six -Month Index (As Published In The Wall .Street Journal) - Rate Caps) THIS NOTE CONTAINS PROVISIONS ALLOWING FOR CHANGES IN MY INTEREST RATE AND MY MONTHLY PAYMENT. THIS NOTE LIMITS THE AMOUNT MY INTEREST RATE CAN CHANGE AT ANY ONE TIME AND THE MAXIMUM RATE i MUST PAY. November 28. 2005. Newville Pennsylvania [Dace) (City] islatel 339 BOBCAT RD, Newville, PA 17241 [Property Address) 1. BORROWER'S PROMISE TO PAY In return for a loan that I have received, I promise to pay U.S. $ 88. 900.00 (this amount is called "Principal"), plus interest, to the order ofLendcr.I.,eoderisNow Century Mortgage Corporation I will snake all payments under this Note in the form of cash, check or money order. 1 understand that Lender may transfer this Note. Lender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note is called the "Note Holder." 2. IN'T'EREST Interest will be charged on unpaid principal until the full amount of Principal has been paid. I will pay interest at a yearly rate of 8.450 %. The interest rate I will pay may change in accordance with Section 4 of this Note. The interest rate required by this Section 2 and Section 4 of this Note is the rate I will pay both before and after any default described in Section 7(B) of this Note. 3. PAYMENTS (A) Time and Place of Payments I will pay principal and interest by making a payment every month. I will make my monthly payments on the first day of each month beginning on February 1. 2006 I will make these payments every month until I have paid all of the principal and interest and -any other charges described below that 1 may owe under this Note. Each monthly payment will be applied as of its scheduled due date and will be applied to interest before Principal. If, on 01 /01/2036 , I still owe amounts under this Note, I will pay those amounts in full on that date, which is called the "Maturity Date." I will make my monthly payments at 18400 Von Karman, Suite 1000, Irvine, CA 92612 or at a different place if required by the Note fielder. (13) Amount of My Initial Monthly Payments Each of my initial monthly payments will be in the amount of U.S. $ 680 .42 This amount may change, (C) Monthly Payment Changes Changes in my monthly payment will reflect changes in the unpaid principal of my loan and in the interest rate that I must pay. The Note Holder will determine my new interest rate and the changed amount of my monthly payment in accord=e with Section 4 of this Note. MULTISTATE ADJUSTABLE RATE NOTE -LIBOR SIX-MONTH INDEX (AS PUBLISHED IN THE WALL STREET JOURNAL) - Single Family - Fannie Mae UNIFORM INSTRUMENT 40-838N (02101 Form 3520 'tt01 VMP MORTGAGE FORMS - (9001671.72 Page 1 01 4 )nib f 4. INTEREST RATE AND MON'T'HLY PAYMENT CHANGES (A) Change Dates The interest rate I will pay may change on the first day of January, 2008 and on that day every 6th month thereafter. Each date on which my interest rate could change is called a "Change Date." (B) The Index Beginning with the first Change Date, toy interest rate will be based on an Index. The "Index" is the average of interbank offered rates for six month U.S. dollar- denominated deposits in the London market ( "LIBOR "), as published in The Wall Sheer Journal. The most recent Index figure available as of the first business day of the month immediately preceding the month in which the Change Date occurs is called the "Current Index.' If the Index is no longer available, the Note Holder will choose a new index that is based upon comparable information. The Note Holder will give me notice of this choice. (C) Calculation of Changes Before each Change Date, the Note Holder will calculate my now interest rate by adding F v And Ninety -five Hundredth(s) percentage points ( 5.950 %) to the Current Index. The Note Holder will then round the result of this addition to the nearest one- eighth of one percentage point (0.125 %). Subject to the limits stated in Section 4(D) below, this rounded amount will be my new interest rate until the next Change Date. The Note Holder will then determine the amount of the monthly payment that would be sufficient to repay the unpaid principal that I am expected to owe at the Change Date in full on the Maturity Date at my new interest rate in substantially equal payments. The result of this calculation will be the new amount of my monthly payment, (D) Limits on Interest Rate Changes The interest rate 1 am required to pay at the first Change Date will not be greater than 9.950 or less than 8.450 %, Thereafter, my interest rate will never be increased or decreased on any single Change Date by more than One And One - hat f percentage point(s) ( 1.500 %) from the rate of interest I have been paying for the preceding 6 months. My interest rate will never be greater than 15.450%. (E) Effective Date of Changes My new interest rate will become effective on each Change Date. I will pay the amount of my new monthly payment . beginning on the first monthly payment date after the Change Date until the amount of my monthly payment changes again. (E) Notice of Changes The Note Holder will deliver or mail to me a notice of any changes in my interest rate and the amount of my monthly payment before the effective date of any change. The notice will include information required by law to be given to me and also the title and telephone number of a person who will answer any question I may have regarding the notice. S. BORROWER'S RIGHT TO PREPAY I have the right to make payments of Principal at any time before they are clue. A payment of Principal only is known as a "Prepayment." When I make a Prepayment, I will tell the Note Holder in writing that I am doing so. I may not designate a payment as a Prepayment if I have not made all the monthly payment due under this Note. I may make a full Prepayment or partial Prepayments without paying any Prepayment charge. The Note Holder will use my Prepayments to reduce the amount of Principal that I owe under this Note. However, the Note Holder may apply my Prepayment to the accrued and unpaid interest on the Prepayment amount before applying my Prepayment to reduce the Principal amount of this Note. If I make a partial Prepayment, there will be no changes in the due dates of my monthly payments unless the Note Holder agrees in writing to those changes. My partial Prepayment may reduce the amount of my monthly payments after the first Change Date following my partial Prepayment. However, any reduction due to my partial Prepayment may be offset by an interest rate increase. 6. LOAN CHARGES If a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest or other loan charges collected or to be collected in connection with this loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from me that exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing the Principal I owe under this Note or by making a direct payment to me. If a refund reduces Principal, the reduction will be treated as a partial Prepayment. Form 3 . M�838N 1 Pp 2.14 niU6 +s• ~ ~ . ~ j ^__--z_—L��'_ z BORROWER'S FAILURE nw PAY aoREQUIRED ' vu Late Charges for Overdue Payments u the Note Holder has not received the full armumm any monthly payment o' the end 'x firtern calendar days after the date it is ou,. / will pay a late char to the Note Holder. The xmvuo,nr the charge will be s.000 m^rm' overdue payment vrnripupm and interest. / will pa this late charge promptly but only once vn each late payment. (B) Default /,/uv not pytmv full amount vf each mo payme onthe date u.,00^./~mm,�uomux� ( Notice of Default If I am in defa the Note Holder may send me a written notice telling me that if I do not pay tire overdue amount by u certain ouc. the Note Holder may require me m pay imme the full amount or Principal that has not been paid and all t interest that / owe vu that amount. that date must bo* least m days after the date ^o which the notice /x mailed = m^o, delivered o/mm*means. (D) No Waiver By Note Holder Even if, *^time when /mn/" default, the Note Holder does not require n*w pay immediately m full asdescribed above, the Note Holder will still have the ,iommxusvo/ar,'io default *x later time, n4 Payment ", Note Holder's Costs and Expenses If the Note Holder has required me to pay immediately in full aug described above, the Note Holder will have the right to be paid back b me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those vsvcxno,ses include, for example, reasonable attorne fees. � � S. GIVING OF Nmrmoo Unless applicable law requires xdifferent m=x^o. m notice that must ,m given wm* under this Note will ov given o' delivering it or by mailing it by first class mail to me at the Property Address above or at ct different address if I give t Note Holder ^ notice o«on different address. Unless the Note Holder requires x different method, any notice that must be given ,^ the Note Holder tinder this Note will o^ given oy mailing uoy first class mail m the Note Holder ^t the address stated /u Section 3(x) above o,*udi address oImngworru notice vr that differen address. v. OBLIGATIONS mF PERSONS UNDER THIS NOTE /r more than one person signs this Note, each person m full and personally obligated m keel) all ^r the promises mxu, in this ww*, including the promise to v"r the mu amount owed. Any person who is u:ourmm,. m,u' or ,,mvqer of this mmv is also vmix^^m to ov mmm things. Any person who takes over these voxom/ow, momu/u the obligations of uumznp, surety or en of this Note, is also obligated mkeo,m ^r the prom made in this Note. The Note Holder may m its rights under this Note against each p individually or against all of us together. This means that any one of-us may oc required m,uymlvr/hmumoo*xo°aonde,uuxmwv. 10-WAIVERS I and any m��w ��m�w��r�ua*�* ,mmwm��m��. "Presentment" the right to require the Note Holder m demand payment o/umvuommm. "Notice m Dishonor" means the right ." r the Note Holder m give notice m other persons that amounts due have not been paid. 11. UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to the Note Holder under this Note, a Mortgage Deed of Trust, or Security Deed (thc "Security instrument"), dated the same date asthis mmo, protects the Note Holder from possible losses that might result x/ xv not keep the promises that / ma in this Note—That Securit Instrument describes howodu"mx~w**mm,mnv/mxy»eoy mmmmme inimoiw=vaymm, /uw/"r all amounts z owe under this Note. Some v, those conditions read mfollows: . / ��x�=� ~�,°, �� Transfer of the Property or a Beneficial Interest in Borrower. As used in this Section 18, "Interest in the Property" means any legal or beneficial interest in the Property, including, but not limited to, those beneficial interests transferred in a bond for deed, contract for deed, installment sales contract or escrow agreement, the intent of which is the transfer of title by Borrower at a future date to a purchaser. If all or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower is not a natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior written consent, Lender may require immediate payment in full of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law. Lender also shall not exercise this option if: (a) Borrower causes to be submitted to Lender information required by Lender to evaluate the intended transferee as if a new loan were being made to the transferee; and (b) Lender reasonably determines that Lender's security will not be impaired by the loan assumption and that the risk of a breach of any covenantor agreement in this Security Instrument is acceptable to Lender. To the extent permitted by Applicable Law, Lender may charge a reasonable fee as a condition to Lender's consent to the loan assumption. Lender also may require the transferee to sign an assumption agreement that is acceptable to Lender and that obligates the transferee to keep all the promises and agreements made in the Note and in this Security Instrument. Borrower will continue to be obligated under the Note and this Security Instrument unless Lender releases Borrower in writing. If Lender exercises the option to require immediate payment in full, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is given in accordance with Section .15 within which Borrower must pay all sums secured by this Security Instrument, If . Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. WITNE T[3E HAND(S) AND SEAL(S) OF THE UNDERSIGNED. (Seal) _ (Seal) SEAN E MARTIN - Borrowcr - Borrower (Seal) (Seal) - Borrower - Borrowcr (Seal) (Seal) - Borrowcr - Borrowcr _... (Seal) .r__(Seal) - Borrowcr . Borrowcr /Sign Original Only/ (M-830N ICx 101 Pop a m e Form 3520 1101 I Pay to the order of, without recourse New Cent ry ortga MpOtIon By: Steve V.P. R orde Mahagament E EXHIBIT B Zucker, Goldberg & Ackerman, LLC 062 -PA -V4 ' E7CIiBBiT °A" . LEGAL DESCREMON ALL that certain messuago and laser of land stAW in (the Township of Upper FnWkford the percent tract previously listed in Lower Frmkfotd Township), County of Cumberland and State of Pennsylvents, Bounded and described as follows: BEGINNING eta stone' the public roadlading to Carlisle; thence by lands now or famorly of JJ Erford, South 22 degrees West, 99.2 perches to a anon in a private mad; thence by leads formmly of Francess McLear, North 72 degrees West, 27.6 perches to a stone; thence by lands now or formerly of Annie M Beecher, North 34 degrees Wort, 153.8 perches to a point; thence by lands forrrly of Francis McLear, North 32 Ys degreas Bast, 67.3 parches to a point; thane by lands now or formerly of J. Beecher and Limo Stover, South 73 '/, degrees East, 40 perches to a stone; thence by land& now or formerly of Daaet, South 41 '/. degrees Bast, 20 perches to a past; thence North 32 % degrees Bust, 313 perches to a port; dtence by lends now or formerly of PA Garber and Jennie Smith Son& 40 K East 67,8 perches to a stone; tbance by lands now or formerly ofJJ Erford, South 5 %, degrees West, 46.1 perches to a stone In the public road, the piece of BEGINNING. Conveyed by Roy W. Chronister and Agnes B. Chronister, his wife, to N. Nell Shughart and Joanne A. Shughart, his wife, recorded in DBV D•19, Page 185. Conveyed by W. Roy Chronister and Agnes E Chmalster, his wife, to Clarence Richard Hurley and Shirley Jane Hurley, his wife DBV H -19, Page 508. Conveyed to Roy W. Chronister and Agnes E, Chronister, his wife, to Victor Hockenberry and Margaret M, Hockenbery his wife, DBV Y-20, Page 572 Conveyed by Roy W. Chronister sad Apes E. Chronister, his wife, to Betty Mae Etter, single woman DBV Z-20, Page 332 Conveyed to Roy W. Chronister and Agnes E. Chroalster, his wife, to Ray M. Snyder and Doris 1. Snyder, his wife, DBV L-26, Page 450 Conveyed by Roy W. Chronister and Agnes E. Chronister, his wife, to J. Chur Chronister and Sondra L. Chronister, his wife, DBV I- 25, Page 121. Parcel No.: 43.04. 0385.046 Cum vPnot Deed Reference: Deed ftm Robert A. Chronister and J. Clair Chronister, co- executors of the Estate of Roy W. Chronister to Ronald L. Hoover and Barbara C. Hoover, husband and wife dated 12/10 /1999 recorded on 3/6/2000 at DBV 217, Page 191. File Number: MORTGAGE FROM: San Martin and Amy Martin , husband and wi fe TO: New Century Mortgage Corporation, It's successors and/or asetges MAIL TO: Re mi e Pew Center Boulevard, L.L.C. 400 Perm nter Boulevard, Suite 707 Pittsburgl6, PA 15235 Y Certify this to be recorded In &gland County Recorder of Deeds ON 19 33PG064 ! - EXHIBIT C Zucker, Goldberg & Ackerman, LLC 062 -PA -V4 Ex"I NT ASC.o AUMCA 71I.MIC-6 COY►IN• Rdl-M61 I)per 0- 1 1 .1 i. M'. 10388 Do Moinm 1A 50506 -0788 LOAN MODIFICATION AGREEMENT LOAN NUMBER: a THIS LOAN MODIFICATION AGREEMENT made on June 17, 2009, by and between SEAN E MARTIN and (the " Borrower's)") and America's Servicing Company ( "Wells Fargo Bank, N.A. doing business as America's Servicing Company ) W I T N E S S E T H WHEREAS, Borrower has requested, and'America's Servicing Company has agreed, subject to the following terms and conditions, to a modification of the note as follows: NOW THEREFORE, in consideration of the covenants hereinafter set forth and of other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged by the parties, it is agreed as follows (notwithstanding anything to the contrary contained in the Note and Mortgage): 1. BALANCE. As of June 17, 2009, the amount payable under the Note and Mortgage (the "Unpaid Principal Balance ") is U.S. $ 87,385.67. 2. EXTENSION. This agreement hereby modifies the following terms of the Note and Security Instrument described herein above as follows: A. The current due"date has been extended from 04 -01 -08 to 09/01/2009. B. The maturity date has been extended from 01 -36 to 01/01/2036. C. The amount of interest to be capitalized will be U.S. $11,105.24. The modified unpaid principal balance is U.S. $98,490.91. D. The borrower promises to pay the unpaid principal balance plus interest, to the order of the Lender. Interest will be charged on the unpaid principal balance of U.S. $ 98,490.91. The borrower promises to make monthly payments of principal and interest of U.S. $ 747.57, at a fixed yearly rate of 8.000 %, not including any escrow deposit, if applicable. If on the maturity date the borrower still owes amount under the Note and Security Instrument, as amended by this Agreement, borrower will pay these amount in full on the maturity date. 3. NOTE AND MORTGAGE. Nothing in this Agreement shall be understood or construed to be a satisfaction or release, in whole or in part of the Borrower's obligations under the Note or Mortgage. Further, except as otherwise specifically provided in this Agreement, the Note and Mortgage will remain unchanged, and borrower and America's Servicing Company will be bound by, and shall comply with, all of the terms and provisions thereof, as amended by this Agreement. LC375 /B1K /Page 1 Loan Modification Agreement Page 2 of 2 Loan Number CORRECTION AGREEMENT. The undersigned borrower(s), for and in consideration of the approval, closing and funding of this Modification, hereby grants America's Servicing Company, as lender, limited power of attorney to correct and /or initial all typographical or clerical errors discovered in the Modification Agreement required to be signed. In the event this limited power of attorney is exercised, the undersigned will be notified and receive a copy of the document executed or initialed on their behalf. This provision may not be used to modify the interest rate, modify the term, modify the outstanding principal balance or modify the undersigned's monthly principal and interest payments as modified by this agreement. Any of these specified changes must be executed directly by the undersigned. This limited power of attorney shall automatically terminate ��i,12 days from the closing date of the undersigned's Modification - (Borrower Initial) By signing this Agreement.I hereby consent to being contacted concerning this loan at any cellular or mobile telephone number I may have. This includes text messages, at no cost to me, and telephone calls including the use of automated dialing systems to contact my cellular or mobile telephone. IN WITNESS WHEREOF, the parties hereto have executed this Agreement as he orst above written. 6, — rrower /Date Borrower /Date f BoWrr/Date Borrower /Date N o n rica's Servicing Company (the "Le'der ") LC375 /B1K /Page 2 012 VERIFICATION Jasmin McLean, hereby states that he/(9 is Vice President Loan Documentation of WELLS FARGO BANK, N.A., mortgage servicing agent for plaintiff in this matter and that he 6 is authorized to make this Verification, and verifies that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of hisj ie information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. The Plaintiff is the investor in the mortgage which is the subject of this action and has delegated the daily servicing responsibility to WELLS FARGO BANK, N.A. Plaintiff lacks sufficient knowledge or information to execute this verification. WELLS FARGO BANK, N.A. is in possession and control of all documents and records supporting the statements in the foregoing pleading and, therefore, the undersigned, rather than an officer or employee of plaintiff, is the appropriate individual to make this Verification pursuant to Pa.R.C.P. 1024(c). e: Jasmin McLean Title: Vice President Loan Documentation Company: Wells Fargo Bank, N.A. Date: 04/17/2014 085 -PA -V3 File # 153950 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA r' Deutsche Bank National Trust Company as CIVIL DIVISION Trustee for Morgan Stanley Loan Trust 2006 -NC2 Plaintiff, Vs. v) �` Sean E. Martin; Amy Martin; Defendants. NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. Zucker, Goldberg & Ackerman, LLC XCP- 153950 If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. TIDS PROGRAM IS FREE. ZUCKER, GOLDBERG & ACKERMAN, LLC lay ►� By. 0 � b,8, Dated: � Scott A. biet BnW, PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Attorneys for Plaintiff XCP- 153950/mti 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233 -8500; (908) 233 -1390 FAX Email: Office @zuckergoldberg.com Zucker, Goldberg & Ackerman, LLC XCP - 153950 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: CUSTOMER/PRI Borrower name(s): Property Address: City: 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? CO-BORROWER Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? 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: Zucker, Goldberg & Ackerman, LLC XCP- 153950 Assets Amount Owed Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1 : Model: Year: Amount owed: Value: Automobile #2 : Model: Year: Amount owed: Value: Monthly Income Name of Employers: 1. 2. 3. Additional Income Description (not wages): 1. Monthly amount: 2. Monthly amount: Borrower Pay Days: Co- Borrower Pay Days: Monthly Expenses (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2 " Mortgage Utilities Car Payment(s) Condo /Neigh. Fees Auto Insurance Med. (not covered) Auto fuel /repairs Other prop. payment Install. Loan Payment Cable TV Child Support/Alim. Spending Money Day /Child Care /Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: Email: Zucker, Goldberg & Ackerman, LLC XCP- 153950 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 known, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: AUTHORIZATION I /We, , authorize the above named to use /refer this information to my lender /servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I /We understand that I /we am /are under no obligation to use the services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: V Proof of Income V Past 2 bank statements V Proof of any expected income for the last 45 days V Copy of current utility bill V Letter explaining reason for delinquency and any supporting documentation (hardship letter) V Listing agreement (if property is currently on the market) Zucker, Goldberg & Ackerman, LLC XCP- 153950 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Deutsche Bank National Trust Company as CIVIL DIVISION Trustee for Morgan Stanley Loan Trust 2006 -NC2 Plaintiff, NO.: VS. Sean E. Martin; Amy Martin; Defendants. REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated February 28, 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 1. Defendant lives in the subject real property, which is defendant's primary residence; 2. 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 unworn falsification to authorities. Signature of Defendant's Counsel /Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date Zucker, Goldberg & Ackerman, LLC XCP- 153950 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Deutsche Bank National Trust Company as CIVIL DIVISION Trustee for Morgan Stanley Loan Trust 2006 -NC2 Plaintiff, NO.: VS. Sean E. Martin; Amy Martin; Defendants. CASE MANAGEMENT ORDER AND NOW, this day of ,20 ,the defendant /borrower in the above - captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant /borrower has complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court- supervised conciliation Conference on at M. in at the Cumberland County Courthouse, Carlisle, Pennsylvania. 1. At least twenty -one (21) days prior to the date of the Conciliation Conference, the defendant /borrower must serve upon the plaintiff /lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant /borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and /or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant /borrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 2. The defendant /borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff /lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff /lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable Zucker, Goldberg & Ackerman, LLC XCP- 153950 resolution, and counsel for the plaintiff /lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff /lender is not available by telephone during the Conciliation Conference, the Court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff /lender at the rescheduled Conciliation Conference. 3. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 4. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, J. Zucker, Goldberg & Ackerman, LLC XCP- 153950 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF, IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY FILED CFPIC . THE PPOTHDNO A t'' MAY 13 PM 3: 05 CUMBERLAND COUNTY PENNSYLVANIA Deutsche Bank National Trust Co. vs. Sean Eric Martin (et al.) Case Number 2014-2574 SHERIFF'S RETURN OF SERVICE 05/02/2014 07:55 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Sean Eric Martin at 339 Bobcat Road, Upper Frankford, Newville, PA 17241. RYAN BURGETT, DEPUTY 05/02/2014 07:55 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Sean Martin,wife, who accepted as "Adult Person in Charge" for Amy Martin at 339 Bobcat Road, Upper Frankford, Newville, PA 17241. RYAN BURGETT, DEPUTY SHERIFF COST: $57.56 SO ANSWERS, May 06, 2014 (ei CountySuite Sheriff, Teleosof•.. Inc. RON R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Deutsche Bank National Trust Company as Trustee for CIVIL DIVISION �w -,- Morgan Stanley Loan Trust 2006-NC2 , -rs C: C73 ; Plaintiff, No.. 14-2574 'a > 1 vs. ISSUE NUMBER: = „w' Sean E. Martin; Amy Martin; � ' c TYPE OF PLEADING: Defendants. - a PRAECIPE FOR ENTRY OF JUDGMENT BY Mortgaged Premises: DEFAULT (MORTGAGE FORECLOSURE) 339 Bobcat Road (a/k/a 339 Bob Cat Road), Newville, PA 17241 FILED ON BEHALF OF: Deutsche Bank National Trust Company as Trustee for Morgan Stanley Loan Trust 2006-NC2 Plaintiff COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG &ACKERMAN, LLC Scott A. Dietterick, Esquire- Pa. I.D. #55650 Kimberly A. Bonner, Esquire- Pa. I.D. #89705 Joel A. Ackerman, Esquire- Pa I.D. #202729 Ashleigh Levy Marin, Esquire- Pa I.D. #306799 Ralph M. Salvia, Esquire- Pa I.D. #202946 Jaime R. Ackerman, Esquire- Pa I.D. #311032 Jana Fridfinnsdottir, Esquire- Pa I.D. #315944 Brian Nicholas, Esquire- Pa I.D. #317240 Denise Carlon, Esquire- Pa I.D. #317226 Roger Fay, Esquire; PA I.D. #315987 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 Atty File No.: XCP-153950 Praecipe for Entry of Judgment Zucker, Goldberg&Ackerman, LLC �P-153950 /^ n /,/ /I H' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Deutsche Bank National Trust Company as CIVIL DIVISION Trustee for Morgan Stanley Loan Trust 2006-NC2 Plaintiff, NO.: 14-2574 vs. Sean E. Martin; Amy Martin; Defendants. PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT(MORTGAGE FORECLOSURE) TO: PROTHONOTARY Please enter judgment, in mortgage foreclosure (in rem only), in the above-captioned case in favor of Plaintiff and against Defendant(s), for failure to file a response to Plaintiff's Complaint within the appropriate time limits from service thereof, and assess Plaintiff's damages as set forth in Complaint: Amount as set forth in Complaint $132,995.60 plus interest on the judgment amount ($132,995.60) from April 17, 2014, at the statutory rate and for foreclosure and sale of the mortgaged premises. I hereby certify that the defendant's last known 339 Bobcat Road address is: Newville, PA 17241 ZUCKER, GOLBERG &ACKERMALLC Dated: ��— �3 --�� BY: ❑ Scott A. ietterick, Esquire; PA. I.D. #55650 ❑ Kimb rly A. Bonner, Esquire; PA. I.D.#89705 ❑ Ralph M. Salvia, Esquire; PA I.D. #202946 ❑ Joel A. Ackerman, Esquire; PA I.D.#202729 ❑ Ashleigh L. Marin, Esquire; PA I.D.#306799 ❑ Jaime R. Ackerman, Esquire; PA I.D. #311032 ❑ Jana Fridfinnsdottir, Esquire; PA I.D.#315944 ❑ Denise Carlon, Esquire; PA I.D.#317226 ❑ Brian Nicholas, Esquire; PA I.D. #317240 ® Roger Fay, Esquire; PA I.D.#315987 Attorneys for Plaintiff XCP-153950 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoIdberg.com DAMAGES ARE HEREBY ASSESSED AS INDICATED ' Date U �S s'� g� Prothonotary Praecipe for Entry of Judgment Zucker, Goldberg&Ackerman, LLC XCP-153950 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Deutsche Bank National Trust Company as CIVIL DIVISION Trustee for Morgan Stanley Loan Trust 2006-NC2 Plaintiff, NC.: 14-2574 VS. Sean E. Martin; Amy Martin; Defendants. AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT STATE OF NEW JERSEY SS: COUNTY OF UNION I, the undersigned attorney for the plaintiff in the above action, being duly sworn according to law, do hereby depose and say that the statements made herein are true and correct to the best of my knowledge, information, and that: 1) The Defendants Sean E. Martin, Amy Martin are not in the military service of the United States of America to the best of my knowledge, information and belief as evidenced by the attached copies; Zucker, Goldberg&Ackerman, LLC XCP-153950 2) The Notice of Intent to take Default Judgment was mailed in accordance with Pa. R.C.P. 237.1 and that the time limits provided for that notice have expired. ZUCKER, GOLBERG &ACKERMAN, LLC Dated: !6 ..! 3. �� BY: A 57, ❑ Scottxeiierick, qui Esre; PA. I.D. #55650 ❑ Kimberly A. Bonner, Esquire; PA. I.D.#89705 ❑ Ralph M. Salvia, Esquire; PA I.D. #202946 ❑ Joel A. Ackerman, Esquire; PA I.D.#202729 ❑ Ashleigh L. Marin, Esquire; PA I.D.#306799 ❑ Jaime R.Ackerman, Esquire; PA I.D. #311032 ❑ Jana Fridfinnsdottir, Esquire; PA I.D.#315944 ❑ Denise Carlon, Esquire; PA I.D. #317226 ❑ Brian Nicholas, Esquire; PA I.D. #317240 Roger Fay, Esquire; PA I.D.#315987 Attorneys for Plaintiff XCP-153950 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoIdberg.com Sworn to and subscribed before me This ( day/-9f(�GtO%� v" , 20 Notary'Public My Commission Expires: JgNELL URLIN ` NOTARY PUBLIC OF NEW JERSEY ID#2364963 My Commission Expires 1011712017 Zucker,Goldberg&Ackerman, LLC XCP-153950 Department of Defense Manpower Data Center Results as of:Oct-10-201409:58:38 AM SCRA 3.0 Status Report Pursuant to Servicememben Civil ReiidAet Last Name: MARTIN First Name: AMY Middle Name: Active Duty Status As Of: Oct-10-2014 On Active Duty On Active Du 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 Da sof 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 Du on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA d 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. Ain, �1. A�M_ r+ Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:hftp://www.defenselink.mil/faq/pis/PC09SLDR.htmi. 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: VEFFU9D4X028J90 Department of Defense Manpower Data Center Results as of:Oct-10-2014 09:57:15 AM SCRA 3.0 Status Report Pursuant to Servicememben Civil ReliefAct Last Name: MARTIN First Name: SEAN Middle Name: E Active Duty Status As Of: Oct-10-2014 On Active Duty On Active Du 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 Das 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 HWHer Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notificatlon 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. )Olt ,.► 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: OEN859C41028AB0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Deutsche Bank National Trust Company as CIVIL DIVISION Trustee for Morgan Stanley Loan Trust 2006-NC2 Plaintiff, NO.: 14-2574 vs. Sean E. Martin; Amy Martin; Defendants. NOTICE OF ORDER, DECREE OR JUDGMENT TO: Sean E. Martin 339 Bobcat Road Newville, PA 17241 [ ] Plaintiff [V] Defendant [ ] Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on U 1 ,-- [ J A copy of the Order or Decree is enclosed, or [V] The judgment is as follows: $132,995.60 � . p cos Prothonotary Zucker, Goldberg&Ackerman, LLC XCP-153950 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Deutsche Bank National Trust Company as CIVIL DIVISION Trustee for Morgan Stanley Loan Trust 2006-NC2 Plaintiff, NO.: 14-2574 vs. Sean E. Martin; Amy Martin; Defendants. NOTICE OF ORDER, DECREE OR JUDGMENT TO: Amy Martin 339 Bobcat Road Newville, PA 17241 [ ] Plaintiff [V] Defendant [ ] Additional Defendant You are hereby notified that an Order Decree or Judgment was entered in the above captioned proceeding on ,y, /S I [ ] A copy of the Order or Decree is enclosed, or [V] The judgment is as follows: $132,995.60 plus costs. T y r � Prothonotary Zucker, Goldberg&Ackerman, LLC XCP-153950 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Deutsche Bank National Trust Company as Trustee CIVIL DIVISION for Morgan Stanley Loan Trust 2006-NC2 Plaintiff, NO.: 14-2574 vs. Sean E. Martin;Amy Martin; Defendant. IMPORTANT NOTICE TO: Amy Martin 339 Bobcat Road Newville, PA 17241 DATE OF NOTICE: 8/21/2014 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 again you. Unless you act within Ten(10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal Help. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone(800)990-9108 Phone(800)990-9108 (717)249-3166 (717)249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Deutsche Bank National Trust Company as Trustee CIVIL DIVISION for Morgan Stanley Loan Trust 2006-NC2 Plaintiff, NO.: 14-2574 vs. Sean E. Martin;Amy Martin; Defendant. AVISO IMPORTANTE TO: Amy Martin 339 Bobcat Road Newville, PA 17241 FECHA DEL AVISO:8/21/2014 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOM-AR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALL EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INIVIEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO 0 NO PUEDE PAGAR UNO, VAYA 0 LLAME LA OFICINA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TO DEFEND &LAWYER REFERRAL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone(800)990-9108 Phone(800)990-9108 (717)249-3166 (717)249-3166 ZUCKER GOLDBERG &ACKERMAN BY: Sc o-f L A- D i e�i,e k, Scott A. Dietterick, Esquire Attorneys for Plaintiff PAID. # 55650 200 Sheffield Street, Suite 301 P.O. Box 1024 Mountainside,NJ 07092-0024 (717) 533-3560 FIRST CLASS U.S. MAIL, POSTAGE PREPAID 153950 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Deutsche Bank National Trust Company as Trustee CIVIL DIVISION for Morgan Stanley Loan Trust 2006-NC2 Plaintiff, NO.: 14-2574 VS. Sean E. Martin;Amy Martin; Defendant. IMPORTANT NOTICE TO: Sean E. Martin 339 Bobcat Road Newville, PA 17241 DATE OF NOTICE: 8/21/2014 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 again you. Unless you act within Ten(10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal Help. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone(800)990-9108 Phone(800)990-9108 (717)249-3166 (717)249-3166 • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Deutsche Bank National Trust Company as Trustee CIVIL DIVISION for Morgan Stanley Loan Trust 2006-NC2 Plaintiff, NO.: 14-2574 vs. Sean E. Martin;Amy Martin; Defendant. AVISO IMPORTANTE TO: Sean E. Martin 339 Bobcat Road Newville, PA 17241 FECHA DEL AVISO:8/21/2014 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOM-AR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROMOS DIEZ (10) DLAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CAB O UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS IMTORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INNIEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO 0 NO PUEDE PAGAR UNO, VAYA 0 LLAME LA OFICINA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TO DEFEND &LAWYER REFERRAL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone(800)990-9108 Phone(800)990-9108 (717)249-3166 (717)249-3166 ZUCKER GOLDBERG&ACKERMAN BY: Scolf A. 12U*er" Scott A. Dietterick, Esquire Attorneys for Plaintiff PAID. # 55650 200 Sheffield Street, Suite 301 P.O. Box 1024 Mountainside,NJ 07092-0024 (717) 533-3560 FIRST CLASS U.S. MAIL, POSTAGE PREPAID 153950 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith l Chief Deputy Richard W Stewart Solicitor Farc nF'NE i,c IFF Deutsche Bank National Trust Co. Case Number vs. 2014-2574 Sean Eric Martin (et al.) SHERIFF'S RETURN OF SERVICE 05/02/2014 07:55 PM -Deputy Ryan Burgett, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally"handing a true copy to a person representing themselves to be the Defendant,to wit: Sean Eric Martin at 339 Bobcat Road, Upper Frankford, Newville, PA 17241. RYAN BURGETT, DEPUTY 05/02/2014 07:55 PM-Deputy Ryan Burgett, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Sean Martin,wife,who accepted as"Adult Person in Charge"for Amy Martin at 339 Bobcat Road, Upper Frankford, Newville, PA 17241, RYAN BURGETT, DEPUTY SHERIFF COST: $57.56 SO ANSWERS, May 06, 2014 RONN"Y R ANDERSON, SHERIFF (cl Counly Suite Shentl,Toleosoft Inc