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HomeMy WebLinkAbout14-4058 Supreme Cq"' � ennsylvania Cour f 03n11M0 leas For Prothonotary Use Only: C ,1 } lxt Docket No: C5 rianr7� ' County 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 IM Complaint © Writ of Summons ® Petition Transfer from Another Jurisdiction ® Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: Deutsche Bank National Trust Company Sun Chon a/k/a Sun Yi Chon; etal T Are money damages requested? Yes No Dollar Amount Requested: within arbitration limits 01 I (check one) El outside arbitration limits N Is this a Class Action Suit? 0 Yes El No Is this an MDf Appeal? ® Yes Ej No c. ' A Name of Plaintiff/Appellant's Attorney: © Check here if you have no attorney(are a Self-Represented [Pro Sel 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 M Buyer Plaintiff Administrative Agencies Malicious Prosecution 0 Debt Collection:Credit Card ® Board of Assessment © Motor Vehicle Q Debt Collection:Other ® Board of Elections Nuisance ® Dept.of Transportation ® Premises Liability © Statutory Appeal:Other S © Product Liability(does not include mass tort) 0 Employment Dispute: ® Slander/Libel/Defamation C © Other: 0 Employment Dispute:Other ® Zoning Board ,h ® Other: I Other: O MASS TORT ® Asbestos N 13Tobacco ® Toxic Tort-DES ® Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS ® Toxic Waste ® Other: [3Ejectment ® Common Law/Statutory Arbitration B 13 Eminent Domain/Condemnation ® Declaratory Judgment E3Ground Rent 0 Mandamus ® Landlord/Tenant Dispute l3 Non-Domestic Relations ®x Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY ® Mortgage Foreclosure:Commercial ©Quo Warranto ® Dental ® Partition 13 Replevin r-il Legal [3 Quiet Title 0 Other: © Medical ® Other: ®1 Other Professional: Updated 111/2011 a � . 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 c } SHERRI J. BRAUNSTEIN, ESQUIRE- ID#90675 : ' ELIZABETH L. WASSALL,ESQUIRE -ID#77788 r� JOHN ERIC KISHBAUGH,ESQUIRE -ID#33078 2 —' NICOLE B. LABLETTA, ESQUIRE - ID#202194 DAVID NEEREN, ESQUIRE - ID#204252 �' c AMANDA RAVER, ESQUIRE -ID#307028Fc n 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 Saxon Asset Securities Trust CIVIL DIVISION 2007-4, Mortgage Loan Asset-Backed CUMBERLAND County Certificates, Series 2007-4 n C/O Ocwen Loan Servicing,LLC 1661 Worthington Road NO. Suite 100 West Palm Beach, FL 33409 Plaintiff V. UNITED STATES OF AMERICA P.O. BOX 11754 HARRISBURG,PA 17108 CHANG CHON A/K/A CHANG MUN CRON 227 EWE ROAD MECHANICSBURG,PA 17055 SUN CHON A/K/A SUN YI CHON 227 EWE ROAD MECHANICSBURG,PA 17055 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 CL'g6) D4�_- 36 229S 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 Plaintiff s favor: Assignor: Saxon Mortgage,Inc. Assignee: Deutsche Bank National Trust Company,as Trustee for Saxon Asset Securities Trust 2007-4,Mortgage Loan Asset-Backed Certificates,Series 2007-4 Date of Assignment: Recorded Date: Book/Instrument#: Page: 2. Upon information and belief Defendant(s) and/or their predecessor: Chang Chon a/k/a Chang Mun Chon and Sun Chon a/k/a Sun Yi Chon (hereinafter"Defendants"),are the owners of property located at 227 Ewe Road, Mechanicsburg,PA 17055 ,by virtue of Deed dated 06/04/1998 and recorded 06/08/1998 in Official Records Book 178 at Page 913 of the Public Records of Cumberland County, Pennsylvania(hereinafter the "Property"). (2A) United States of America is a defendant by virtue of a potential interest in the property. 3. On 10/09/2007,Defendant(s)and/or their predecessor: CHANG CHON A/K/A CHANG MUN CHON AND SUN CHON A/K/A SUN YI CHON promised to pay to the order of Saxon Mortgage,Inc. ,the principal sum of $ 192,000.00 payable with interest thereon provided in the Note. 4. By Mortgage dated 10/09/2007,Defendant(s)and/or their predecessor: CHANG CHON A/K/A CHANG MUN CHON AND SUN CHON A/K/A SUN YI CHON to secure the Note,mortgaged to Saxon Mortgage,Inc. , the Property which is the subject of this action. The Mortgage was recorded on 10/22/2007 in Official Records Instrument Number: 200740179. 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 09/01/2013, 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 $181,086.79 Accumulated Interest $9,349.83 Accumulated Late Charges $439.30 Escrow Deficit/(Reserve) $332.08 Property Inspection Fees $93.00 Property Valuation Fee - BPO $200.00 Title Report Fee $300.00 Grand Total $191,801.00 The above figures are calculated as of 05/23/14: 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 6.37500%. The per diem interest accruing on this debt is $31.4400 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 $61.20. Plaintiff is entitled to recover attorneys fees and costs in accordance with the terms of the mortgage and note and reserves its right to recover these amounts incurred and to be incurred in bringing and maintaining this action. 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 $191,801.00 plus ongoing interest, costs, fees, and charges collectible under the mortgage, including but not limited to attorney fees and costs and for sale of the mortgaged premises. U AW OFFI , P.0 BY: 0.,I VERIFICAPR eer , quire I Duane Thompson, Contract Management Coordinator of Ocwen Loan Servicing, LLC("Ocwen")the servicing agent(or servicer) for Deutsche Bank National Trust Company, as Trustee for Saxon Asset Securities Trust 2007-4, Mortgage Loan Asset-Backed Certificates, Series 2007-4 ("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 Ocwen'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 believe to be true or which I know to be false Date: —Zle—/� eca _ Name: Duane Thompson Title: Contract Management Coordinator Company: Ocwen Loan Servicing LLC the servicing agent (or servicer) for Deutsche Bank National Trust Company, as Trustee for Saxon Asset Securities Trust 2007-4, Mortgage Loan Asset-Backed Certificates, Series 2007-4 Borrower: CHANG CHON A/K/A CHANG MUN CHON SUN CHON A/K/A SUN YI CHON Property Address: 227 Ewe Road, Mechanicsburg, PA 17055 MJU #: 14030267-1 ALL THAT CERTAIN lot or piece of growitl situate iu the To��-nship of Lower Allen, Cowity of Cumberlwid and Commonwealth of Pennsylvania, hounded and described according to a Final Subdivision Plan for Sheepford Crossing, Section 2, prepared by Whitlock Hartman, Professional Engineers, Camp Hill, Pennsylvania, dated July 5, 1985, and record�d April 10, 1986 in Plan Book 49, Page 143. BEGINNjING at a point on the Northwest sic e of Ewc Road acid a corner of Lot No. 130 on said Plan; thence extending along said Lot, North seventeen d •giccs, fifteen minutes, zero seconds West, 150.00 feet to a point in line of other land of Sheepford Corp; t ence extending along said lands, North seventy-two degrees, forty-five minutes, zero seconds .East, 43.6feet to a point a corner of Lot No. 132 on said Plan; thence extending along said Lot, South sixty-foto-d groes, thirty-eight minutes, twenty-six seconds East, 212.02 feet to a point at the intersection of Ovis Drive and F.,we Road; thence extending along a curve to the Southwest having a radius of 20.00 feet the arc distance of 16.54 feet. to a point on the Northwest side of Ewe Road; thence extending along said road, South seventy-two degrees, forty-five minutes, zero seconds West, 185.00 feet to the point and place of beginning. BEING Lot No. 131 on said Plan; House Nu 227 Fwe Road. BEING designated as tax identification num�cr 13-26-0251-113 in the Deed Registry Office of Cumberland County, Pennsylvania. BEING known as No. 227 Ewe Road. BEING Tax Parcel No. 13-26-0251-113. BEING the same premises which Tae Hwan im and Un Cha Kim, his wife by Deed dated June 4, 1998 and recorded June 8, 1998 in the County of Cum erland in Deed Book 178 Page 913 conveyed unto Chang Chon and Sun Yi Chon, his wife, in fee. i i ?3548-07 1 To: Sun Yi Chou 227 Ewe Road Mechanicsburg,PA 17055 Re: Property Address: 227 Ewe Road Mechanicsburg,PA 17055 MJU#: 14030267-1 Exhibit A To: Chang Chou 227 Ewe Road Mechanicsburg,PA 17055 Re: Property Address: 227 Ewe Road Mechanicsburg,PA 17055 MJU#: 14030267-1 March 19,2014 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): Chang Chon Sun Yi Chou PROPERTY ADDRESS: 227 Ewe Road,Mechanicsburg,PA 17055 LOAN ACCT.NO.: ORIGINAL LENDER: Saxon Mortgage,Inc. CURRENT LENDER/SERVICER: Deutsche Bank National Trust Company,as Trustee for Saxon Asset Securities Trust 2007-4,Mortgage Loan Asset- Backed Certificates,Series 2007-4 HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SA VE 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 ONLYAND 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(Bring it up to date). NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender on your property located at: 227 Ewe Road,Mechanicsburg,PA 17055 IS SERIOUSLY IN DEFA ULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due:_ Monthly Payment of $1,656.58 For September 2013 $1,656.58 Monthly Payment of $1,618.18 For October 1, 2013 through March 1,2014 $9,709.08 Late Charges $439.30 Other Charges(explain/itemize Property Inspection Fees $63.00 Property Valuation Fees/BPO $100.00 Total Amount Past Due: $11,967.96 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 $11,967.96, 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 02/24/2014 01:16 PM Advantage Credit Counseling Servke/CCCS of Western PA Community Action Commission of Capital Region 2000 Linglestown Road 1514 Derry Street Harrisburg,PA 17102 Harrisburg,PA 17104 888-511-2227 717-232-9757 t Housing Alliance of YorkN 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 Hairisburg,PA 17110 717-334-1518 717-780-3940 800-342-2397 i ! UDR � WIm U.S.POSTAGE>>AT £Y SOVXStiw ° cbRA7E CENfEF° wooDCREST ROAD r r CHERRY HILL,NJ 08003 4 ZIP 08003 � a05.34° 91 71,99 9991 7033 2356 3376 % 02 4Y1 0001387090MAR 45 2044 9 f To: Sun Yi Chou 227 Ewe Road Mechanicsburg,PA 17055 U.S.POSTAGE>3 PffWy WvrE,g UDREN LAW boplogg.F:d, , WOODCREST .:GRPt'RA,Tr 4&T2F , •••••�• 141 IWOODC,REST ROAD ' ZIP 08003 $ 006.34° CHERRY MILL,NJ 08003 { 02 91 7090NAR 49 2644 91 7199 9991 7033 2156 3383 To: Chang Chon 227 Ewe Road Mechanicsburg,PA 17055 An4,- FORM I IN,THE COURT OF COMMON PLEAS OF � CUMBERLAND COUNTY, PENNSYLVANA -+ bf0a Plaintiff(s) CX'"01AA VS. Ci Chav� P'(un C Nun y�� �- �� C�tn Ic( aIaICIfrn5wn \11i Chc1r\ . �_- �--o :�• Defendant(s) Civil �Y NOTICE OF RESIDENTIAL MORTGAGE FORECLOSE 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 attaahed:.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.eonciliation.zonference.. Itis not necessary for.you to contact MidP.enn Legal Service for the appointment of a legal representative. however,you mustprovide 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 mustbe filed with the Court within sixty(60)days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME,YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED.BY THIS NOTICE. THIS PROGRAM IS FRE pe ully su e 115 r _ Date re of Counsel for Plaintiff) David Neeren, Esquire FORM 2 Cumberland County.Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland.County Court of Common Pleas Docket# BORRO'�NTR 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 PIease provide the following information to the best of your knowledge: 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? 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: 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: Other transraortation(automobiles boats motorcycles) Model: Year: Amount.owed: Value Monthly Income Name of Employers: l.. 2. 3. Additional Income Description(not wages): I. 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 .Mort a e Food 2° Mo a [utilities Car Pa ens Condo/Nei . Fees Auto Insurance Med.(not covered Auto fuel/repairs Other prop.pa ent Install.Loan Payment Cable TV Child SupportlAtim. Spending Mone Da /Child Care/Tu it. Other Expenses Amount Available for Monthly.Mortgage Payments Based on Income&Expenses: Have you been working witha Housing Counsel-ing Agency? Yes Q No Q If yes,please provide the following information: Counseling Agency: Counselor: Phone(Office): Fax: - 2 i . .............._..... 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: 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: Proof of income V/ Past 2 bank statements -Yr 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) Listing agreement(if property is currently on the market) J S FORINT 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA t>euka� GCkA I. Plaintiff(s) VS. Defendant(s) CIVIL REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated , 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; 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 1.8 Pa. C.S. §4904 relating to unsworn falsification to authorities. Signature of Defendant's Counsel/Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date 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 ELIZABETH L.WASSALL, ESQUIRE - ID#77788 JOHN ERIC KISHBAUGH, ESQUIRE - ID#33078 NICOLE B. LABLETTA,ESQUIRE -ID#202194 - DAVID NEEREN,ESQUIRE -ID#204252 AMANDA RAVER,ESQUIRE -ID#307028 =� = F WOODCREST CORPORATE CENTER ter-- _. ::u C--) 111 WOODCREST ROAD, SUITE 200 _' ' c CHERRY HILL,NJ 08003-3620 - 856-669-5400 o a Pleadings@udren.com Deutsche Bank National Trust Company,as Trustee for Saxon Asset COURT OF COMMON PLEAS Securities Trust 2007-4,Mortgage Loan Asset-Backed Certificates, CIVIL DIVISION Series 2007-4 CUMBERLAND County 1661 Worthington Road, Suite 100,West Palm Beach,FL 33409 V. Plaintiff NO. 1 / „C ((� .� !J J United States of America 228 Walnut Street P.O.Box 11754 Harrisburg,PA 17108 Chang Chon a/k/a Chang Mun Chou 227 Ewe Road Mechanicsburg,PA 17055 Sun Chon a/k/a Sun Yi Chon 227 Ewe Road Mechanicsburg,PA 17055 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;Elizabeth L.Wassall,Esquire;John Eric Kishbaugh, Esquire;Nicole B.LaBletta,Esquire;David Neeren,Esquire,and Amanda Rauer,Esquire on behalf of the Plaintiff, in the above-captioned ma -� UDREN OFFA ES,P. B . T;1squire SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff THE PRC 1 HCNO i :�`� ��t�rxr��r)IIFir•r�� Jody S Smith Chief Deputy • ,.., 241hi JUL 3' At to: 36 Richard W Stewart CUMBERLAND COUNTY Solicitor CFC QF Tke SHERIFF PENNSYLVANIA Deutsche Bank National Trust Company vs. United States of America (et al.) Case Number 2014-4058 SHERIFF'S RETURN OF SERVICE 07/14/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: United States of America, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 07/16/2014 08:30 AM - The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure served by the Sheriff of Dauphin County upon Susan Melendez, who accepted for United States of America, at Federal Building, P.O. BOX 11754, 228 Walnut Street, Harrisburg, PA 11754. Jack Lotwick, Sheriff, Return of Service attached to and made part of the within record. 07/21/2014 08:28 PM - Deputy Dawn Kell, 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 Chang Mun Chon, Husband, who accepted as "Adult Person in Charge" for Sun Yi Chon at 227 Ewe Rd., Lower Allen Twp., Mechanicsburg, PA 17055. IJP DAWN KELL, DEPUTY 07/21/2014 08:28 PM - Deputy Dawn Kell, 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: Chang Mun Chon at 227 Ewe Rd., Lower Allen, Mechanicsburg, PA 17055. SHERIFF COST: $85.95 July 22, 2014 (c) CountySuite Sherif(, Teleosoft, Inc. 'Sictusyl kt_LL DAWN KELL, DEPUTY SO ANSWERS, RONW R ANDERSON, SHERIFF Shelley Ruhl Real Estale Deputy Matthew L. Owens Solicitor •41' ,_1111111_,Iftg , Commonwealth of Pennsylvania County of Dauphin Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Jack Duignan Chief Deputy Michael W. Rinehart Assistant Chief Deputy DEUTSCHE BANK NATIONAL TRUST COMPANY, ET AL VS UNITED STATES OF AMERICA Sheriffs Return No. 2014-T-2033 OTHER COUNTY NO. 2014-4058 And now: JULY 16, 2014 at 8:30:00 AM served the within COMPLAINT IN MORTGAGE FORECLOSURE upon UNITED STATES OF AMERICA by personally handing to SUSAN MELENDEZ * 1 true attested copy of the original COMPLAINT IN MORTGAGE FORECLOSURE and making known to him/her the contents thereof at FEDERAL BUILDING, 228 WALNUT STREET, SUITE 220 HARRISBURG PA 17108 * RECEPTIONIST Sworn and subscribed to before me this 17TH day of July, 2014 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County My Commission Expires January 8, 2018 So Answers, Sheriff of D uphin Coun By Dep heriff Deputy: JEFF TEETER Sheriffs Costs: $41.25 7/15/2014 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 Saxon Asset Securities Trust 2007-4, Mortgage Loan Asset -Backed Certificates, Series 2007-4 1661 Worthington Road Suite 100 West Palm Beach, FL 33409 Plaintiff v. United States of America C/o Peter J. Smith, Esq., U.S. Attorney for the Middle District of PA, 228 Walnut Street P.O. Box 11754 Harrisburg, PA 17108 Chang Chon a/k/a Chang Mun Chon 227 Ewe Road Mechanicsburg, PA 17055 Sun Chon a/k/a Sun Yi Chon 227 Ewe Road Mechanicsburg, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County rn r- cn r> <CD NO. 14-4058 Civil o >c MORTGAGE FORECLOSURE PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: CD ry C71 0 Kindly enter judgment in favor of the Plaintiff and against the Defendant(s), CHANG CHON A/K/A CHANG MUN CHON; SUN CHON A/K/A SUN YI CHON; 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: Unpaid Principal Balance Interest Per Complaint Additional Interest Late Charges Per Complaint Escrow Per Complaint Property Inspection Fees Property Valuation Title Report Fee Grand Total FROM TO 05/23/2014 08/26/2014 Nom ir\KOcid $181,086.79 $9,349.83 $2,986.80 $439.30 $332.08 $93.00 $200.00 $300.00 $194,787.80 ' pa £ -w6 Ref- 3ioaso I hereby certify that (1) the addresses of the Plaintiff and Defendant are ... sown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached he DAMAGES ARE HE BY ASSESSED AS INDICATED DATE: MJU#: 14030267 CASE#: 14030267-1 UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID#45362 LORRAINE GAZZARA DOYLE, ESQUIRE - ID#34576 SHERRI J. BRAUNSTEIN, ESQUIRE - ID#90675 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 JOHN ERIC KISHBAUGH, ESQUIRE - ID#33078 NICOLE B. LABLETTA, ESQUIRE - ID#202194 DAVID NEEREN, ESQUIRE - ID#204252 AMANDA RAUER, ESQUIRE - ID#307028 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-M00 pleadings a(�udren.com Deutsche Bank National Trust Company, as Trustee for Saxon Asset Securities Trust 2007-4, Mortgage Loan Asset -Backed Certificates, Series 2007-4 C/O Ocwen Loan Servicing, LLC 1661 Worthington Road Suite 100 West Palm Beach, FL 33409 Plaintiff v. UNITED STATES OF AMERICA P.O. BOX 11754 HARRISBURG, PA 17108 CHANG CHON A/K/A CHANG MUN CHON 227 EWE ROAD MECHANICSBURG, PA 17055 SUN CHON A/K/A SUN YI CHON 227 EWE ROAD MECHANICSBURG, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County Na jLfL/DSg COMPLAINT IN MORTGAGE FORECLOSURE L C `;= mCD C- = -- i '`; M— C— r.- i- == r -,�rn r— — :74.1 a -C� — a z r__<>= --fa 3> C) -41.•CDx © cc, c:a x-• — 04( cn 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 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY *tir ofn)nb�rr�l�� OFF tCE OF Tk>r $ ERIF Deutsche Bank National Trust Company vs. United States of America (et aL) Case Number 2014-4058 SHERIFF'S RETURN OF SERVICE 07/14/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: United States of America, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according,to law. 07/16/2014 08:30 AM - The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure served by the Sheriff of Dauphin County upon Susan Melendez, who accepted for United States of America, at Federal Building, P.O. BOX 11754, 228 Walnut Street, Harrisburg, PA 11754. Jack Lotwick, Sheriff, Return of Service attached to and made part of the within record. 07/21/2014 08:28 PM - Deputy Dawn Kell, 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 Chang Mun Chon, Husband, who accepted as "Adult Person in Charge" for Sun Yi Chon at 227 Ewe Rd., Lower Allen Twp., Mechanicsburg, PA 17055. DAWN KELL, DEPUTY 07/21/2014 08:28 PM - Deputy Dawn Kell, 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: Chang Mun Chon at 227 Ewe Rd., Lower Allen, Mechanicsburg, PA 17055. SHERIFF COST: $85.95 July 22, 2014 (c) CountySuite Sne,itt, Tekosof Inc. DAWN KELL, DEPUTY SO ANSWERS, g_ RONNY R ANDERSON, SHERIFF Shelley Ruh]. Real EstaU Deputy Matthew L. Owens Solicitor Commonwealth of Pennsylvania County of Dauphin Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Jack Duignan Chief Deputy Michael W. Rinehart Assistant Chief Deputy DEUTSCHE BANK NATIONAL TRUST COMPANY, ET AL VS UNITED STATES OF AMERICA Sheriffs Return No. 2014-T-2033 OTHER COUNTY NO. 20144058 And now: JULY 16, 2014 at 8:30:00 AM served the within COMPLAINT IN MORTGAGE FORECLOSURE upon UNITED STATES OF AMERICA by personally handing to SUSAN MELENDEZ * 1 true attested copy of the original COMPLAINT IN MORTGAGE FORECLOSURE and making known to him/her the contents thereof at FEDERAL BUILDING, 228 WALNUT STREET, SUITE 220 HARRISBURG PA 17108 * RECEPTIONIST Sworn and subscribed to before me this 17TH day of July, 2014 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County My Commission Expires January 8, 2018 So Answers, Sheriff of Dauphin Coun By Deheriff Deputy: JEFF TEETER Sheriffs Costs: $41.25 7/15/2014 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 Saxon Asset Securities Trust 2007-4, Mortgage Loan Asset -Backed Certificates, Series 2007-4 Plaintiff' v. Chang Chon a/k/a Chang Mun Chon, Sun Chon a/k/a Sun Yi Chon United States of America Defendant(s) TO: Chang Chon a/k/a Chang Mun Chon 227 Ewe Road Mechanicsburg, PA 17055 Date of Notice: August 12, 2014 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-4058 Civil 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 TERM NO 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. BY: A Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 MJU#: 14030267 CASE#: 14030267-1 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 Saxon Asset Securities Trust 2007-4, Mortgage Loan Asset -Backed Certificates, Series 2007-4 Plaintiff v. Chang Chon a/k/a Chang Mun Chon, Sun Chon a/k/a Sun Yi Chon United States of America Defendant(s) TO: Sun Chon a/k/a Sun Yi Chon 227 Ewe Road Mechanicsburg, PA 17055 Date of Notice: August 12, 2014 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-4058 Civil 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 DIU (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 DINER() 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. BY: AMANDA L. RAUER, ESQUIRE PA. I.D. # 307028 Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 MJU#: 14030267 CASE#: 14030267-1 Pennsylvania Office 100 W. 3rd Ave. Suite 200 Conshohocken, PA 19428 (PH) 215-568-9500 Mark J. Udren, Esq. Licensed: PA, IV, FL UDREN LAW OFFICES, P. C. New Jersey Office Woodcrest Corporate Center 111 Woodcrest Rd. Suite 200 Cherry Hill, NJ 08003 (PH)856-669-5400 (FX) 856-669-5399 www.udren.com Prothonotary of Cumberland County One Courthouse Square Carlisle, PA 17013 Re: Deutsche Bank National Trust Company, as Trustee for Saxon Asset 4, Mortgage Loan Asset -Backed Certificates, Series 2007-4 vs. UNITED STATES OF AMERICA, CHANG CHON A/K/A CHANG CHON A/K/A SUN YI CHON, Cumberland County C.C.P. No. 14-4058 Civil MJU#: 14030267 CASE#: 14030267-1 Florida Office 2101 W. Commercial Blvd Suite 5100 Fort Lauderdale, FL 33309 (PH) 954-378-1757 (FX) 954-378-1758 Securities Trust 2007- MUN CHON, SUN Dear Sir or Madam: Enclosed please find Affidavit of Non -Military Service for the above captioned matter. I have also enclosed a copy of the Affidavit of Non -Military Service to be time stamped and returned in the enclosed self-addressed stamped envelope. Thank you for your assistance in this matter. Sincerely yours, Kevin Kerr Foreclosure Specialist MX/ Enclosures MJU#: 14030267 CASE#: 14030267-1 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingl@udren.com Deutsche Bank National Trust Company, as Trustee for Saxon Asset Securities Trust 2007- 4, Mortgage Loan Asset -Backed Certificates, Series 2007-4 Plaintiff v. UNITED STATES OF AMERICA, CHANG CHON A/K/A CHANG MUN CHON, SUN CHON A/K/A SUN YI CHON, Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-4058 Civil 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), CHANG CHON A/K/A CHANG MUN CHON, SUN CHON A/K/A SUN YI CHON, 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: UNITED STATES OF AMERICA is not a living person therefore is not elidgible for military service. This statement is made subject to the penalties of 18 'a.C.S. m4904 relating to unsworn falsification to authorities. Dated: August 25, 2014 MJU#: 14030267 CASE#: 14030267-1 Department of Defense Manpower Data Center Status Report Pursuant to Servicermembeirs Civil Relief Act. Last Name: CHON First Name: SUN Middle Name: YI Active Duty Status As Of: Aug -25-2014 Results as of : Aug -25-2014 07:48:29 AM EXHIBIT A SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA . l. No . NA This response reflects the individuats'.active duty status based ori 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 HislHer 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 ttie 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. I. 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 th_ 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: WCD4T15BZ01 C2F0 Department of Defense Manpower Data Center Status Report Pursuant to Servicemembers Civil Relief Act Last Name: CHON First Name: SUN Middle Name: Active Duty Status As Of: Aug -25-2014 Results as of : Aug -25-2014 07:47:29 AM EXHIBIT A SCRA 3.0 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 reflectsw the Individuals' active duty status based on the Active Duly Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA _ - • No'. t NA This response reflects where the Individual left active duty status within 36f dayspreceding the Active Duty Status Date f r• 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. v�. 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: VC4EC 11 B001 B8A0 Departmerrt of Defense Manpower Data Center Status Report Pursuant to Servicemembers Civil Relief Act Last Name: CHON First Name: CHANG Middle Name: MUN Active Duty Status As Of: Aug -25-2014 Results as of : Aug -25-2014 07:45:59 AM EXH181771 SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA ' -- Noy 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 - I 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. yA 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: QCR5C1 OBQ01 B560 Department of Defense Manpower Data Center Status Report Pursuant to Serv1cemembers Civil Relief Act. Last Name: CHON First Name: CHANG Middle Name: Active Duty Status As Of: Aug -25-2014 Results as of : Aug -25-2014 07:42:37 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date 1ctive Duty End Date Status Service Component NA NA.' + - - No NA t 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/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(0 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: RCR1612BZ01AB00 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin s s udren.com Deutsche Bank National Trust Company, as Trustee for Saxon Asset Securities Trust 2007-4, Mortgage Loan Asset -Backed Certificates, Series 2007-4 Plaintiff v. United States of America Chang Chon a/k/a Chang Mun Chon Sun Chon a/k/a Sun Yi Chon Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-4058 Civil PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due Interest From 08/27/2014 to Date of Sale 12/03/2014 Ongoing Per Diem of $31.44 to actual date of sale including if sale is held at a later date. (Costs to be added) aim 9 g ces 03 MJU#: 14030267 CASE#: 14030267-1 $ 194,787.80 $ 3112.56 AMANDA L. RAUER, ESQUIRE PA. I.D. # 307028 Ao,asThbo a SD(J� L5IL* O9b& �l P_41-`�oa� (ivu�"I d ZF �a 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 Saxon Asset Securities Trust 2007-4, Mortgage Loan Asset -Backed Certificates, Series 2007-4 Plaintiff v. United States of America Chang Chon a/k/a Chang Mun Chon Sun Chon a/k/a Sun Yi Chon Defendant(s) FILED-OFF- °A-VitiANEY FOR PLAINTIFF MEI AUG 26 Al110:00 CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-4058 Civil 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 L1 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. AMAN . • . RAUER, ESQUIRE PA. . f� .. # 307028 I 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 Saxon Asset Securities Trust 2007-4, Mortgage Loan Asset -Backed Certificates, Series 2007-4 Plaintiff v. United States of America Chang Chon a/k/a Chang Mun Chon Sun Chon a/k/a Sun Yi Chon Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-4058 Civil Deutsche Bank National Trust Company, as Trustee for Saxon Asset Securities Trust 2007-4, Mortgage Loan Asset -Backed Certificates, Series 2007-4, 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: 227 Ewe Road, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Chang Chon a/k/a Chang Mun Chon 227 Ewe Road Mechanicsburg, PA 17055 Sun Chon a/k/a Sun Yi Chon 227 Ewe Road Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: United States of America C/o Peter J. Smith, Esq., U.S. Attorney for the Middle District of PA, 228 Walnut Street P.O. Box 11754 Harrisburg, PA 17108 Chang Chon a/k/a Chang Mun Chon 227 Ewe Road Mechanicsburg, PA 17055 Sun Chon a/k/a Sun Yi Chon 227 Ewe Road Mechanicsburg, PA 17055 3. ame and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Lower Allen Township Address to follow. Alpha Consulting Engineers, Inc. Address to follow County of Cumberland Address to follow Lower Allen Township Authority Address to follow. Susquehanna Bank Address to follow. 4. Name and address of the last recorded holder of every mortgage of record: Deutsche Bank National Trust Company, as Trustee for Saxon Asset Securities Trust 2007-4, Mortgage Loan Asset -Backed Certificates, Series 2007-4 1661 Worthington Road Suite 100 West Palm Beach, FL 33409 Sr Mortgage Holders - None Jr Mortgage Holders - None 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 Tenant/ Occupants 227 Ewe Road Mechanicsburg, PA 17055 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: United States of America Address to follow. Internal Revenue Service Technical Support Group, William Green Federal Building 600 Arch Street, Room 3259 Philadelphia, PA 19106 Attorney General of U.S. US Department of Justice, Room 5111 Main Justice Building, 10th & Constitution Ave., NW Washington, DC 20530 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: MJU#: 14030267 CASE#: 14030267-1 UDRENOFF, CES, P.C. BY: ER, ESQUIRE # 307028 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 Saxon Asset Securities Trust 2007-4, Mortgage Loan Asset -Backed Certificates, Series 2007-4 Plaintiff v. United States of America Chang Chon a/k/a Chang Mun Chon Sun Chon a/k/a Sun Yi Chon Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-4058 Civil AFFIDAVIT OF LAST KNOWN ADDRESS UNDER RULE 76 The Defendant(s) last known address is as follows: UNITED STATES OF AMERICA C/O PETER J. SMITH, ESQ., U.S. ATTORNEY FOR THE MIDDLE DISTRICT OF PA, 228 WALNUT STREET P.O. BOX 11754 HARRISBURG, PA 17108 CHANG CHON A/K/A CHANG MUN CHON 227 EWE ROAD MECHANICSBURG, PA 17055 SUN CHON A/K/A SUN YI CHON 227 EWE ROAD MECHANICSBURG, PA 17055 This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. AMANDA L. RAKER, ESQUIRE PA. !,D. # 307028 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadins ' udren.com Deutsche Bank National Trust Company, as Trustee for Saxon Asset Securities Trust 2007-4, Mortgage Loan Asset -Backed Certificates, Series 2007-4 Plaintiff v. CHANG CHON A/K/A CHANG MUN CHON, SUN CHON A/K/A SUN YI CHON UNITED STATES OF AMERICA Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-4058 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Sun Chon a/k/a Sun Yi Chon 227 Ewe Road Mechanicsburg, PA 17055 ry cr% C., CD CO - Your house (real estate) at 227 Ewe Road, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriffs Sale on 12/03/2014 at 10:00 A.M. at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $194,787.80, 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. 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 Saxon Asset Securities Trust 2007-4, Mortgage Loan Asset -Backed Certificates, Series 2007-4 Plaintiff v. CHANG CHON A/K/A CHANG MUN CHON, SUN CHON A/K/A SUN YI CHON UNITED STATES OF AMERICA Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-4058 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY 7' = CD '-, TO: United States of America' C� C/o Peter J. Smith, Esq., U.S. Attorney for the Middle District of PA, 228 WaInur' Street P.O. Box 11754 Harrisburg, PA 17108 Your house (real estate) at 227 Ewe Road, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriffs Sale on 12/03/2014 at 10:00 A.M. at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $194,787.80, 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 attomey'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.) ri 2J _c, cp 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. 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 Saxon Asset Securities Trust 2007-4, Mortgage Loan Asset -Backed Certificates, Series 2007-4 Plaintiff v. CHANG CHON A/K/A CHANG MUN CHON, SUN CHON A/K/A SUN YI CHON UNITED STATES OF AMERICA Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-4058 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Chang Chon a/k/a Chang Mun Chon 227 Ewe Road Mechanicsburg, PA 17055 cJ ry C7, CD. rrt r rT Your house (real estate) at 227 Ewe Road, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriffs Sale on 12/03/2014 at 10:00 A.M. at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $194,787.80, 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 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR SAXON ASSET SERCURITIES TRUST 2007-4, MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2007-4 Vs. NO 14-4058 Civil Term CIVIL ACTION — LAW UNITED STATES OF AMERICA C/O PETER J. SMITH, ESQ., U.S. ATTORNEY FOR THE MIDDLE DISTRICT OF PA, CHANG CHON A/K/A CHANG MUN CHON, SUN CHON A/K/A SUN YI CHON WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $194,787.80 L.L.: $.50 Interest FROM 8/27/2014 TO DATE OF SALE 12/3/2014 ON GOING PER DIEM OF $31.44 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $3,112.56 Atty's Comm: Atty Paid: $234.70 Plaintiff Paid: Date: 8/26/14 Due Prothy: $2.25 Other Costs: 1 _ David leviirrothono ary (Seal) By: Deputy REQUESTING. PARTY: Name: AMANDA L. RAUER, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF 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 as Trustee for Saxon Asset Securities Trust CIVIL DIVISION 2007-4,Mortgage Loan Asset-Backed CUMBERLAND County Certificates, Series 2007-4 Plaintiff r•.) NO. 14-4058 Civil r-, v. Chang Chon a/k/a Chang Mun Chon; -- ,' Sun Chon a/k/a Sun Yi Chon; ET AL c� Defendant(s) MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, moves this Honorable Court for an Order directing service of the Notice of Sale upon Defendant(s): CHANG CHON A/K/A CHANG MUN CHON, SUN CHON A/K/A SUN YI CHON, by regular mail and certified mail, and by posting the mortgaged premises and in support thereof avers the following: 1. Process was unable to be served at the then last known address of said Defendant(s) as follows: CHANG CHON A/K/A CHANG MUN CHON 227 EWE ROAD MECHANICSBURG, PA 17055 SUN CHON A/K/A SUN YI CHON 227 EWE ROAD MECHANICSBURG, PA 17055 A copy of the Return of Service is attached hereto as Exhibit"A". 2. Process was unable to be served at the then last known address of said Defendant(s) as follows: CHANG CHON A/K/A CHANG MUN CHON CHON'S KARATE 22 COLONIAL PARK MALL HARRISBURG, PA 17109 A copy of the Return of Service is attached hereto as Exhibit"B". 3. Pursuant to Pa.R.C.P. 430, Plaintiff made a Good Faith Investigation, the report thereof being attached hereto as Exhibit"C". 4. Said investigation was unable to determine an alternate address for said Defendant(s). 5. The last known address of Defendant(s) is as set forth in the attached Exhibits. WHEREFORE, Plaintiff prays and respectfully requests that this Honorable Court enter an Order pursuant to Pa.R.C.P. 430 directing service of the Notice of Sale upon said in paragraph 1,by regular mail and certified mail, and by posting the mortgaged premises. UDREN LAW OFFICES, P.C. Attorneys or Plaintiff Nicole LaBlefta, Esquire Service of Process by Deutsche Bank National Trust Company.as Trustee.et.al.. Plaintiff(s) N. APS International, Ltd. vs. 1-800-328-7171 Chang Chon aka Chang Mun Chon,et.al..Defendant(s) INTI:RVAIIU!VAt APS International Plazn 7800 Glenroy Road a Minneapolis.MN 55439-3122 APS File lit 130986-0001 — AFFIDAVIT OF DUE AND DILIGENT ATTEMPT Service of Process on: LDREN LAW OFFICES --Chang Cbon,aka Chang Mutt Chon Court Case No.Cumberland Co 14-4058-Civil Ms.Henri Crommarty III Woodcrest Rd..Ste.200 Cherry Hill.NJ 08003-3620 Customer File: N14030267-I State of:'RA nSkilva 1iO )ss. County of: Ota.4u,1 ) Name of Server: -r ck V X-- .undersigned. being duly sworn,deposes and says that at all times mentioned herein,s/he was of legal age and was not a party to this action; Documents Served: the undersigned attempted to serve the documents described as: Notice of Sheriff's Sale of Real Property Service of Process on: The undersigned attempted to serve the documents on Chang Chun,aka Chang Mutt Chon and after due and diligent efforts.was unable to effect service. Attempts: The following is a list of the attempts made to effect service: Uatet✓fimeJAddreu Attempted: 227 ENe Road.Mechanicsburg,PA 17055,09104oi4 $a5 2 PIM Reason for NunService:MO U.Y1.1Wer Q J.-S ,Crr itzt.P.rtt-k• natesfTImeIAddress Attempted:aa-, ewt_izoo+d. PA- 17os , oa(IUCx)I`It 3:514 PYL4 Reason for Non-Service: Q/ t.tSC,rCik.a.rtcj• Alot siAnn resd (AXIS pe "10 a erAi cts. flutesmmnllddress Attempted:r*Ma,cine eoc s:A, keclt.WUCS ?A t-105S r79[tt�a0l-1 g:49 ern Reason for Non-Serslce:I)G'Q4gu,Q.rc,4-�-r'csiolua ti• 'i•n-t vLtA^eSS Co.ve4 VIZ" YtL llCri$,g.r fc rk44-o{L&irtrR.v-tiSQM. _ Based upon the above stated facts.Affiant believes the defendant is avoiding service. Signature of Server: Undersigned declares under penalty of perjury Subscribed and sworn to before mc this that the foregoing is true and correct. . I t da of spl-1 yle fr62x, 20 19 Signature of Server Notary Public (Commission Expires) APS International, Ltd. COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Brittany Edcius.Notar Public Lower Paxton Township,Dauphin County My commission expires April 11.2018 EXHIBIT A • Deutsche Bank National Trust Company,as Trustee,et.al., �__� Service of Process by Plaintlff(s) \. APS International, Ltd. vs. 1-800-328-7171 Chang Chon aka Chang Alun Chon,et.al.,Defendants) IN'1'£R`ATlUN a_ `;L APS International Plaza - Nair 7800 Glenroy Road Minneapolis,MN 55439-3122 APS File#: 130986-0001 - _.. _. — _ _ _ AFFIDAVIT OF DUE AND DILIGENT ATTEMPT Service of Process on: UDREN LAW OFFICES I --Sun Chon.aka Sun Yi Chon Ms.Henni Crommarh• Court Case No.Cumberland Co 14-4058-Civil 111 Wooderest Rd..Ste.200 Cherry Hill.NJ 08003-3620 Customer File: N 14030267-1 State of: PerlrlStiVki,exisx )ss. - - - - - - - - - - - - - - - - - County of: 'btpn ) Nance of Server: —Mack �4 „r .undersigned,being duly sworn,deposes and says that at all times mentioned herein, s/he was of legal age and was not a party to this action; Documents Served: the undersigned attempted to serve the documents described as: Notice of Sheriffs Sale of Real Property Service of Process on: The undersigned attempted to serve the documents on Sun Chon,aka Sun Yi Chan and after due and diligent efforts. was unable to effect service. Attempts: The following is a list of the attempts made to effect service: ltatesll'ime/Address Attempted: 227 Ewe Road,Mechanicsburg,PA 17055 I 091,1"a'aCl y-S 2 Pry) Reason for Non-Ser•ice:Po t3 Er cul-si.L2✓esti:4A 1 1 f Uates/Timc/AddressAttempted: aal wt.Ito t t11',+t_t. C11J GS6L.41) ,Pt/'7•I70S� rPs/ial mi'i-3:5 1 PM ,I Reason for NonSenice:�o cterso.t.fr cd- t-k5 reSlt(rte e• A �rkt.tsit'.S5 card was a354ed 'b fie.grerrtt S hatesiTime/AddressAttempted:."- __e.! •, h►' �.A• ---� PI 0 $- �e ' Reason for Non-Senice:)uv ctft5teef ci 4kkg- re c/%L.e.tT'R-61u't5S r-ex't"d. & o.3 tertyu foSKfI-th...La t erKAStS• Based upon the above stated facts,Affiant believes the defendant is avoiding service. Signature of Server: Undersigned declares under penalty of perjury Subscribed and sworn to before me this that the foregoing is true and correct. i 1 -clay of ,20fj Ot/I rl00 it Signature of Server Notay ublic (Commission Expires) APS International, Ltd. COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Brittany Edcius.Notary Public Lower Paxton Township.Dauphin County My commission expires April 11,2018 Service of Process by Deutsche Bank National Trust Company,ns Trustee,et.al.. �-—� APS International, Ltd. Pinintiff(s) VS. 1-800-328-7171 Chang Chon aka Chang Mun Chon.et.al.,Defendant(s) jNTERNXTtONAL APS International Plaza 7800 Glenroy Road • - Minneapolis.MN 55439-3122 APS File it: 131327.0001 AFFIDAVIT OF DUE AND DILIGENT ATTEMPT Service of Process on: UDREN LAW OFFICES -Chang Chon,aka Chang Mutt Chon Ms.Henni Crommam Court Case No.Cumberland Co 14-4858-Civil 1 11 Woodcrest Rd.,Ste.200 Cherry Hill.NJ 08003-3620 Customer File: N14030267-I - - - - State of: flS(it.11LLill0. )ss. - - - - - - - - - - - .1 County of: ".e to ) Name of Server: C.rlcwl R-s .undersigned.being duly sworn.deposes and says that at all times mentioned herein,s'he was of legal age and was not a party to this action: Documents Served: the undersigned attempted to serve the documents described as: Notice of Sheriff's Sale of Real Property Service of Process on: The undersigned attempted to serve the documents on Chang Chon,aka Chang Mun Chon and after due and diligent efforts. was unable to effect service. Attempts: The following is a list of the attempts made to effect service: UateammelAddrecs Attempted: Chon's Karate-22 Colonial Park Mall.Harrisburg,PA 17109, 01(30b-c IL( Ifl.'CX'ilWt Reason for NumSen•irer11/10 x'100:'5 toP.//_Io(Y?rI fund M one t 1. r'CPnJ. L h ipitsuucc howl (Or-1Pd. moon's Ka.r0.1c-a . Colonies!. Porte a+4ti, o sb ,P4 Dates/Time/Address Attempted: Lila'a to/0alt-oi'4 a4 ,p:SS PM Reason for Non-Service-rho- Subjlrt S lxoj% .0 S4+9.1.-ea( S eta lon 1^0.$ AO 1olStNesS 04.4,"€r 4 Dates/Time/Address Attempted: Reason forNon-Service: Based upon the above stated facts,Affiant believes the defendant is avoiding service. Signature of Server: Undersigned declares under penalty of perjury Subscribed and sworn to before me this that the foregoin tru and orrect. lL day of �1 . 20 t_� 0'di 11201 x Signature of Server Not, Public (Commission Expires) APS International, Ltd. COMMONWEALTH OF PEN!.SYLV.AMA NOTARIAI.SEAL Brittany Edcius.Notary Public Lower Paxton Towmhip.Dauphin County My commission expires April 11,2018 EXHIBIT B Affidavit of Good Faith Investigation At the request of the taw firm identified below I initiated an investigation into the whereabouts of the defendant identified as the subject below. The following is true and accurate representation of my investigation. Client provided information: File Number: 14030267-1 Attorney/Law Firm:UDREN LAW OFFICES, P.C. (PA) Subject Name:CHANG CHON A/K/A CHANG MUN CHON Property Address:Street:227 Ewe Road City: Mechanicsburg State: PA Zip: 17055 Skip Results:Date of Birth: 1959 ProVest File Number:4101563 Last Known Address(as of 9/23/2014)Street:227 Ewe Rd City:Mechanicsburg State: PA Zip: 17055 4875 Death Record Search As of 09/23/2014,the Social Security Administration has no death record on file for Chang Chon a/k/a Chang Mun Chon. Social Security Number [X]Verifed []Not Verified SSN#XXX-XX-XX80 Employment Search Chon's Karate Business Records Search Chon's Karate 22 Colonial Park Mall, Harrisburg, PA 17109 Chang Chon Owner Creditor Header Inquiry The latest address from the credit header info is: Address: 227 EWE RD, MECHANICSBURG, PA 17055 4875 Department of Motor Unable to obtain Motor Vehicle Records in the State of Pennsylvania. Vehicle Records Search* Drivers License Information Search No verifiable information. ]Govemmental**+ M Non-governmental Professional Licenses Search No records found. Freedom Of Information Act Inquiry FREEDOM OF INFORMATION ACT INQUIRY MADE TO U.S. Made to U.S.Postal Service POSTAL SERVICE: THE FOLLOWING ADDRESSES WERE SENT TO THE UNITED STATES POSTAL INSPECTOR AT THE ZIP CODE LISTED WITH NO RETURN INFORMATION TO DATE: 227 EWE ROAD 1 MECHANICSBURG I PA1 17055 I CUMBERLAND COUNTY Military Search Not on Active Duty; Did not leave Active Duty within the past 367 days; Has not been notified of a future call up to Active Duty Inquiry of Relatives, 717-761-4407: Spoke with possible neighbor,Don Hartman, does not Neighbors,&Friends know defendant. 717-763-4708: Called possible neighbor, Stephanie Enck, answering machine answered,no message left. Comments: 717-975-3688: Called number listed to defendant, Chang Chon, number has been disconnected A search of Federal Bureau of Prisons resulted in no records for our defendant. A search of Pennsylvania Department of Corrections resulted in no records for our defendant. Our defendant was not found to be currently incarcerated searching Pennsylvania County Jails. EXHIBIT C A search of Philadelphia Prison Systems resulted in no records for our defendant. *Data not available in AL,AR,CA,HI,NH,OR,PA,VA,WA."Historical data in CO,DE,ID,IL,KY,LA,MD,MA,MS,MO,NH,ND, SC,WV. +Data available in CO,CT,DE,FL,ID,IL,KY,LA,ME,MD,MA,MI,MN,MS,MO,NH,ND,OH,SC,TN,TX,WV,WI,WY. The foregoing statement is true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Under penalties of perjury,I declare that I have read the foregoing affidavit and that the facts stated in it are true. • STATE OF FLORIDA COUNTY OF HILLSBOROUGH t.P '2 4 2014 Gianna Hernandez ProVest File Number 431 Sworn to or affirmed and signed before me on this—day of Provest Services LLC (( (Seal) Date: ° ` I zy 2a�� -�-- JOSHUA N,PIMENTEL Signato ei Notary Public,State of FIodde (J My Comm.Expires May 24,2015 No.EE 97050 — Printed Name of Notary Public Personally Known ( )Produced as identification Affidavit of Good Faith Investigation At the request of the law firm identified below I initiated an investigation into the whereabouts of the defendant identified as the subject below. The following is true and accurate representation of my investigation. Client provided information: File Number: 14030267-1 Attorney/Law Firm:UDREN LAW OFFICES, P.C. (PA) Subject Name:SUN CHON A/K/A SUN YI CHON Property Address: Street:227 Ewe Road City: Mechanicsburg State: PA Zip: 17055 Skip Results: Date of Birth: 1961 ProVest File Number:4101563 Last Known Address(as of 9/23/2014)Street: 227 Ewe Rd City: Mechanicsburg State: PA Zip: 17055 4875 Death Record Search As of 09/23/2014,the Social Security Administration has no death record on file for Sun Chon a/k/a Sun Yi Chon. Social Security Number [X]Verifed[] Not Verified SSN#XXX-XX-XX52 Employment Search CHON MOTEL ENTERPRISES, INC. Business Records Search Name CHON MOTEL ENTERPRISES, INC. Current Name Business Corporation-Domestic- Information Entity Number:3145001 Status:Active Entity Creation Date:5/21/2003 State of Business.: PA Registered Office Address:227 EWE RD MECHANICSBURG PA 17055- Cumberland Mailing Address: No Address Officers Name:SUN VI CHON Title: President Address:227 EWE RD MECHANICSBURG PA 17055-4875 Name:SUN VI CHON Title: Secretary Address:227 EWE RD MECHANICSBURG PA 17055-4875 Name: SUN VI CHON Title:Treasurer Address:227 EWE RD MECHANICSBURG PA 17055-4875 Creditor Header Inquiry The latest address from the credit header info is: Address:227 EWE RD, MECHANICSBURG, PA 17055 4875 Department of Motor Unable to obtain Motor Vehicle Records in the State of Pennsylvania. Vehicle Records Search* Drivers License Information Search No verifiable information. []Govemmentai'"+ [X]Non-governmental Professional Licenses Search No records found. Freedom Of Information Act Inquiry FREEDOM OF INFORMATION ACT INQUIRY MADE TO U.S. Made to U.S. Postal Service POSTAL SERVICE: THE FOLLOWING ADDRESSES WERE SENT TO THE UNITED STATES POSTAL INSPECTOR AT THE ZIP CODE LISTED WITH NO RETURN INFORMATION TO DATE: 227 EWE ROAD I MECHANICSBURG I PA( 17055( CUMBERLAND COUNTY Military Search Not on Active Duty; Did not leave Active Duty within the past 367 days; Has not been notified of a future call up to Active Duty Inquiry of Relatives, 717-761-4407: Spoke with possible neighbor, Don Hartman, does not Neighbors,&Friends know defendant. 717-763-4708:Called possible neighbor, Stephanie Enck,answering machine answered,no message left. Comments: 717-975-3688: Called number listed to defendant, Sun Chon, number has been disconnected. A search of Federal Bureau of Prisons resulted in no records for our defendant. A search of Pennsylvania Department of Corrections resulted in no records for our defendant. Our defendant was not found to be currently incarcerated searching Pennsylvania County Jails. A search of Philadelphia Prison Systems resulted in no records for our defendant. 'Data not available in AL,AR,CA,HI,NH,OR,PA,VA,WA."Historical data in CO,DE,ID,IL,KY,LA,MD,MA,MS,MO,NH,ND, SC,wV. +Data available in CO,CT,IDE,FL,ID,IL,KY,LA,ME,MD,MA,MI,MN,MS,MO,NH,ND,OH,SC,TN,TX,WV,WI,WY. The foregoing statement is true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unswom falsification to authorities. Under penalties of perjury,I declare that I have read the foregoing affidavit and that the facts stated in it are true. STATE OF FLORIDA SEP 24 2014 EQQi Akad►i p COUNTY OF HILLSBOROUGH Gianna Hernandez ProVest File Number: 63 Sworn to or affirmed and signed before me on this_day of Provest Services LLC /.� (Seal) Date: 1I2L.4\2V`4+. JOSHUA n4 PIMEN EL Notary Public,State of Florida Signatures blic My Comm.Expires May 24,2015 �.Sign 1J No.EE 97050 Printed Name of Notary Public ersonally Known ( )Produced as Identification 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 as Trustee for Saxon Asset Securities Trust CIVIL DIVISION 2007-4,Mortgage Loan Asset-Backed CUMBERLAND County Certificates, Series 2007-4 Plaintiff NO. 14-4058 Civil v. Chang Chon a/k/a Chang Mun Chon; Sun Chon a/k/a Sun Yi Chon; ET AL Defendant(s) MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule the plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. NOTE: A sheriffs return of"not found" or the fact that a defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). Notice of intended adoption mailed to last known address requires a "good faith effort" to discover the correct address. Adoption of Walker, 468 Pa. 165, 360 A2d 603 (1976). An illustration of a good faith effort to locate the defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and employers of the defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As set forth in the Returns of Service marked Exhibits "A" and "B" the Sheriff and/or Process Server has been unable to serve the following Defendant(s) at their last known addresses. A good faith effort to discover the whereabouts of the Defendant(s) has been made as evidenced by the attached Affidavit of Good Faith Investigation marked Exhibit "C". WHEREFORE, Plaintiff prays and respectfully requests service of the Notice of Sale upon Defendant(s)by regular mail and certified mail, and by posting the mortgaged premises. UDREN LAW OFFICES, P.C. BY: (:)/a-t_J Attorneys for Plaintiff Nicole LaBlella, Esquire VERIFICATION The undersigned hereby states that he/she is the Attorney for the Plaintiff in this action, that he/she is authorized to make this Verification, and that the statements made in the foregoing MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of his/her knowledge, information and belief . The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C. S . Sec 4904 relating to unsworn falsification to authorities . Date: / � I b—/ 5 I UDREN LAW OFFICES, P .C. BY: Qi if Attorneys for Plaint Nicole LaBiea, Esquire 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 as Trustee for Saxon Asset Securities Trust ! CIVIL DIVISION 2007-4, Mortgage Loan Asset-Backed CUMBERLAND County Certificates, Series 2007-4 Plaintiff NO. 14-4058 Civil v. Chang Chon a/k/a Chang Mun Chon; Sun Chon a/k/a Sun Yi Chon; ET AL Defendant(s) CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was served by U.S. mail on each of the attached parties or their attorneys this 15TH day of October, 2014. Udren Law Offices, P.C. Attorney for Plaintiff By: GA\AU Nicole aBIetta, Esquire SERVICE LIST CUMBERLAND COUNTY, PENNSYLVANIA CCP.No. Docket Number: 14-4058 Civil NAME: CHANG CHON A/K/A CHANG MUN CHON MAILING ADDRESS: 227 EWE ROAD MECHANICSBURG, PA 17055 NAME: SUN CHON A/K/A SUN YI CHON MAILING ADDRESS: 227 EWE ROAD MECHANICSBURG, PA 17055 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL TRIAL DIVISION Deutsche Bank National Trust Company, as Trustee for Saxon Asset Securities Trust 2007-4, Mortgage Loan Asset -Backed Certificates, Series 2007-4 Plaintiff v. Chang Chon a/k/a Chang Mun Chon; Sun Chon a/k/a Sun Yi Chon; ET AL Defendant(s) NO. 14-4058 Civil ORDER N7 AND NOW, this ZD` day of oc-P3124 , 20 Y , upon consideration of Plaintiffs Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale on Defendant(s), Chang Chon a/k/a Chang Mun Chon, Sun Chon a/k/a Sun Yi Chon, shall be complete when Plaintiff or its counsel or agent has served true and correct copies of the Notice of Sale by posting the mortgage premises at: 227 EWE ROAD MECHANICSBURG, PA 17055 (73 o , --4 C) C) -1 CD" CD rrl 373 "" And by mailing by certified mail and regular mail to the last known address of Defendant(s) as follows: CHANG CHON A/K/A CHANG MUN CHON 227 EWE ROAD MECHANICSBURG, PA 17055 SUN CHON A/K/A SUN YI CHON 227 EWE ROAD MECHANICSBURG, PA 17055 fiL.4Lerr_L N. 17�L�lar /o/ c0 y BY THE COURT: y 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 Saxon Asset Securities Trust 2007- 4, Mortgage Loan Asset -Backed Certificates, Series 2007-4 Plaintiff v. CHANG CHON A/K/A CHANG MUN CHON, SUN CHON A/K/A SUN YI CHON, Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-4058 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 serviceon 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 mad . the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to author' • Dated: MJU#: 14030267 CASE#: 14030267-1 BY: Att s _ s for Plaintiff David Neeren, Esquire PA ID 204252 UDREN LAW OFFICES, P.C. WOODdREST CORPORATE CENTER 111 WO6DCREST ROAD, SUITE 200 CHERR'( HILL, NJ 08003-3620 856-669-400 pleading udren.com Deutsche Bank National Trust Company, as Trustee for Saxon Asset Securities Trust 2007-4, ortgage Loan Asset -Backed Certific tes, Series 2007-4 J. Plaintiff United States of America Chang hon a/k/a Chang Mun Chon Sun Ch n a/k/a Sun Yi Chon Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-4058 Civil AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 Deutsche Bank National Trust Company, as Trustee for Saxon Asset Securities Trust 2007- 4, Mortg ge Loan Asset -Backed Certificates, Series 2007-4, Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date tie Praecipe for the Writ of Execution was filed, the following information concerning the real pifoperty located at: 227 Ewe Road, Mechanicsburg, PA 17055 1. Name nd address of Owner(s) or reputed Owner(s): Chang Cion a/k/a Chang Mun Chon 227 Ewe itoad Mechanicsburg, PA 17055 Sun Choi a/k/a Sun Yi Chon 227 Ewe itoad Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: United States of America C/o Peteil J. Smith, Esq., U.S. Attorney for the Middle District of PA, 228 Walnut Street P.O. Box 11754 Harrisbu g, PA 17108 Chang Chon a/k/a Chang Mun Chon 227 Ewe Road Mechanicsburg, PA 17055 Sun Chon a/k/a Sun Yi Chon 227 Ewe Road Mechanicsburg, PA 17055 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Lower Allen Township 120 Limekiln Road New Cumberland, PA 17070 Lower Allen Township 2233 Gettysburg Road Camp Hill, PA 17011 County of Cumberland c/o Keith O. Brennerman, Esquire 44 West Main Street Mechanicsburg, PA 17055 Alpha Consulting Engineers, Inc. c/o Law Offices of Robert M. Walker, LLC 3810 Market Street, Suite B Camp Hill, PA 17011 County of Cumberland, Office of the Solicitor 1 Courthouse Square, Room 208 Carlisle, PA 17013 Lower Allen Township Authority c/o Steven P. Miner, Esquire 635 North 12th Street, Suite 101 Lemoyne, PA 17043 Susquehanna Bank c/o Rhoads & Sinon, LLP One South Market Street, 12th Floor, P.O. Box 1146 Harrisburg, PA 17108-1146 Susquehanna Bank SBMT Graystone Bank 112 Market Street Harrisburg, PA 17101 Woori America Bank 7400 Front Street Cheltenham, PA 19012 Woori America Bank c/o Hartman Shurr 1100 Berkshire Boulevard, Suite 301 P.O. Box 5828 Wyomissing, PA 19601 4. Name and address of the last recorded holder of every mortgage of record: Deutsche Bank National Trust Company, as Trustee for Saxon Asset Securities Trust 2007- 4, Mortgage Loan Asset -Backed Certificates, Series 2007-4 1661 Worthington Road Suite 100 West Palm Beach, FL 33409 Sr Mortgage Holders - None Jr Mortgage Holders - None 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 Tenant/ Occupants 227 Ewe Road Mechanicsburg, PA 17055 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: United States of America US Attorney, US Department of Justice 228 Walnut Street, P.O. Box 11754 Harrisburg, PA 17108 Internal Revenue Service Technical Support Group, William Green Federal Building 600 Arch Street, Room 3259 Philadelphia, PA 19106 Attorney General of U.S. US Department of Justice, Room 5111 Main Justice Building, 10th & Constitution Ave., NW Washington, DC 20530 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: II/ IlJiq MJU#: 14030267 CASE#: 14030267-1 UDRE B Atto or Plaintiff David Neeren, Esquire, PA BD 204252 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 eutsc e an ationa rust onlpany, as Trustee for Saxon Asset Securities Trust 2007-4, Mortgage Loan Asset -Backed Certificates, Series 2007-4 Plaintiff v. UNITED STATES OF AMERICA; CHANG CHON A/K/A CHANG MUN CHON; SUN CHON A/K/A SUN YI CHON; Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-4058 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S): CHANG CHON A/K/A CHANG MUN CHON; SUN CHON A/K/A SUN YI CHON; PROPERTY: 227 Ewe Road, Mechanicsburg, PA 17055 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on 12/03/2014 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#: 14030267 CASE#: 14030267-1 EXHIBIT A Name Address of of Sender and Henrietta Crommarty UDREN LAW OFFICES, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 C p ri Registered Insured COD Certified n Return Receipt for Merchandise n Int' I Recorded Del. n Express Mail Check appropriate block for Registered Mail: n With Postal Insurance [1 Without postal Insurance stamp here if issued as addi icateconal ofmailingor for additional copies of this bill. Poshrrarkand Date ofReceipr Line An'cle 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 MalCumberland County Real Estate Tax Department 1 Courthouse Square, Carlisle, PA 17013 Cumberland County Domestic Relations Section 13 North Hanover Street, Carlisle, PA 17013 of PA, Department Revenue EMICommonwealth of Bureau of Compliance, PO Box 281230 Harrisbur_, PA 17128-1230 4 14-4058 Tenant/ Occupants 227 Ewe Road, Mechanicsbur, PA 17055pODC/iFsT Internal Revenue Service Technical Support Group, William Green Federal Building 600 Arch Street, Room 3259, Philadel rhia, PA 19106 I IP cEP �s" yx 6 12/03/2014 Attorney General of U.S, h. eth US Department of Justice, Room 5111 Main Justice Building, 10th & Constitution Ave., NW Washin• on, DC 20530 m t n. hry« 'gr 04 3 00 USA, US Attorney, US Department of Justice oo © 228 Walnut Street, P.O. Box 11754, Harrisburg, PA 17108 ,� 1i o 8 Lower Allen Township 120 Limekiln Road, New Cumberland, PA 17070 Q ch o 1. o m 9 County of Cumberland c/o Keith O. Brenneman, ©" Esquire 44 W. Main Street, Mechanicsbur_•, PA 17055ME0 . 10 Alpha Consulting Engineers, Inc. a N o 0 c/o Law Offices of Robert M. Walker, LLC 3810 Market Street, Suite B, Camp Hill, PA 17011 Susquehanna Bank c/o Rhoads & Sinon, LLP t•�T . r+,. lialE One South. Market Square, l2's Fl., P.O. Box 1146, Harrisbu :, PA 17108-1146 i t++_�re•':,1? •I, t.. ' J. + Cumberland County, Office the Solicitor of 1 Courthouse Square, Room 208, Carlisle, PA 17013 lf BIMLower Allen Township c/o Steven P. Miner, Esquire 635 North 1271 Street, Suite 101, Lemoyne, PA 17043 X 14 Alpha Consulting Engineers, Inc. 115 Limekiln Road, New Cumberland, PA 17070 MIENLower Total AIIen Township 2233 Gettysburg Road, Camp Hill, PA 17011 number of Pieces Listed by Sender 1 J C Total Number es Received ost Office Postm. er, Per (Nr 7�. ��� Employee) The full declaration of aion of nonnego $500,000 per occurrence. $25,000 for registered coverage on insured and value is required on all domestic and international registered mail. table documents under Express Mail document reconstruction insurance The maximum indemnity payable on Express Mail merchandise is mail, sent with optional postal insurance. See Domestic Mail Manual COD mail. See International Mail Manual for limitations of coverage The maximum is $50,000 $500. The R900, S913, on international indemnity per p ece maximum indemnity and S921 mail. payable far the subject to a limit of payable is for limitations of Special handling charges apply only to third and forth class parcels, PS Form 3877, February 1994 Form Must be Com r leted b Typewriter, Ink or Ball Point Pen Chang Chon a/k/a Chang Mun Chon - MJU# 14030267-1 (Cumberland County) Sun Chon a/k/a Sun Yi Chon - MJU# 14030267-1 (Cumberland County) 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 Merchandise Intl Recorded Del. ❑ Express Mail Check appropriate block for Registered Mail: g ❑ With Postal Insurance ❑ Without postal Insurance Affix stamp 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 Susquehanna Bank sbm to Graystone Bank 112 Market Street, Harrisburg, PA 17101 2 3 1p 4 144058 N . T /o 5 12/03/2014 ‘.TAGEii PITNEY BOWES ams arimmit 8003 $ 001.30° 1387090 SEP. 05. 2014. 03 7 8 9 10 1�1 11 ca 12 13 X LU 14 15 Total number of Pieces Total Number of Pieces Postmaster, Per (N, n • . • iving L tployee) The full declaration of value is required on all domestic and international registered mail The maximum indemnity payable for the Mail document insurance is $50,000 to limit of Listed by Sender 1 Received at Post Office % / / /� / reconstruction of nonnegotiable documents under Express reconstruction per p ece subject a $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 011 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. PS Form 3877, February 1994 �� Form Must be Completed by Typewriter, Ink or Ball Point Pen Chang Chon a/k/a Chang Mun Chon - MJU# 14030267-1 (Cumberland County) Sun Chon a/k/a Sun Yi Chon - MJU# 14030267-1 (Cumberland County) Name and Address of Sender Henrietta Crommarty UDREN LAW OFFICES, P.C. 111 Wooderest Road, Suite 200 Cherry Hill, NJ 08003 Ell Registered n Insured Ell COD ri Certified Return Receipt for Merchandise n Inti Recorded Del. Express Mail Check appropriate block for Registered Mail: El With Postal Insurance 0 Without postal Insurance Affix stamp certificate of additional copies Postmark and Due Sender If COD here if issued mailing of this Date of R.R. FeeFee as or for bill. Receipt S.D. S.H. Fee Rst. Del, Fee Remarks Line Article Number Name of Addressee, Street, and Post Office Address Postage Fee Hand ing Charge Act. Value (If Regis.) Insured Value 1 14-4058 Woori America Bank c/o Hartman Shurr 1100 Berkshire Boulevard, Suite 301, P.O. Box 5828o Wyomissing, PA 19610 coo 0 2 Woori America Bank 7400 Front Street Cheltenham, PA 19012 ,•0 ca us it co i ' 3 12/03/2014 CD 0 , g t 1 CO `4, ss , . W 0 : i i 1C4 08 .---------- La i 0 a) 0o 6 F•-• el 0 o --- 7 o 0- No ' 1. • r . • 1 • :me: , 51 . • 'Aft 71:& ' 5 • Nei :CA. 10 V ' ..'. 1,1 co 1....11 M 12 X LLI 13 14 15 Total number of Pieces Listed by Sender 2 Total Number of Pieces Received a ' Poser, Pe ante of Receiving Employee) The full declaration of value is required on all domestic andinternational registered maiL The maximum indemnity payable for the reconstruction of nonnego iable documents under Express Mail document reconstruction insurance is $50,000 per piece 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, S913, and $921 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. PS Form 3877, February 1994 Form Must be Completed by Typewriter, Ink or Ball Point Pen Chang Chon a/k/a Chang Mun Chon - MJU# 14030267-1 (Cumberland County) Sun Chon a/k/a Sun Yi Chon - MJU# 14030267-1 (Cumberland County) Udren Law Offices, P.C. Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 HAC (PA -3129) #14030267-1 1,1\!11,191!11!1\241.,1 USA, US ATTORNEY, US DEPARTMENT OF JUSTICE 228 WALNUT STREET, P.O. BOX 11754, HARRISBURG, PA 17108 U.S, POSTAGE >> PITNEY BOWES wt. =mon I/mm=1:mm. • ei visainr AMIN!. ZIP 08003 $ 005.130 02 1V1 0001387090 SEP 05. 2014 Udren Law Offices, P.C. Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 HAC (PA -3129) #14030267-1 1 11 11 11 1 111 1 1 111 11 1 91 7199 9991 7034 2538 7250 ATTORNEY GENERAL OF U.S. US DEPARTMENT OF JUSTICE, ROOM 5111 MAIN JUSTICE BUILDING, 10TH & CONSTITUTION AVE., NW WASHINGTON, DC 20530 U.S. POSTAGE >> PITNEY BOWES vP.5rad==0 ZP08003 $ 005.1:30 02 1101 0001387090SEP. 05 2014 Udren Law Offices, P.C. Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 HAC (PA -3129) #14030267-1 rt. 11 II 11 • 1 91 7199 9991 7034 2538 7243 INTERNAL REVENUE SERVICE TECHNICAL SUPPORT GROUP, WILLIAM GREEN FEDERAL BUILDING 600 ARCH STREET, ROOM 3259, PITILADELPHIA, PA 19106 U.S. POSTAGE >> PtTNEY BOWES 1.•17.93., ZIP 0800.3 $ 005.130 02 1I'Y 0001387090 SEP 05. 2014 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin s s udren.com Deutsche Bank National Trust Company, as Trustee for Saxon Asset Securities Trust 2007-4, Mortgage Loan Asset -Backed Certificates, Series 2007-4 Plaintiff v. UNITED STATES OF AMERICA, CHANG CHON A/K/A CHANG MUN CHON, SUN CHON A/K/A SUN YI CHON, Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County MORTGAGE FORECLOSURE NO. 14-4058 Civil VERIFICATION OF SERVICE OF NOTICE OF SALE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he or she is counsel for Plaintiff in the above case and that pursuant to the court order issued in this matter a true and correct copy of the Notice of Sale was sent by certified mail and regular first class mail as follows: TO: CHANG CHON A/K/A CHANG MUN CHON 227 EWE ROAD, MECHANICSBURG, PA 17055 SUN CHON A/K/A SUN YI CHON 227 EWE ROAD, MECHANICSBURG, PA 17055 DATE MAILED: October 24, 2014 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: November j' , 2014 MJU#: 14030267 CASE#: 14030267-1 EXHIBIT B David Neeren, ESno� PA 8D 20 252 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL TRIAL DIVISION Deutsche Bank National Trust Company, as Trustee for Saxon Asset Securities Trust 2007-4, Mortgage Loan Asset -Backed Certificates, Series 2007-4 Plaintiff v. Chang Chon a/k/a Chang Mun Chon; Sun Chon a/k/a Sun Yi Chon; ET AL Defendant(s) NO. 14-4058 Civil ORDER AND NOW, this ZO' day of o ls..r , 20 a Y , upon consideration of Plaintiffs Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale on Defendant(s), Chang Chon a/k/a Chang Mun Chon, Sun Chon a/k/a Sun Yi Chon, shall be complete when Plaintiff or its counsel or agent has served true and correct copies of the Notice of Sale by posting the mortgage premises at: 227 EWE ROAD MECHANICSBURG, PA 17055 -41 rn� 0m , —+ c 771• Orn And by mailing by certified mail and regular mail to the last known address of Defendant(s) as follows: CHANG CHON A/K/A CHANG MUN CHON 227 EWE ROAD MECHANICSBURG, PA 17055 SUN CHON A/K/A SUN YI CHON 227 EWE ROAD MECHANICSBURG, PA 17055 Co y fiLater.L k). /6/ iy EXHIBIT B BY THE COURT: y Udren Law Offices, P.C. Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 HAC (PA -3129) # 14030267-1 CERTIFIED if L 91 7199 9991 7034 1908 8217 SUN CRON A/K/A SUN YI CHON 227 EWE ROAD MECHANICSBURG, PA 17055 1•51 U.S. POSTAGE* PITNEY BOWES ZIP(38°°3 $ 005.130 02 111 00013870900CT 24. 2014 Udren Law Offices, P.C. Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 HAC (PA -3129) # 140302674 11 ll 11 1u 11 91 7199 9991 7034 1908 8200 CHANG CHON A/K/A CHANG MUN CHON 227 EWE ROAD MECHANICSBURG, PA 17055 U.S. POSTAGE *PITNEY BOWES /111=.2W11 M A INIIIMMin=f vommum..amear ZIP 08003 $ nna 410 021V 1161 0001387090 OCT 24. 2014 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 Saxon Asset Securities Trust 2007-4, Mortgage Loan Asset -Backed Certificates, Series 2007-4 Plaintiff v. CHANG CHON A/K/A CHANG MUN CHON, SUN CHON A/K/A SUN YI CHON UNITED STATES OF AMERICA Defendant(s) TO: ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DWISION Cumberland County MORTGAGE FORECLOSURE NO. 14-4058 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY Sun Chon a/k/a Sun Yi Chon 227 Ewe Road Mechanicsburg, PA 17055 Your house (real estate) at 227 Ewe Road, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriffs Sale on 12/03/2014 at 10:00 A.M. at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $194,787.80, 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 fmd 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 stoic 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.) EXHIBIT B 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. lithe 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 EXHIBIT E UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings a�?udren.com Deutsche Bank National Trust Company, as Trustee for Saxon Asset Securities Trust 2007-4, Mortgage Loan Asset -Sacked Certificates, Series 2007-4 Plaintiff v. CHANG CHON A/K/A CHANG MUN CHON, SUN CHON A/K/A SUN YI CHON UNITED STATES OF AMERICA Defendant(s) TO: ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FQRECLOSURE NO. 14-4058 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY Chang Chon a/k/a Chang Mun Chon 227 Ewe Road Mechanicsburg, PA 17055 Your house (real estate) at 227 Ewe Road, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriffs Sale on 12/03/2014 at 10:00 A.M. at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $194,787.80, 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 SHERIFFS SALE To prevent this Sheriff's 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.) EXHIBIT B YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHI RIFF'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 fmd 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 Ltherty Avenue Carlisle, PA 17013 (800) 990-9108 EXHIBIT E3 Name and Address of Sender Henrietta Crommarty UDREN LAW OFFICES, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 L E ii Registered Insured COD Certified Return Receipt for Merchandise n Int'! Recorded Del, Lil Express Mail Check Registered Ej [I] appropriate block for Mail: With Postal Insurance Without postal Insurance Affix stamp here if issued as certificate of mailing or for additional copies of this bill. Postmark and Date o Recei#t Line Article Number Name of Addressee, Street, and Post Office Address Postage Hand ing 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 14-4058 Chang Chon a/k/a Chang Mun Chon 227 Ewe Road Mechanicsburg, PA 17055 MEI 2 Sun Chon a/k/a Sun Yi Chon 227 Ewe Road Mechanicsburg, PA 17055 Mill111111.11 3 12/03/2014 r: immum 4 = 5 6 ntwAi arrlin 03 $ 70901 7 8 1- 9 CO 10 11 12 M MEIMEMEMIIIMMINEMINIM 13 14 IMEMINIMMIENIIMIMINEMII 11111111111111111111.1111111111111 15 M1.1.1 11=1.11111 111=11=1..=MEMIIIMMINII Total number of Pieces Listed by Sender Total Num of Pieces Receive at Po Office PostmastrPt.n1eof Receiving Employee The flatl deciaration of value is required on all domesticinternational reconstruction of nonnego fable documents under Express Mail $500,000 per oc.eurrence. The maximum indemnity payable on registered tl. The maximum mdetnnity payable for the document reconstruction insurance is $50,000 per piece subject to a limit of Express Mail merchandise is $500. The maximum indemnity payable is 2 $25,000 for registered rnail, sent with optional postal insurance. See Domestic Mail Manual R900, S913, and S92I 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. PS Form 3877, February 1994 Form Must be Completed by Typewriter, Ink or Ball Point Pen Chang Chon a/k/a Chang Mun Chan - MJU# 14030267-1 (Cumberland County) Sun Chon a/kJa Sun Yi Chon MJU# 14030267-1 (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 Saxon Asset Securities Trust 2007-4, Mortgage Loan Asset -Backed Certificates, Series 2007-4 Plaintiff v. CHANG CHON A/K/A CHANG MUN CHON; SUN CHON A/K/A SUN YI CHON; et al ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 14-4058 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. f Date: f t /`1 IIt1 EXHIBIT B UDREN L BY: Att . e 'or Plaintiff David Neeren, Esquire PA ID 204252 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL TRIAL DIVISION Deutsche Bank National Trust Company, as Trustee for Saxon Asset Securities Trust 2007-4, Mortgage Loan Asset -Backed Certificates, Series 2007-4 Plaintiff v. Chang Chon a/k/a Chang Mun Chon; Sun Chon a/k/a Sun Yi Chon; ET AL Defendant(s) NO. 14-4058 Civil ORDER AND NOW, this 2d` day of off/ , 20 Y , upon consideration of Plaintiffs Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale on Defendant(s), Chang Chon a/k/a Chang Mun Chon, Sun Chon a/k/a Sun Yi Chon, shall be complete when Plaintiff or its counsel or agent has served true and correct copies of the Notice of Sale by posting the mortgage premises at: 227 EWE ROAD MECHANICSBURG, PA 17055 And by mailing by certified mail and regular mail to the last known address of Defendant(s) follows: CHANG CHON A/K/A CHANG MUN CHON 227 EWE ROAD MECHANICSBURG, PA 17055 SUN CHON A/K/A SUN YI CHON 227 EWE ROAD MECHANICSBURG, PA 17055 irisLL . LzL a� EXHIBIT B BY THE COURT: • beutsche Bards National Trust Company, as Trustee. et. al., Plaintiff(s) vs. Chang Chon aka Chang Mun Chon, et. al., Defendant(s) UDREN LAW OFFICES Ms. Henni Crommarty 111 Woodcrest Rd.. Ste. 200 Cherry Hill, NJ 08003-3620 State County of: Name of Server: Date/Time of Service: Place of Service: Documents Served: Service of Process on: Person Served. and Method of Service: Description of Person Receiving Documents: Signature of Server: R1 ) ss. 1:14r1C ) Chi) Service of Process by APS International, Ltd. 1-800-328-7171 APs tNIERNATIONAL 1 APS International Plaza 7800 Glenroy Rd. Minneapolis, MN 55439-3122 APS File ti: 131786-000I AFFIDAVIT OF SERVICE -- Individual Service of Process on: --Sun Chon, aka Sun Yi Chon by posting Court Case No. Cumberland Co 14 -4058 -Civil -W\ undersigned. being duly sworn, deposes and says that at the time of service. s/he :as of legal age and was not a party to this action: that on the a y of 460e ( . 20A . at lto'clock at 227 Ewe Road the undersigned served the documents described as: Notice of Sherifrs Sale of Real Property w/ Order , in Mechanicsburg. PA 17055 A true and correct copy of the aforesaid document(s) was served on: Sun Chon, aka Sun Yi Chon by posting —I By personally delivering them into the hands of the person to be served. By delivering them into the hands of . . a person f suitable age. who verified, or who upon question' ated, that he/she resides with Sun Chon, aka Sun Yi Chon by posting at the place of service, and whose relationship to the person is: The person receiving documents is described as follows: Sex • Skin Color • Hair Color : Facial Hair Approx. Age ; Approx. Height : Approx. Weight f my knowledge and belief. said person was not engaged in the US Military at ne of se ice. d decl res tinder regain is true and Under that th erjury Subsc d an (9 before me this .. r 0 V Signature o ,er S International, Ltd. 1 at . A NOTARIAL SEAL 'Tannin L Crutchor, NOtafy Public Cirinile Boro, Cumberland County Commlsion Expires Sept. 9,2015 P NNSYLAlit t ic41 ommission Expires) EXHIBIT B 'Deutsche Bank National Trust Company. as Trustee, et. al., Plaintiff(s), vs. Chang Chan aka Chang Mun Chon, et. al., Defendant(s) UDREN LAW OFFICES Ms. !tenni Crommarty I l 1 woodcrest Rd.. Ste. 200 Cherry Hill, NJ 08003-3620 State of. -S )\) County of: Name of Server: Date/Time of Service: Place of Service: Documents Served: Service of Process on: Person Served. and Method of Service: Description of Person Receiving Documents: Signature of Server: e ACP, c` Ak Vit, APS t\TEANATION4L Service of Process by APS International, Ltd. 1-800-328-7171 APS International Plaza 7800 Glenroy Rd. Minneapolis, MN 55439-3122 APS File #: 131786-0001 AFFIDAVIT OF SERVICE -- Individual Service of Process on: --Chang Chon, aka Chang Mun Chon by posting Court Case No. Cumberland Co 14 -4058 -Civil at at the time of service that on the at 227 Ewe Road d yo s undersigned. being duly sworn. deposes and says ras of legal age and was not a party to this action: _ 14C19k 20 1'4' at t. . �.:�o'clock M the undersigned served the documents described as: Notice of Sheriffs Sale of Real Property w/ Order • to Mechanicsburg, PA 17055 A true and correct copy of the aforesaid document(s) was served on: Chang Chon, aka Chang Mun Chon by posting By personally delivering them into the hands of the person to be served. delivering them into the hands of 5—i -1A suitable agewho verified, or who upon C a ed, . a person , of questioning that he/she resides with Chang Chou, aka Chang Mun Chon by posting at the place of service. and whose relationship to the person is: The person receiving documents is described as follows: Sex ; Skin Color : Hair Color ; Facial Hair Appr'.. Age : Approx. Height : Approx. Weight knowledge and be f. said person was not engaged in the US Military at servicl1. declares under pe ing I rue and c Subscribed and swo f APS International, Ltd. H NOTARIAL SEAL Public Tammie L. Crotchet, Notary pu2015 Carlisle Boro, Cumber S oand Sept 9, untyo A les My Commission, 8 ot:rAtto , F PENNS EXHIBIT B Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY ~~~~ 71 ot Deutsche Bank National Trust Company vs. Chang Chan a/k/a Chang Mun Chan (et al.) Case Number 2014-4058 SHERIFF'S RETURN OF SERVICE 09/29/2014 02:11 PM - Deputy Shawn Gutshall, being duly sworn accoringkx|ow.obab»soemicewosperfonnedby posting a true copy of the requested ReaEstate Wr, Notice and Description, and Sale Handbill in the above titled action, upon the property Iocated at 227 Ewe Road, Lower Alien Township, Mechanicsburg, PA 17055, Cumberland County. 09/29/2014 02:11 PM Deputy Shawn Gutshall, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personaily handing a true copy to a person representing themselves to be Chang Chon, Husband, who accepted as "Adult Person in Charge for Sun Chon a/k/a Sun Yi Chon at 227 Ewe Rd., Lower Allen Twp., Mechanicsburg, PA 17055, Cumberland County. 09/28/2014 02:11 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personaily handing a true copy to a person representing themselves to be the Defendant, to wit: Chang Chon a/k/a Chang Mun Chon at 227 Ewe Rd., Lower Allen, Mechanicsburg, PA 17055, Cumberland County. SHERIFF COST: $987.54 SO ANSWERS, October 16, 2014 RONN R ANDERSON, SHERIFF �.LX'-rLIKT 3 11c) CountySwle meriff, Telaosu/� UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 eadin s s udren.com Deutsche Bank National Trust Company, as Trustee for Saxon Asset Securities Trust 2007-4, Mortgage Loan Asset -Backed Certificates, Series 2007-4 Plaintiff v. United States of America Chang Chon a/k/a Chang Mun Chon Sun Chon a/k/a Sun Yi Chon Defendant(s) CERT ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-4058 Civil FICATE OF SERVICE The undersigned hereby certifies that true and correct copies of the Notice of Sale were served upon the following Defendant(s) named herein by: Regular First Class Mail ® Certified Mail Date Served: September 5, 2014 TO: United States of America C/o Peter J. Smith, Esq., U.S. Attorney for the Middle District of PA, 228 Walnut Street, P.O. Box 11754, Harrisburg, PA 17108 MJU#: 14030267 CASE#: 14030267-1 EXHIBIT B UDAW OF IC S,. B : Atto yfir' PIaintiff � — ir David Neeren, Esquire PA SD 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 Saxon Asset Securities Trust 2007-4, Mortgage Loan Asset -Backed Certificates, Series 2007-4 Plaintiff v. CHANG CRON A/K/A CHANG MUN CHON, SUN CHON A/K/A SUN. YI CHON' UNITED STATES OF AMERICA Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-4058 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: United States of America C/o Peter J. Smith, Esq., U.S. Attorney for the Middle District of PA, 228 Walnut Street P.O. Box 11754 Harrisburg, PA 17108 Your house (real estate) at 227 Ewe Road, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriffs Sale on 12/03/2014 at 10:00 A.M. at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $194,787.80, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take Immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. You may able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) EXHIBIT B Udren Law Offices, P.C. Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hi IL Ni 08003-3620 LUC (PA -3129) #14030267-1 91 7199 9991 7034 2538 7274 UNITED STATES OF AMERICA, C/O PETER J. SMITH, ESQUIRE, U.S. ATTORNEY FOR THE MIDDLE DISTRICT OF PA 228 WALNUT STREET, P.O. BOX 11754 HARRISBURG, PA 17108 JOINIMMEM 4:311=1, ZIP 08003$ 005.1 3° 02 1r1 00013870 0 SEP 05. 2014 Name and Address of Sender Henrietta Crommarty UDREN LAW OFFICES, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 ri 0 n 0 Registered Insured COD Certified (—I Li Return Receipt for Merchandise F7 Infl Recorded Del. Express Mail Check appropriate block for Registered Mail: Fl With Postal Insurance LI Without postal Insurance Affix stamp here if issued as certificate of mailing or for additional copies of this bill. Postmark and Date o Rece' Line Art'cle 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. S.D. Fee Fee S.H. Fee Rst. Del. Fee Remarks 1 United States of America, c/o Peter J. Smith, Esquire U.S. Attorney for the Middle District of PA 228 Walnut Street, P.O. Box 11754 Harrisbur,. PA 17108 111111111111 lailillill cr, III 4 14-4058 IIIMIIIIIIIIIIIIIIIIIIII 00.3 ;cc'c) ilMIMIIIIIIIIIIIIIIIIIIIIIIIIIIIIII . I 6 12/03/2014 MI IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII 8 IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII l' 910 EIIIIIIIIIIIIII 1111 1.1.1111111111111 111111112111' 13 14 IIIIIIIIIIIIIMIIIIMMIIII. 15 Total number of Pieces Listed by Sender 1 Total Number of Pieces Received at Pos Office Postmaster, Per N. , e ofRceivin: toployee) s The MI declaration of value is required on all domestic and reconstruction of nonnego iable documents under Express Mail 5500,000 per occurrence. The maximum indemnity payable on $25,000 for registered mail, sent with optional postal insurance. coverage on insured and COD mail. See International Mail Manual charges apply only international registered mail. The maximum indemnity payable for the document reconstruction insurance is $50,000 per p'ece subject to a limit of Express Mail merchandise is $500. The maximum indemnity payable is See Domestic Mail Manual R900, S913, and S92I for limitations of for limitations of coverage on international mail. Special handling to third and forth class parcels. PS Form 3877, February 1994 ./rm Mustbe Completed by Typewriter, Ink or Ball Point Pen Chang Chon a/k/a Chang Mun Chon - MJU# 14030267-1 (Cumberland County) Sun Chon a/k/a Sun Yi Chon - MJU# 14030267-1 (Cumberland County) UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin s s j ud Deutsche Bank National Trust Company, as Trustee for Saxon Asset Securities Trus 2007-4, Mortgage Loan Asset -Backed Certificates, Series 2007-4 Plaintiff v. UNITED STATES OF AMERICA CHANG CHON A/K/A CHANG MUN CHON SUN CHON A/K/A SUN YI CHON Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-4058 Civil NOTICE OF THE DATE OF CONTINUED SHERIFF'S SALE The Sheriffs Sale scheduled for December 3, 2014 at 10:00 AM in the above -captioned matter has been continued until February 4, 2015 at 10:00 AM. Date: ( 4k,'6`i; i, MJU#: 14030267 CASE#: 14030267-1 UDREN LAW OFFICES, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 (856) 669-5400