HomeMy WebLinkAbout06-1459GOLDBECK McCAFFERTY & McKEEVER
BY: JOSEPH A. GOLDBECK, JR.
ATTORNEY I.D. #16132
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
(215) 825-6318
W W W.GOLDBECKLAW.COM
ATTORNEY FOR PLAINTIFF
DEUTSCHE BANK NATIONAL TRUST COMPANY, FOR
THE BENEFIT OF THE CERTIFICATEHOLDERS OF
MORGAN STANLEY ABS CAPITAL I INC.
7105 Corporate Drive
PTX B-35
Plano, TX 75024-3632
Plaintiff
vs.
SALLY J. MILLER
Mortgagor and Real Owner
402 West Main Street
Walnut Bottom, PA 17266
Defendant
Term
No. 0? -/?/ 59 l lui
`V ;,_ ,4\C'TEON: MORTGAGE
CHFGL.G9URF
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages,
you must take action within twenty (20) days after the Complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further notice for any money claim in the Complaint
of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
AVISO
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS
QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE LISTED RESPONDA DENTRO
DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES
NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL
PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA
DEMANDA.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL
PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A
FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES
DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER
DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES.
USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN
ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA
PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO.
SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE
INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS
ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT
A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you
still may be able to SAVE YOUR HOME FROM FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-
9400 or.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling.
3). Visit HUD'S website www.hud.eov for Help for Homeowners Facing the Loss of Their Homes.
4). Call the Plaintiff (your lender) at 800-641-4978 and ask to speak to someone about Loss Mitigation
or Home Retention options.
5). Call or contact our office to request the amount to bring the account current, or payoff the mortgage
or request a Loan Workout / Home Retention Package. Call Beth at 215-825-6329 or fax 215-825-6429. The
figure and/or package you requested will be mailed to the address that you request or faxed if you leave a
message with that information. The attorney in charge of our firm's Homeowner Retention Department is David
Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of
CWD-5788.
Para infonnacion en espanol puede communicarse con Loretta at 215-825-6344.
This Action of Mortgage Foreclosure will continue unless you take action to stop it.
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is DEUTSCHE BANK NATIONAL TRUST COMPANY, FOR THE BENEFIT OF THE
CERTIFICATEHOLDERS OF MORGAN STANLEY ABS CAPITAL I INC., 7105 Corporate Drive,
PTX B-35 Plano, TX 75024-3632.
2. The name and address of the Defendant is SALLY J. MILLER, 402 W. Main Street, Walnut Bottom, PA
17266-9718, who is the mortgagor and real owner of the mortgaged premises hereinafter described.
On October 01, 2004 mortgagor made, executed and delivered a mortgage upon the premises hereinafter
described to DECISION ONE MORTGAGE, which mortgage is recorded in the Office of the Recorder
of Deeds of Cumberland County as Book 1884, Page 3202. The mortgage has been assigned to:
DEUTSCHE BANK NATIONAL TRUST COMPANY, FOR THE BENEFIT OF THE
CERTIFICATEHOLDERS OF MORGAN STANLEY ABS CAPITAL I INC. by assignment of
Mortgage, which has been lodged for recording. The Mortgage and assignment(s) are matters of public
record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure
1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those
documents are matters of public record.
4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit
"A" ("Property").
5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid
for October 11, 2005, and each month thereafter and by the terms of the Mortgage, upon default in such
payments for a period of one month, the entire principal balance and all interest due and other charges
are due and collectible.
6. The following amounts are due to Plaintiff on the Mortgage:
Principal Balance
Interest from 09/11/2005
through 03/31/2006 at 7.9000%
Per Diem interest rate at $20.60
Reasonable Attorney's Fee at 5% of Principal Balance as
more fully explained in the next numbered paragraph
Late Charges from 10/11/2005 to 03/31/2006
Monthly late charge amount at $34.89
Costs of suit and Title Search
Monthly Escrow amount $214.25
$95,194.59
$4,161.20
$4,759.73
$209.34
$900.00
$105,224.86
If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less
than the amount demanded based on work actually performed. The Attorney's Fees requested are in
conformity with the Mortgage and Pennsylvania law. Plaintiff reserves its right to collect Attorney's
fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party
purchaser at Sheriff s Sale or if the complexity of the action requires additional fees in excess of the
amount demanded in the Action.
8. Plaintiff is not seeking a judgment of personal liability (or and "in person am' judgment) against the
Defendant in this Action but reserves it's right to bring a separate Action to establish that right, if such
right exists. If Defendant has received a discharge of their personal liability in a Bankruptcy proceeding,
this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that
was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to
Pennsylvania law.
9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has
been sent to Defendant by certified and regular mail, as required by Act 160 of 1998 of the
Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s)
attached hereto as Exhibit "B". The Defendant has not had the required face-to-face meeting within the
required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant
through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit
Counseling Agency.
WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $105,224.86,
together with interest at the rate of $20.60, per day and other expenses costs and charges incurred by the
Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law
until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff s Sale of the Property.
By: U a,
GOLDB K ] *CAFFERTY & McKEEVER
BY: JOSEPH A. GOLDBECK, JR., ESQUIRE
ATTORNEY FOR PLAINTIFF
SCHEDULE C
PROPERTY DESCRIPTION
The land refenedlto In this Commitment Is described as follows:
ALL THAT CERTAIN tract of land with improvements thereon erected, situate. In South Newkin Township,
Cumberland Couarty, Pennsylvania, bounded and described as follows:
BEGINNING at a point at the Intersection of the Oakvlse Road; thence along the centerline of the said Wakwt
Bottom Road, South 04 degrees West, a distance of 212.5 feet to a point; thence along other lands now or
formerly of Fred Rosenberry, North 20 degrees 30 minutes West, a disfence of 143 feet to a stake: thence along
other lends now or fbmmrly of Rehoboth Community Center, North 72 degrees 35 minutes East, a distance of
207.5 foot to a point an the centerline of the sold Oakville Road, South 22 degrees 42 minutes Fast, a d1mance
of 114 foot to the point or place of BEGINNING.
This description id according to a survey made by T.L. Easier Registered Engineer, dated October 22, 1947.
HAVING thereon erected a two and one half story dwelling house.
Ccitify this to be recorded
1n Cumberland County PA
Recorder of Deeds
ALTA C01MMIMenr
solrmae c
(Mk US-K I)IMIt236,04.4
SKI 884PG32--t6
Eyt,.hibit B
tblR laws
VO Box 909E
Teele¢Ile, CA 92599-9048
Send Payments To:
PO BOX 660694
Dalas, TX 75266 0694
Send Correspondence to:
PO Box 5170, MS SV314 B
SMni Valley, CA 93065
inni?n?no
Sally J Miller
402 W MAIN ST
WALNUT BOTTOM, PA 17266-9718
05141=5rpen1
PRESORTED
First Class Mail
LLS Postage
and Fees Paltl
WSO
MCmnbyMdLw
HOME LOANS
P.O. Box 660694
Dallas, TX 75266.0694
Send Payments to:
PO Box 660694
Dallas. TX 75266-0694
December 12, 2005
Certified Mail:
0701IL89728
Return Reciept Requested
Regular Mail
Sally J Miller
402 W MAIN ST
WALNUT BOTTOM, PA 17266-9718
Account No.: 38270676
Property Address:
402 West Main Street
Walnut Bottom, PA
Current Servicer:
Countrywide Home Loans Servicing LP
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 EMERGENCY MORTGAGE ASSISTANCE PROGRAM IHEMAP) 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 30 DAYS OF
THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency.
This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit
Counseling Agency may be able to help answer them. 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 NOTIFICACI6N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR
VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACI6N OBTENGA UNA
TRADUCCI6N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN
CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU
CASA DE LA PERDIDADEL DERECHO A REDIMIR SU HIPOTECA.
ORIGINAL LENDER:
CURRENT LENDEPJSERVICER
Countrywide Home Loans Servicing LP
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND
HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
leale 11 e 1,1 .111 amber an allnear, e ad bou,,onderce.
We re,bho, yea a fee larany paymett return or reledxt by your M1rendal into Wan auyeato appumbis ew
. Make your check payable to Account Number. 38270676-0 Balance Due for charges listed above: $2.783.36 as af12112J2006.
Couneywide Home Lcans Sall JMiller
y
. Write your heacurenumber on
your check or money order 402 West Main Street Ppaaeoperhemall inion me ?,???ama a in'o mur
. Write in any additional amounts
aueim?al
you are indullnq Of total in
mare than $5000, ideate send Princyal
certified met aLQPal
. Wnl al your check to the tueiio?al
payment coupon Pscmr
. Oont include ea eaponaance
Countrywide
. Lanni send cash PO BOX 660694 finer
Dallas, TX 7 5 2 6 6-0 694
HOMEOWNER'S NAME(S): Sally J Miller
PROPERTY ADDRESS: 402 West Main Street
Walnut Bottom, PA
LOAN ACCT. NO.: 38270676
II??LI?I,?,LLII,„IL.II???II?I?L ??LJLL??I?J??IJIL?I
.l
Total
038270676000000278336000278336
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.
i ARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your
e for thirty (30) days from the date of this Notice . During that time you must arrange and attend a 'lace-to-face'
with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR
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. It&
property t d t forth at the d of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your are lenderjmmediately 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.) If you have tried and are unable to resolve this
problem with the lender, you have the right to apply for financial assistance from the Homeowners 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. Your application MUST be filed or postmarked within thirty (30) days of your
face-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER
TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY
AND YOURAPPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency
under the eligibility critena established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a
decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have
met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its
decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING
PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN
ATTEMPT TO COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property located at
402 West Main Street Walnut Bottom, PA
IS SERIOUSLY IN DEFAULT because
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now
past due
Monthly Payments: October, 2005 - January, 2006 (3 mos. @ $911.99/month) $2,735.97
Late Charges: October, 2005 - December, 2005 (2 mos. @ $34.89/mnnth) $69.78
Other Late Charges' Total Late Charges:
Uncollected Costs:
Partial Payment Balance:
TOTAL DUE:
YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable)
Wool
$0.00
($22.39)
$2,783.36
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 $2,783.36, PLUS ANY MORTGAGE PAYMENTS AND
LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD.
Payments must be made either by cashier's check, certified check or money de mad v ble and sent to:
E-mail use: PrmiJhg your a-coal address balm will allow as to send you information an your arrears
Al.,nt Number IV70676
SallyJ Miller Email address
How we post your payments: All assured
payments of princlpsl and interest will be applied m
the longest outstanding ineallment due, unless
otherwise expressly prullbltel or limited by law. If
you submit an amount in addition to your ormeQAetl
monthly amount. we will apply your payments se
folbws: (I) to outstanding monthly payments M
principal and matter, (II) escrow Falseness, it late
charges and other amemem you own is connection
with your loan and (N) to reduce the nations g
principal balance of your loan. Please speciN d you
want an additional amount applied to fubre
payments, rather than prlnci ail reducnon.
Postdated checks: Caontrywdle's policy is to rot
accept Profiles! emus, unless specifically ,.it
to by a loan counselor or tachdelan.
Countrywide at P.O. Box 660694, Dallas, TX 75266-0694
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 aoolicable)
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 (301 DAYS, the lender also intends to instruct its attomeys 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 attorneys 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.
under the mortgage
The lender may also sue you personally for the unpaid principal balance and all other sums due
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 Sheriff's 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
mortgage property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual
date of the Sheriff's 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: Countrywide Home Loans Servicing LP
Address: P. O. Box 660694 Dallas, TX 75266-0694
Phone Number: 1-800-669-0102
Fax Number: 1-805-577-3432
Contact Person: MS PTX-36
Attention,- Loan Counselor
EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and
your right to occupy it. If you continue to live in the property after the 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 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 UNDERTHE MORTGAGE DOCUMENTS.
TO ASSERTANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER.
TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
Your loan is in default. Pursuant to your loan documents, Countrywide may, enter upon and conduct an inspection of your
0700689728
property. The purposes of such an inspection are to (if observe the physical condition of your property, (ii) verify that the
property is occupied and/or (iii) determine the identity of the occupant. If you do not core the default priorto the inspection, other
actions to protect the mortgagee's interest in the property (including, but not limited to, winterization, securing the property, and
valuation services) may be taken. The costs of the above-described inspections and property preservation efforts will be
charged to your account as provided in your security instrument.
If you are unable to cure the default on or before January 11, 2006, Countrywide wants you to be aware of various options that
may be available to you through Countrywide to prevent a foreclosure sale of your property. For example:
• Repayment Plan: It is possible that you may be eligible for some form of payment assistance through Countrywide.
Our basic plan requires that Countrywide receive, up front, at least Y' of the amount necessary to bung the account
current, and that the balance of the overdue amount be paid, along with the regular monthly payment, over a
defined period of time. Other repayment plans also are available.
• Loan Modification: Or, it is possible that the regular monthly payments can be lowered through a modification of the
loan by reducing the interest rate and then adding the delinquent payments to the current loan balance. This
foreclosure alternative, however, is limited to certain loan types.
• Sale of Your Property: Or, if you are willing to sell your home in order to avoid foreclosure, it is possible that the sale
of your home can be approved through Countrywide even if your home is worth less than what is owed on it.
• Deed-in-Lieu: Or, if your property is free from other liens or encumbrances, and if the default is due to a serous
financial hardship which is beyond your control, you may be eligible to deed your property directly to the Noteholder
and avoid the foreclosure sale.
If you are interested in discussing any of these foreclosure alternatives with Countrywide, you must contact us immediately. If
you request assistance, Countrywide will need to evaluate whether that assistance will be extended to you. In the meantime,
Countrywide will pursue all of its rights and remedies under the loan documents and as permitted by law, unless it agrees
otherwise in writing. Failure to bring your loan current or to enter into a written agreement by January 11, 2006 as outlined above
will result in the acceleration of your debt.
Time is of the essence . If you have any questions concerning this notice, please contact Loan Counseling Center immediately at
1-800-669-0102.
APPWDIX C
PENNSYLVANIA HOUSING FINANCE AGENCY
HOMEOWNERS EMEROENCYMORTGAGE ASSISTANCE PROGPAM
CONSUWP" 4MTT , MNS9 NG AGENCIES _ , ..
ADAMS CDVNTY
Armed Red Cross -Hanover Chapter
529 Ca1819 Street
Hanover, PA 1733f
Ph: 717-837-3768
f-ac 717.637-3294
ARMSTRONG COUNTY
CCCS of Western PenrrysNania Inc.
217 E. Prank Road
Altoona, PA 16602
Ph: 6149448100
Ph: 814-944-5747
CCCB d Western Pennyslvania, Inc.
217 E. Plank Road
Altoona, PA 16602
Ph; 814 944 8100
Faz 6114044,5743
FA, Ipll tr-e ja1113 ?',i:nnl:t5 vi i iN iM1iln
31 West a Sing
Waynesboro, PA 17286
Ph: 717-7623285
CCCS d Waslem PA
2080 Linglestovn Road
Hartlsosg, PA 17102
Ph: 717-541-1757
Ph: 717-541-4670
Adams County Housing Authority
139-143 Ca1s4s St
Gettysburg, PA 17325
PR 717-3341518
Fm 717.3348326
ALLEGHENY COUNTY
NaunNvaMaHHUSIng Flinarrce Agency
(Madre Hail
2275 Swalov H9 Road
BAlding 280
POtsbLnh,PA 15220
Pit 412-429-2842
Fax 412-429-2835
Action Flousing, Inc.
426eAVenua
Well
PMSbugh.PA 15219
Ph: 412.391-1956
PIE 412-281-2102
Poe 800-792-2801
Fax 412-:91-4512
CC( a d Western Pwmylvani4 Fnc.
309 Srldhfield areal
PM~. PA 15222
Ph: 412-4T7 7584
Urban league d Rhsburgh
Ratline to Equd Oppo: only
OnaS'r1iiU1vfeu Strew
F81.1hW%PA 15222-2222
Rc 412-7-4-4W2
Far, 412-2615207
mon,veb6y Urtenviam Cornmktes
120 E.9° Avenue
HenWitai0, PA 15120
PM. 412.462-9962
CrIC01111 ad PA
401 Wand Steel
Sellow
Pl6ebuil PA 16222
Pi. 412338-9954
Ph: 800731-2933
FM 4123384953
Comma ityAdbn Southwest
22 West High Street
WalyrwasbULg,PA 15370
PR 724852-2893
Herdrlg OpPOMMIX63
133 Sellil Street
PoslOECe BOZ9
McKeeapal, PA 15132
Ph: 412664-1908
Fez: 412-W,14 0873
Credil Caunst4ot8 M PA
401 Wood Slrml
Suile4306
FiltSturgi PA 15222
Ph: 412.3389954
Ph: WO-737.2933
F. 412-338.9963
Weal Crenmunily Action PrOgram
827 Water Street
Blot 167
lod ne, PA 15701
Ph: 724-465-2651
Fat: 724.465-5118
BEAVER COUNTY
Action Hmsing, Inc,
425 6" Avenue
Suite 950
Pittsburgh, PA 15219
M. 412-3314956
Fan 412.391.4512
Routing Oppoaonilies of Beaver Co., Inc.
650 Carporaion Slreel
Suite 207
Beaver, PA 15009
Ph: 724428-7511
Cre3t Couaekxs of PA
401 Woad Sbad
Sole 980
Pittsburgh, PA 15222
Ptt 412-3389961
PIK 800737-2933
Far 412.3389963
Mm-Valley tAwragoyed Commihee
120 E. 0 Averpre
Honlaskad, PA 15120
Pit 412-4629962
Ptc 412-462-9964
Houswy Oppurtun)er_s Inc.
133 Seventh Sh l
Post Owe Bmr 9
McKeesport. PA 15134
Phc 412-6641906
Fare 412-6640673
BEDFORD COUNTY
sedwdfulbon Housing Services
10211 Line* FghWay
Evatat, PA 16537
Ptr, 814623.9129
Fac 814623-7187
KeysanaECOlanb Development
Corpar06an
1954 Mary Grace Lane
Jelvft vm, PA 15%1
Ptr 814535-0556
Far 8145394688
wealthimizeft office
917 Milllin Street
Iteit116don, PA 16652
Ph: 814543-2343
Talleland Services, Inc.
5435 East mail) Street
SCmel5el, PA 15501
Ph: 81.1-4469628
Pit 806452-0148
Fare 814-443-369D
BERKS COUNTY
Budget Counserng Censer
247 North Filth Street
Beadplg, PA 19601
Ph: 610575.7888
Far. 611637$.7630
ECcruvrlic Opportunity Cabinet V Schuylkill
225 N Centre Street
Polkvilla, PA 17901
Ph: 717$224995
Fax 717.622-0429
CCCS of Lehigh Valley
3671 Crescml Court East
Whitehall, PA 10052
Ph: 610821-4011
Ph: 0W-220-2733 (814 only)
Fan 610821-6932
Coninnoi'y Housing Counselor, Inc-
Post0lime"244
Kerneh Square, PA 19348
Pk 6104443682
Fax 670444412-43
GLAIR COUt4TY
Sedlwd{dWrF Housing Services
I'll 1, OWMA
Ebaelq PA 15537
Ph: 814623-9/gg
Far 8t482b7167
CCCS d Western Penr vvmIa, Inc.
2171- Pla k Road
Afto PA 16602
Ph: 814-944-8100
Flt 8144445747
Keystone Ecortarnic Develapenent Corp.
1954 May Grace Isle
Johnslomal 18001
Ph: 514595 556
Far 814-539.1666
Wmpiatratext office
917 mm Sired
HuntirgdaO, PA 16652
Ph: 81484&2343
BRADFORD CDUM
CCCS of Nmheas%m Ponawyaria
1400 Abhgti et Emesudve Park
Supa 1
Oil Sunerilt PA 18411
Ph: 570587-9163
Ph: 8001022-8537
Fac 570587-9134
Fe c 570687-9135
31 W. Market Street
Wilkes-Barn. PA 18702
Ph. 570821-0837
Ph: 570922-9537
Far 570821-1786
9 South 7a Street
811o titibu .PA 19360
Pfr 8009224.'8 .
Fmc SW0420-MI
1631 S. ANkrton Street -
Suite 10.
State Celege, PA 16801
Ph: 814-23&3666
Fax 614138-3680
TheTrehati Cenrt al Northeastern PA
10 Publk: Avenue
Montrose, PA 18801
Ph: 570-M 332-
W W-9024045
Fax 570-278-1889
Gelman Street
Post Office (IM369
CUSIM , PA 18614
Ph: 570-928.9668
Fax. 570-928.8144
33 Walnut Street
Webb", PA 16901
Ph: 570-7243252
Fez 5704245783
185EYMrastred
Post ORU Box 218
Troy, PA 16947
W 570.297-2101
103 Warren Street
Post OIKcZBM709
Tunktuvwck, PA 18657
PM 570-0966840
Fax: 570-Mb-6332
931 Man Street
Honesdale, PA 18431
PM. M-253 8q,11
Faz 570253.4817
BUCKS COUNTY
Acorn fleeing Capa zaton
846 North NOW Street
Miedalpttie, PA 19130
PM. 215-765.122t
Fa, 215.7661427
Docks County Housing Group, Im.
140 East FAchmisort Avenue
La $aM PA 19D47
Flt 2116760-0310
Fac 215-7504318
KAZE
157 ~My AYenr^ 2 ° Fl=
Plx}adephia, PA 19140
Pk 215426-8025
re c 216428-9122
Caren may Development Corp. of
Frmktwd
46M Grimm Street
Phial VW PA 19124
Ph: 2167442990
Fac 2167442012
NMQ West Counseling Service
6001 North Broad street
Phgadetplda, PA 19141
Ph: 2153247500
Pete 215-324-8753
CCGSe1 Domere valley
1515 Market Street- Suite 1325
PhbdWta,PA 19107
Pk 215.563.5865
Fac 215864-2666
Tweet Cotta me valet'
405 ShtrygFad Center
To"% PA IOD47
1904ae1.
FU 2116 215
Plc 5836686
1111.1 1 1. IV
CCCS at Lehigh Valley
3671 Crescent Court East
Whitehall, PA 18052
Ph: 610-021-4011
Pn: 800-220-2733
Fax: 610.821-8932
C= of Western! PA
21MCVIM Perk Plans
4otMO^ PA 15904
Ph: 814.639,8335
-CCCS(*Wmlem PA
217 E. Plank Road
Altoona, PA 16602
Ph: 814-944-810D
Fen: 81419.14-5747
Amerie C e71 Court I' o Institute
845 Coates Street
(;-aVayvile, PA 19320
Ph: 888-212.6741
144E. Deka07 PMe
Kkg of Prussls, PA 19406
Ph: 610871,2210
Fax 6102664814
755 York Road
SWe 103
Warminster, PA 18974
Ph: 216444-9429
Far: 215-958-6344
BUTLER COUNTY
Action Housing, Inc.
425 fie Avenue
Sate 950
Pittsburgh, PA 15219
.Ph: 412391-1956
Ph: 412-281-2102
Housing Opportunities, Inc.
658Oonpwate Sl.
Suite 207
McKeesport, PA 15132
Ph: 412664-1590
Fac 412-664-04173
Housng Opporkmides, Inc.
133 Seventh Street
Post Omc¢ Box9
"imasport, PA 16134
Ph: 412-6641908
Fax 4112-W4-0873
CCCSd Western PA
YMCA Buid4g
339 IoM Weshington Street
Bu9e,PA Mitt
Ph: 724292.7812
Mr Varey Lloenployed Commklea
120 E9e AVa'ue
Homestead, PA 15120
Ph: 412-482-9962
Fat 412-482-9984
Crede Cesmek'M Of PA
401 WoM Street, Suits 806
PHISWgh, PA 152M
Pht 4123309954
Ph: 300737-2933
FM 412-33&9983
CAMBRIA COUNTY
Bedlottlfulim Housing Services
R.D. 1, 8%384
Everell, PA 15537
Ph: 814-623-9129
Fax 8146237187
htdiare C1y Community Action; Program
827 Weer Street. Box 187
Wave. PA 16701
Ph: 412-465-2857
Fat; 412-165.5118
Keystone Ecm Development Corp.
1054 Mary Grace Lane
Johnstwirn PA 15901
Ph: 814-51$6$$6
Fax: 8145:39-1tRIB
Tableland Services, Inc
535 East Main Street
Somerset, PA 15501
Ph: 814.445-9628
Ph: 5001452-0148
Fax 814.4433690
CAMERON COUNTY
NOIIWO Tor CawnUM13t Mum Corp.
Post Oboe Bmr 399
135 We 'ea, PA 15834
Ph: 814m, %1 61
Fea 81AM013 814.4880825
fsz
CCCS d Northeastern PA
1631 S. Afnenm Street
Spite 100
State CdlECe, PA 161301
Ph: 814-2383668
Fax: 814-2388669
CCCS d W astern PA
217 E. PWnk ROW
ABOOna, PA 16602
Phi 814-944-8100
Fee 814-944.5747
CAFIBON COUNTY
Eocd ScTroy" county
225 K Centre Street
Pottsville. PA 17901
M. 570-622.1095
Fax: 570-622-0429
CCCS(*LOdgh Ya4ey
3671 CreseritCaA East
Whitehall, PA 16052
Plc 610821-4011
Pte 800220.2733 (717 and 814 m1y)
r= 6108210137
CCCS of NmMastem PA
1400 AbbQW ExevVlNe Park
Suite 1
Clarks &aami6. PA 18411
Ph: 510.687.9163
Pot BDU 02-9537
Fax 670587-9134
Fez 670.597.9135
9 South 7" Street
Slwdslwrg, PA 18360
W. 6704268990
Ph: 8OD-922-9537
Fair 570420.9991
C6mmisson m Ecwexnic Opponur ity d
LOfarne County
163 Amber Late
Wi6cee0e44e, PA 18702
Ph: 570026-0510
Ph: 800822-0359
Fax: 5701129.1665-Callbefore faxing
Ph: 5704564994 - H=eltm
Fax 6704565631-Call beforefaxiN
Ph: 670836.4090-Tunkhannock
31 W. Mallet street CCCSOIDdpwrev27cy CCCSpIWeeteln PA
WBtm-B7n@, PA 16702 - 1515 AAGift8deet 21
? BkkgA
sule I= J
100). PA IM
.. PIU 81011mm5 PhiadeVk PA 10107 Ph 8441185385
. : Pure .570M-1785 .. .PR: 215 . .
Fat 215953.700 CLIAlTOH f?I1MY '
1031 &Afil xm ^xtre04 LYcoe'a<+9"CF'aon Counties
Stile tOD Cornmuruly Holaing Cwnseling Inc. Cennisslm hr Community Actlen (STEP)
Slate C033A PA 16801 Pas( Ollie 8mUt 2138 Lkv* Street
Ph: 8142383688 Kennett Square, PA 19348 Post C6te BM 1328
Far 814238.3669 Ph: 610.4443682 Wiplamnord,PA 17703
5ax. 610-44 8243 Ph: 570325.0587
CENTHECOUMY - Fax 570322-2197
CCCS of Western Pennsylvarro,Mc. Phia Council for CaMtelity Adv.
217 E. Plank Road IDD North 17°' 511nm r,CCs cd Plrthe nic ,
A nono, PA 16602 yuit'l 600 201 fl:vta Street
ph: 814-944-810o Ph Wulphia PA 19103 Vdrl nSporl, PA 11-703
Fax: 814944-5747 Ph: 215-567-7603 ph: 570.323-6627
Fax 215-9639941 Fax: 57"23 6626
Lycorning-CFnfw Co. Comm. For
Cormnur* Aam Cennurlily Development Corp of CCCS or WAheastem PA
(STEP) f noklool 1631 S Atherton SlteeL
2138 Lincnn Street Group "nistr'y Stile 100
Pmt Mice Bar 1328 4620 Griscorn Street Steta CcAege, PA 16801
WBIlarAspott-PA 17703 PNIadelpNa,PA t9124 Ph: 814-2363568
Ph: 570328-0587 Pf1: 216-74429M Fsx: 814-238.3669
Fax 576 3 22-2197 Fav: 215744.2012
COLUM8IA(%3UF11y
CCC5 of Northeastern FA -CCCS of Cdaware vales
?CCB al North a tom P. ?a ?:?
*31 S
1631 AlheAOn Blreet
& Atherton Street Marshall Raiding 31 W. MakM Street
Stile 100 790 E. Market Seael Past Ofts ft 1127
Scale College, PA 16801 SuR9215 Wilk(s-Barre. PA 18702
Ph: 814-238.3668 West Chester. PA 19302 Ph: 576821.0837
Fa: 6142383669 Ph: 215-5835655 PIT. Wll9%2.9537
Few. 570821-1785
CCCS of Northeastern PA American Crefi Co'mseAn2 lnsn'-le
201 Basis Street 845 Cowles Street Canmiss'IM on Eccromic Opportunity of
Williamsport, PA 17703 Coolesvnle, PA 19320 Laterite Canty
Ph: 570323-6827 Ph: 808-212-6741 163 Amber Lane
Fa: 570323-6626 WAkss Zene,PA 18702
144 E. Dekalb Pike M. s76a260510
CHESTER COUNTY Virg of Prussia PA 19406 Ph 80682&0359
Aoom Horsing Corporation Ph: 610.971-2210 Foe 5708241665 - Ca0 beforefaxing
845 Mana Broad Street Fax: 616265-4814 Pie 5764554994_Harelm
Pheadephia,PA 19130 Fax: 5701555631-W betee Im4ng
Ph 2167651221 755 York Road Ph: 576836-4090-Tunkhanmck
Far- 215765-1427 "a 103
WarMn.W. PA ID974 1400 Abiglon FSecoem Park
Belief Courlsefrlg Center Ph: 215 444-M Suite 1
247 North Fifth Street Fax: 21595663M Clerks Sumrrs3L PA 18411
Fieaft PA 19601 PIL 570987-9163
Ph 610375.7866 CLAMON COUNTY PW 800472-0537
Fex 215375.7830 CGCS d wmwm Perrc;vwmia)nc. Foe 670.567-0134
YMCA tk11KV Fax: 670967-9135
HALE 339 Nola Washington Street
AI W.Alboery Avelua Odder, PA 18001 CRAWFORD COUNTY
'C
Flow Ph: 412-282-7812 B~T. Wasltnglm Curler
PNlelebtdNPA 19140 1720 Haland Sired
Ptr 215^426-8025 CLEARSELD COUNY Ede, PA 16503
Fa: 215-4269122 Kirealo M Ecomndc Oeveopmem Pb: 814.4S35744
Cur Fec 814453-6749
Media Fellowship House r alone
302 S. Jackson Street Johnsmm PA 15901 Jahn F. Kennedy Curter, Inc.
Mate, PA 19063 Ph: 814-535-8556 2021 Earl M!O Street
Pip 810.566-0646 Forc 814-5361688 Erie, PA 10610
Fax 510'665'8587 Pk 814-99844M
CCCS of Weslem Pepnsytvank Inc. Fax $14-11911-1243
Tabor Cemrmlely Services, tic. 217 E. Plank Road
439 E. 1418 Street Alouna PA 16502 Gfceler Ede Cpmrnm8y Aclien CommAtee
Larlaester, PA 17602 Ph: 814944-8100 15 wage Steel
Pte 7173973182 Far. 814914-5747 Ede, PA 16601
PR 800-788.M(H.O. only) PD: 814.459.458t
Fa+c 7173904127 Indiana Go. Commuaty ACtim Fax 814458-0161
Prograp
Amerkaw Red Cross of Chester 827 Wale Street Snenorw valfey Urban League. Inc.
1729 EdgemgS Avenue Om 187 601 bb*m Avenue
CbMW, PA 19013 Indlarla, PA 16701 Farrel, PA 16121
Ptt: 510-8741484 Per. 724,465-2657 Or. 412-961-5310
Fax: 724-085-5118
Nordmest Cwmeing Services CUMBEFB.AND COUNTY
5001 H, Broad Sir CCCS of NoMeleaem PA CCCS of weslem Fennsylverue, Ina.
PleadelphiA PA 19141 1631 S. Atherton Street 2000 Un9lestaan Rwd
Ph: 2153244600 Stale 100 Furl. bum. PA 17102
Fax 215324-8753 Slate College, PA 16801 PR 717-541-1757
Ph: 814238.3668
Fax: 814-2383669
U A MoUcpofilan Hardsbutg
Haltahle9, PA 17101 ..
Ptc 717-234-W .
Fac 7V-234-9469 .
Comm iffy Action Cantu. of the Capital
Region
1514 Derry Street
Hardsbur9, PA 17104
Ph: 717-232-9757
Fac 717-234-2227
FlnanGa Counseling Services of Fronktm
31 WWIT'Shee1
?ag
Ph: 717-762.3,35
YWCA of Cadiste
301 G SUM
Caftle, PA 17013
Ph: 717.243-3818
Fax 717 73 1-96 80
Adams Ccuny Hosing Authony
139143 Carlisle Street
Gettyshtlrg, PA 17325
Ph 717534-1518
Fax 717-334-8326
DAUPHIN COUNTY
CCCS of WWlan Pennsylvania Inc.
2000 urdmlmvn Road
Handsbug,PA 17102
Ph: 717-541-1757
Fax 717.541-4670
Commuhly Action Gommissio, el the
Capital He en
1514 Derry Sheet
Hardsbum PA 17104
Ph: 717-232-9757
Fax: 717-234-2227
Urban L" m of Metropolilan Harrishurg
2107116 Street
HarraWr%PA 17101
Ph: 717-234-5925
Fax 717-2349459
DELAWARE COUNTY
Acorn Halting Corporation
846 we %Broad Street
PhAalelphl&PA 19130
Pik 21S-7631221
Floc 215.7651427
CCCS of Delaware Valley
1515 Markel Street
SLas 1825 -
PhiladepNA PA 19107
Phr 215-503-5665
Fat 215084-2660
- Met2a Felbwshp Hmse
3D2 S. krk3W Street
Mean. PA 19063
Ph: 6185650848
Fax 610-6658567
PhiladelpMa cmwu for Caniomiy
Adva wrest
100 North 17* Street
Suite am
Phdadelphle. PA 19103
Ph: 216587-7803
Fax 215963.9341
A7nekm Red Cross of Chester
1729 Edgnwnt Awma
Ch%tw,PA 19013
Ph: 6188744484
ACCI
173 SUBIW AVOW
&de 1
W%VA PA 19087
P1k 8188712210
Fat 313-BB7-7860
Nalhwesl Counseling Service
5001 North limed Birm
Phladelphia, PA 19141
Ph: 215.324-7500
Fax: 215-324 11753
HALE
167 W. Allegheny Ave., 27' Flan,
PhilaJd eg9na PA 1911,0
Ph: 215-426-6025
Fax 215426-9122
Coramnily Housing Counselor, Inc.
Past Office Bm244
Kennett Square, PA 19348
Ph: 610444-3602
Fax: 610.444-8243
cccsd Western PenllsyMx4a Inc.
1 GIaN1Qpg111+lare
. 2l?tdw CaReyDMe .. .
Cscaedpp, PA 15§01
.P1k 72YLCi&12A0 ,.
Tahidad Sere , Inc.
131 Nadu Center Avenue
Sotctnsel. PA 15501
Ph 814445-9628
Fec 814-443-3690
Mon Valley Iklemployed Commillee
120 E e Avenue
HOm25tead,PA 1512n
Ph: 412-462-9962
Ccm iy ActionSwlh,vesl
22 WWI High Street
Wayn%scU4PA 15370
Ph 7248524893
4620 Des4 Corp d Franklord
Group "nistry
Grail Iscm
Steel
Philadelphia, 19124
Ph: 215-h: 215-744--22900
Fax 215744-2012
CCCS of Delaware Valley
280 North Providence Road
mega, PA 19063
Ph: 215-563-5665
ACi
144 E. CekA Pke
Kin3 ol Prussia. PA 13105
Ph: "c 10971-2210
Pager. 610.9734219
ELK COUNTY
John F. K¢m,edy Carew. Inc.
Eas120e Street
Ede, PA 16510
PW 814 415 8 0 4 0 0
Fax: 814.898-1243
NoilhemT- r CmvnuNty Action Corp
2021
Post 016ce il=389
135 West a Shag
EMor m PA 15834
Ph: 814-1851181
F= 8144880825
PATE COUNTY
Beaker T. WWhkiglan Center
1720 HoMW Street
Erie, P0. 16503
Phc 814'1535744
Fat 814-4633749
John F. Karl" Center, Mc.
2021 Ewt a Street
Er(e,PA 16510
Ph: 8148980400
Fat 814-BW1243
G[Wier edo Cpmmwey Action
Committee
18 west 96 shoal
Erie, PA 1601
Plc 814-459-WI
Fax 814456.0187
FAME COUNTY
Ac5a1l-lmie19,Inc.
4258'AAvenue
S&9950
PlItsbugh, PA 15219
Ph: 412-391-1966
Pte 412-281-2102
Fax 412-391-4512
Fayette Cc Canrmmity Acticn Agency. Inc.
137 North Beeson Avenue
L1nkohl r, PA 15401
Fir. 724.437.60.50
Ph: 608427-NFO
Fax: 724437-4418
CCGSd Western PA
199 EdM Street
Uniontown, PA 15401
Ph: 724-4W-8939
FOREST COUNTY
IN armmFwwt Cw tics EC cynic
Oppoomly Counts
204 Liberty Street
PC6105(ce Box 547
WanaA PA 1636
PR 814-726-22400
Fax 8147218510
FRANKLIN COUNTY
Financial Services Unlimited
31 West e Street
Waynessbom PA 17268
Ph 717-762.3285
CCCSr4 Wwie n Permwirwia. Inc.
912SculhGeorge Street
York, PA 17403
Pic TiT-8454178
Comm* Actlm[krrunlWfort of 04alal
POOH
1514 Daly Sheet
H*rlbWeg. PA 17104
Pic 717-2329757
Fat; 717-2342227
CCCS of Western PA
20WLin mime" Road
Harrisburg. PA 17102
Pre 717541-1757
Fax 717341.4670
YWCA at Carlisle
301 G Street
C9T%I , PA 8913
Ph: 717-2433818
Fax 717-2433948
Amafcm Red Creel-flmrua Chapter
529 Cable Street
Hanover, PA 17331
Ph: 717637-3768
Fac 717837-3294
Umm w Of Metropolitan He9.
2107 K Sheet
Harc#Wug, PA 17101
Ph: 717-234-5925
Fac 717-234.9459
Ad= CMK4 I ouft AUthorlly W K%raOD OMOW9y ACWn Program LA C
139-149Cads(9187aet 827WdW8aeN,11x%T ?,??qmf?1r? nPanasvwanla
4968yshlag, PA 17315
.
.. Pte M3441618 P721-6 2 7
.. ..• Fax 7173344328 Fax 7244B651ti) Note ml 84W
' - New Cmk PA 16101
FULTpI COUNTY - CCCSof Westela PA M. 7244 SMM
f9et8adfhllan Horsing SWcm 210A COlup Park Plaza
R.D. 1, BOx 364 Johnsbrm, PA 15904 312 Chestnut Street
Everett, PA 16537 Ph: 8145395335 Stdt8227
Ph: 8145239129 Mea&Wle, PA iWS3 i
Fac 814.623-7187 JEFFERSON COUNTY Ph: 814333-8570
Jahn
Center, Inc.
CCCS ut Weelern Pennsylvania, Inc. St
2021 East East 20 2e 1 Street Shenargo Valley Urban League, Inc.
912 ScuN George Street Erie, PA 16510 fi01 Inuana Avenue
Yod:, PA 17403 Ph: 1148WWOO Farrdt,PA 16121
Ph: 7178464176 fan 81489&1243 Ph: 724981-5310
Financial CounsWrg Services d Franldm InIff"County C=ML"tY Action Housing OppodUniltes of Shaer County
31 West3 Street Program 658 Copwaeon St.
W ayneslgm, PA 11268 827 Water Sheet, Box 187 Suite 207
Ph: 717-762x285 Ind'iara PA 15701 Uearer,PA 15009
Ph: 724-465-2557 Ph: 724-728-7202
Weethefatlon Ollte Fax 724-065-5119 Fax: 724-729-7202
917MM61,W
tWnfingdon, PA 16652 CCCS a Wealem PenrvsyNanla. Inc. LEBANON COUNTY
Ph: 814.843-2343 YMCA &ddkg Ecaromip Opportunity Cabinet of Schuylkill
on Street
0
? NorM CM"
GREENE COUNTY PA 1
001 22
55 r4wm Carve,Street
AcUm Hot sing, Inc. Ph: 724-282-7812 Po11sWIA PA 17901
4256'e'Avemre Ph: 670.622-1995
SU08950 JUNIATACOUNTY Fax: 570622-0429
Pittsburgh, PA 15219 CCCS at Western PenesyNenia, Inc.
Ph: 412391-1955 217 E Plank Peed Tabor Comnxvuty Services, Inc.
Ph: 412-251-2102 Allomd PA 16602 439 E. IGn9 Street
Fax 412-391-4512 Ph: 8149/48100 Lancroslef,PA 17S42
Fax: 81411,W45747 Ph: 717091-5182
Commurily Aclian Scuthvasl Ph: 800488-5062
22 Wmt K9A Sheet WeaMenalion Office Fax: 717399-4127
Waynesburg. PA 15370 SIT hAtAn 6beta
Ph: 724-852-2393 HuntwXAw,PA IGF52 LEHIGH COUNTY
Far. 7 24 627-7 13 Ph: 814643-2343 CCCS d LeNgh Valley
3671 Crescent Caurl East
Moo-Valley Unemployed Committee LACKAWANNA COUNTY Whdehak PA 18052
120E-9°AVenue CCCS of 1,10'11 atem PennsvNara Ph: 570821-4011
1 bdwsietd, PA 15120 31 W. Minkel Shed Pn: 80M1220-2733 (717 and 814 eny)
Ph; 412-462-9962 Poet OMMOaot1127 Fac 610821-8932
Fe,c 412-4629964 WIMBB-Barte A 18702
Ph: 570-120837
P
vC Opportunity Gab(netq Schuylkill
CCCS Ed Weslem Pennsylvania, Inc. pt 80092
-9`u37 C-111,
?
1 Worth Gale Square Fax 6708241785 225
t"MCentre Street
2 Garda) Caller Odva PbAT^ PA 17901
GreeIAM PA 15601 }4Dpppingiop Executive Perk Ph: 570622.1995
PW.. 724-OM-1290 SURD 1 I= 67044-0429
CMdn S MM. PA 18411
HUNrWGOON COUNTY Ph WD-W-9163 LLMERNECOUNTY
Deflimmk tan Housng Services Pk W%95595V CCC4 of "I ftly l m Peqfx;Y
Narda
R.D. I, swam Fax: 570-SP-9134 31W.MaMc4Sbeet
EVOMM PA 16531 Fat 570587-9135 Post OMWBat1127
Pik 814-623-9129 Wika ilewre,PA 18702
Far: 814.629-7187 LANCASTER COUNTY Ph: 570821-0837
Comlrmn9y HmOM Counselors, PtK 800922-95ffi
WeallIaLta4on Ofr" Ircuporew Fat 570.821.1785
917 Wft Sheet Post Office ft 744
HurllkgdatPA 16652 KaeIS4lSquar4 PA 19948 }400AUz1Morr ESOKUlJvs Park
Ph: 814843-2343 Ph 2154449682 Sable t
Fax 215-4443178 CgMS SLIFFM m, PA 18411
CRS of Westem Poruls*arlla, Inc. PW 570567-9153
217 E. Plank Faad CCCS or Westem Peorsylvaia, Inc. Ph: 8009559537
A OOM PA IW42 91280M George Street Fat 570587-9134
Ph: 814-944-8100 York PA 17403 Fm 6 70 557 913 5
Fax 814944-5747 Pic 7178464176
Ccnmdssicn m Economla Opportunity d
U4D" COUNTY CCCS at Cetigh Ve" Luzeme Cnmly
CCCSO(Westem Pennsylvania, Inc. 3871 Crested Can East }63 AIMer larg
1 North Gale Square WDBdceI, PA 18052 Wilkes-Dame, PA 16702
2 (3min Center Drive Ph: 215-821-401} Ph: 6704260510
Greensburg, PA 15601 Ph 00022D-2733 (717 and 814 only) PR 800822-M
_ Ptt 72483&1290 Fat 2158218932 Fore 57087+1886- Call before faxing
Ph: 670455-4994- Hxxdton
Wryslana Ecofpmic Devyopment TaborCamxuily Services, Inc. FM 570-0565631- Cal before faxng
COP-AM 439 E MIS Street Ph: 5709364090-TWkhannoek
195417ary Grace Lane Lanceskr, PA 17602
JohnslowA PA 16901 Pb: 717397.5182 EOC Of SchuyMU Canty
PIK 8143366556 Ph. 690788.5062 225 North Centre Sheet
Fax 814539-1688 Fat 717-399-4117 Pottsville, PA 17901
Pic 5708224995
I Fax 5706228429
LYCOIM1dtel f>h6ellY4R COUNTY'
CCCSM Ndtll?lem PelraMuanln
.31 W.
Pc&0le17mt1127 .
- W*O8,MPAJS702' .
or
Pte 890 .
Fax 670821-1765
1400 Abington Executive Park
Suite 1
parks SVnmilt, PA 18411
Ph: 570-507-9163
Ph: 800-922.9537
Fax 570587-9134
Fax: 570807-9175
201 Basin Snreat
Wedanslwrt, PA 17703
Ph: 570-323.6627
Fac 570323-6526
tyCOrttinxJCe01an Counties Commission
far
Cormmwdly AC1ten (STEP)
2138 Lincoln Street
PWO15ce0ox 1326
WeeamsPorb PA 17703
Ph: 570.328-0597
Fax: 570-322-2197
McKgmeouN7Y
Joie F. Kennedy Center, Inc.
20121 Rise Skeet
Ede, PA 16510
Ph: 814.898-0400
Pax: 814.6901943
Northern Tier Cdnmumly Action Group
Past OMcatiox 389
135 W. a Street
Empuriurr4 PA 15834
Pit: 814-4864161
Fac 814486.8825
MERCER COUNTY
SkenalgoVal" Urban League. too.
601 Inolara Avaare
Farek PA 16121
Ph: 724-9613310
CCCS of Western PemsyNania, Inc,
YMCA%Aft
339 NaM Waghkngtgn Street
Buller, PA 16001
Pic 724282-7812
MIFFLIN (:OUM^Y
CCCS W Western Pennsylvania Inc.
217 E- Plonk PAW
ABcan& PA 16802
Im 814444917
Fax 814-9443747
CCCS of Northeastern Pennsylvania
16318. Albertan Street
Su90100
Sidle O* A PA 16801
Ah: 814238-3660
Fm 5142383668
Wealhedzialan Office
911 MM Sime
Huntingdon, PA 16652
Pk 814943-2343
MONROECOUNTY
CCCS 01 Norivalsten Pennsylvania
31 W. Make Street
Pcei 011100 Beat 1127
Wilke A%ff , PA 18702
Plc 670921-M
Ph: 800-m4537
Fa: 570521-17&5
9 SDUIIII PSheel
Stladahup,PA 10360 .
Ph 67 0-420 89 00
Ph W0422-9537
Fats 5711,4208AM
.. 1400Aligfon Executive Park
Suite 1
Clarks Summllt, PA 18411
Ph 570387-9163
Ph: 690822-9537
Fac 570-587-9134
Fax: 570.507-9136
Corm M Economic Opponuniny of
lu,enwCounty
163 Amber Lane
Wishes-Sarre, PA 18702
Ph 570928-0510
Ph: 800822-0359
Fax 570029.1665 - Call before taxing
Ph: 570-0554994 - Hazallm
Fax: 570.455-5631 - Cali before taxing
Ph 570-836-4090-Tunkha'mock
MONTGOMERY COUNT'
Acorn Housing Corporalion
846 North Broad Street
Phllaaephla, PA 19130
Ph: 216-765-1221
Fax: 2154654427
CCCS of Delaxare Valley
Mall mwl Buseass Cemear
190 W. Germantown Peca Suite 140
NOMSIOxn, PA 19401
Ph: 215.563-5665
CCCS d Delawa8 VaYeY
1515 Market Street, Suite 1325
Philadelphia, PA 19107
Ph: 215663.6665
Fax 215.8644666
NoN»mst Counseling Service
5001 N. Broad Skeet
RRad$Itda PA 19141
Pre 215324-75W
Fax 2153248763
Crvaawdy ACGan Development Comm
113 E Main Swed
Norristown, PA 19401
Hn 610277-6363
Fa 610277-2123
Camxnry Housing Counselors Inc.
PQia 0Ike BW 244
Kennett S"M PA 19348
P1: 2154445682
Fa 215448.8243
Media Fdbwship House
302 S. Jedregn Street
Meruq PA 19065
Ph, 610665-0846
(-mc 610.5656687
Phea Coupe for CermunityA W rant
100 Norm 171 Btred, suite 600
PhillO hie, PA 19103
Ph 2156677803
Fax 215963-9941
American Credit Counseling Institute
045 Cables St
Coatasulle, PA 19320
Fire 088.2128741
144 E. Oekalb Pike
Kingalftussfa PA 19406
Ph: 510971-2210
Fac 610-2"14
756Yek Plead
a" 103
Wamllste; PA 1874
PfC 216-4446428
Frio 215968-8344. .
MONT1NiR courB?Tr
GCGSd Ngrlheaste Pe nsv( aria
31 W. Maker Street
Post Olfxe Box 1127
Wilkes -Barra PA 10702
Ph: 570-821-0837
Ph: 606-92241537
Far: 570-821-1785
IAW Abing;an Executive Pixk
Suite I
parks Su'nmL, PA 18411
Ph: 5703979163
Ph: 600922-9537
Fax: 570507.9134
Fax 570387-0135
NORTHHAMPTON COUNTY
CCCS of Lobigh Valley
3871 018SCeat Cart East
Whitehall. pA 16052
Ph: 610-621.4011
Ph: 800.220.2733 (717 and 814 only)
Fax 616821-8932
NORTHUMBER ANO COUNTY
CCCS of Northeastern Pennsylvania
31 W. Markel Street
Post Office 8Ox 1127
Wtkes-8we, PA 18702
Ph' 570 621-08 37
Ph: 80 0. 922-95 3 7
Fax: 570821,1785
1100Abington Executive Pork
Suite 1
CPmkS Sumrrutt, PA 18411
Pir 570587-9163
Pit 800-922-9537
Fac 570587.9134
Fm: 570587-6735
201 Basin Strout
W91kerapOn,PA 17703
Ph: 570.123.6627
Far: 670323-0648
Economic Oppolkrmty CabinMd Schy948
County
225 Own, CeOre Street
POtlsvOa, PA 17901
Ph: 570-S22-1995
Fac 570-6229429
PERRYCOUNTY
CCCS of Western P"Sylvmla Inc.
2000 Lwdmtwm Read
Narisbut9, PA 17102
Ph: 717541-1757
Fax 717-641-4870
Urban of Metropolitan t(adshug
2107N,6 Sheet
Ha hSha9, PA 17101
Ph: 717234-6925
Fax: 717-234.9459
YWCAs Car5s10
301 B Skeet
Carlisle, PA 17013
Ph: 717-24"18
Fax: 717-243,'{948
Financlal Couseing Services of Franklin
31 Wes13' Street
WayneSbao,PA 17268
Ph: 717-7623285
WaaUr-alydion OOice
911 Mifflin Street
lkmlingdrn, PA 16652
Ph: 8149432343
Cw u * AdmComnlssion of The, MCIDM7Y SOMERM
pmom .
1 C=01NdBleaglsmPmnstAvida • BeglitidF446t4f Hwft Serpkm
,
. .. .15
1
Dow Street
W.??.trkel8heet
9
AA.t ew694
Har15MAg.PA 17104-. .. .. O1le PCk 1177
4 .eArAPA 17,33'7 ..
.. PIV 717-2MV57 W PA 18702 PW 814623-9129
- - Fax 717/1342221
.. .. P1V 570821-083/ Fax 814-623.7187
Mr. 800-922.9537
PHILADELPHlACOUNTY Fax 570421.1785 CCCS of W%tem Pennsybnuta, Inc.
Acorn Rousing Corporation I NorM Gate Square
048 Nedh Stood Street 9 South 7a Street 2 Garden Center Drive
Philadelphia, PA 19130 Stroudsburg, PA 10350 Greensburg, PA 15601
Ph: 215-765-1221 Ph: 570420.8980 Ph: 724-038-1290
Fax 215.785-1427 Ph: 8069224537
Fax: 570420-6981 Tolma1d Sdvices Inc.
Northwest CushlsAv) Sem, 535 C4 M:11 Sueel
5001 N. Dmad Street - 14tH A OM-,. uWe P[ak. JCInC+et, PA 15501
PHadelpNa PA 10141 Suite 1 Fn: 014-1,15-9628
Ph: 215x24-7500 Clacks 8ommill, PA 18411 Ph: 006 45241 4 8
Fax: 215324-8753 Ph: 570.687.9163 Fax 814-4433690
Ph: 870.9229537
CCC3 of Delaware Valley fax: 570.587-9134 Keystone Economic Development Corp.
t515 Markel S1md Fax: 570.5879135 1954 Mary Grace Lane
Suite 1325 Jahtatoam, PA 15901
Philadelptta, PA 19107 P90Et1 COUNTY Ph 814.5358556
PIT. 215-5633666 Nadham Tier Community, action Group Far 814539-1688.
Fax 215-884-2666 135 West 4e Street
E'po tn, PA 15834 CCCS oI Western PA
RACE Ph: 814486-1161 279-A College pads Plaza
167 W-Akgheoy Fez 814.48-0825 Johuimmn, PA 15904
Z' Flay Ph. 814-5398335
PhOedle1pNa PA 19140 SCNUYLKILL COUNTY
Plc 215.426-8025 Budget Counseling Center SULLIVAN COUNTY
fax 2154209122 241 Naar NO, Street CCCSd NONpastern Pennsylvania
Readtlg PA 19FA7 1400 Atinglon Execulfye Park
MedaFellow" House Ph: 6 10 875-7 86 6 Sole 1
302 S. Jackson Street Fax: 6103754030 Clarks Summhp PA 18411
A4eda, PA 19063 Ph: 570.587.9163
Ph 610-565.0846 Canruission on Economic Opportunity Ph: 500.922.9537
Fax 610-565.8567 of Luzern Co. Fax 570587-9134
- 163 ArASB Lane Far. 570567-9135
PCCA Wgkua-ONre,PA IB702
100 Nalh 17° Sheet Ph: 570826-0510 31 W. Marled Street
Sate 60O Ph: F/am-0359 Wdkes-Bw%PA 18702
PNladeWh PA 19103 Fax 57II-M-1665-CallbelosefvAV Pk 570.1121-0837
PR 215.561-7803 W. 570-455 4 994-Hazelim Pk 806922-9537
Fax: 215-9539941 Fax 510455-5831-Gag before renting Fax 570821-1786
Ph: 5708344090-Tudkhanvock
- C=of OdawaleVatl
valley 'e T2YWl
dNonne fa?dn PA
Cne
l(a Oppyl Cabinet or Sctrtrylkitl
Fconommic Street
Street
185 Elinba
215
SuM215 C
o.
Co. P
W
PostCM Ol6ce BOZ218
' ChdryKtl,141080O2 2z it Centre Sired Troy, PA 16947
Ph: 216.5636665 Potfsvk PA 17981 PIV 570-297-2101
PIK 570622-1995 Fax 570297-2799
Housing Association of Delaware Valley Far, 570622-0429
lwl)wakax Sked 17 CrAW Streel
Su8e 601 CCGStfu hValey Wdfs0yq PA 1690(
PhIladepHa,PA 19102 Poo OMmSmA Ph: 5147245252
PIV PIS Ar" io WhOebA PA 18052 I= 570724-5783
Far 215.7909132 Ph: 610821-4011
Fax: 810821.8932 103 Waxen 8hee1
klnkskp A eeci m of Detonate Valley Post Office Um 709
658 North Wan Street SSNyDFS COUNTY Tutdsannock, PA 18657
Ph"AtNA PA 19123 CCCS of Westem Pernsylvanfa,Inc- M 5708386840
Ph: 215478-0224 2000 lJglestown Road Fax 5708368332
Fax 215765-7614 Hardsl urg, PA 17102
Ph: 717-5414757 German Sheet
Cortmmlily Deed. Corp. of Franktord Foe 717341-4610 ftslowaaeaT359
Grail Mirtslry Otahcre,PA 18614
46120 Gdsoom Strad Cannpety Acton Carnmission of the Pk 5709289668
pyliodialWA PA 19124 CVU Region Fox 570.928-8144
Ph: 21-744-2990 1514 DarN Strout
Free 216-744-2012 tiardebleg. PA 17104 931 Mdn Street
Plc 717-2329757 HwlesdoK PA 18431
Amatcan CmM Cuunse8no Institute Fos: 717.234-2227 Ph: 6702536941
845 Cates SUeal Fee 570253-4817
Cpd4948e, PA 19320 U10an League of mouropoltan
Ph: 888-2123741 Hardsbu19 71ake Avdue
21O7* Street 0wt339
144 E. Ddtalb Pike Hardsburig, PA 17101 Montrose, PA 18801
"Of Pnr 4 PA 19406 PtV 717-2343925 PA 570278+1338
Plc 610-971.2210 Fax 711-2344459 P1x BOO-WAO45
Fax 610255.4814 Foe 570.2781689
755 York Read
Sale 103
Warmisfer,PA 18,474
Ph: 215+449429
Fax 215-958-6344
I.
• sB3(g)
61RNNACOM 103wwm$fed walrelcMd Cwale9 EC410mk
_
mtam, PaetOA illsim 09 OmarAY*w"
. .. 1406ANnOMROMUNPerk - - TWkWrP*PA 18657 . 1209PWr Avft,AvwQ%Wo9
fAia4 pit mme-5840 - Pae1,AARDO)CW
CJmb Staran8l,PA 10411 - Fax 57DL068?32 . ' WarreA PA 19366
.. ,. Pk WOW-9163 Ph 814-72624W
Pk 80D-92LA537 931 Man Sheet Fax: 8147234510
FM 670.5874134 Honesdale, PA 10431
Fax 570 8 87 913 5 Ph: 570-2536941 WASHINGTON COUNTY
Fax 570-2534017 Ad{an Hk Iug, inc.
3l W. Market Sneei 425 6°Avenue
W*es-Berta. PA 18702 The Trd,& Center of NE PA Suite 950
Pit 570-821.0837 7 Lake Avenue Mstrngh, PA 15219
W. 863.9229537 Box 339 Ph: 412-391-1056
Fac 570-821-t'M[ oAnmrn;n, PA 1"80! fT: 412-201-21C,
N, 570,V8-"4139 F.'c -112-3944512
Treheb Cente'of Nodhca rr=SPA Ph: 00090240.15
185 Omim Street Fax, 570.278-IBB9 CCCS of Weslem Pe1nsviv&O, ion.
Post Office Box 218 1 North Gale Square
Troy, PA 16947 UNIONGOUNTY 2 Garden Cedar Drive
Ph 570-297.2101 LycorNng-Unto , Co Canm fot Comm Gteetlsberq, PA 15601
Far. 5702972709 mlion (STEP) Ph: 724-8384290
2136 Lincoln Street
German Street Post Office Box 1320 Housing Oipabinflies, lm.
Post 04" Box 389 WH9aasp0d, PA 17703 133 swam Sheet
OusbOre, PA 18614 Ph: S76326060T Mckeespot, PA 15132
Ph: 570.928-9608 Fa: 570322-2197 Ph: 412664-1590
Fax' 6709288144 Fat: 412-W 0873
GCGS d W estem Pensuyhrana. IM.
17 Grattan Street 217 E. Planck Road Cie& Canroelom a PA
Wdsboto,PA 16901 Akoana PA 16602 401 Woad Street
Ph: 570-724-5252 Ph: 814944-8100 Suite 906
Far. 570724-5783 Fax 614-9445747 Pittsburgh PA 15222
Ptr. 412330-9954
103 Watren Sheet ffC8 d 1'1eATeaatam Penns,4 A 1 . 804737-2933
' Poal Me Box 709 31 W. MarkNStroca Fm: 412-330-9963
Tu*hanmck, PA 18657 Pest Me Box 1127
1 Ph: 570-836-6840 W)IkesBatre, PA 16702 Community Aclion South'eesl
fax: 570438-6332 Ph: 570821-=T 22 W e,l Kp t Street
f ph: 800-922-9537 Wayne9wrq, PA 15370
ml Main Sheet Far 570P82117BS Ph 7248522693
Honesdale, PA 18431
Ph: 670-253-8941 1400 Abington Executive Park 53 K College Street
( Fax 570-253-4817 Suits I Washington, PA 15301
GAatl s SummM. PA 18411 Pn: 724-2228292
7 LB .Avenue Ph: 570-587-9163
Bat 333 Ph: 800922-9S37 M,r Valley Umftgbyed Conmi4ee
{ k4edmse, PA 18001 Fat 570-587-9134 120 E. 9?Arenue
Pin: 5762703338 Fec Sm587.9135 HomeMead, PA 15120
Ph WO-982-4045 Plx 412102-99@
Fat 570-278-1809 201 Basin Sheet Fat 412-462.9964
1 AAr4mvpok PA 17703
TIOGA COUNTY Ph: 5709236627 WAYNECG OM
d 6hnheasl PelmsvNan' Fax: 5703206626 Cgof Northeastern PeltlZiopla
1400 AGrglon Es Ai've Perk 1463 Abington ExeclAUe Park
Sutel VENANGO COUNTY Suite1
Clerks SurrvrA PA 18411 Gteakr Etta Cammudly Acton Ckrke Buea^ PA 18411
Ph 570-587-9189 Plr WO-587-9163
Ptt 800-9229537 to Was19A51reo m. 2-969229637
Tai 570587.9134 Erie PA 16501 Fax 570307-9134
Fax 570587-9135 Ph: 914-4544581 Fa: 570587-9135
Foe 814-4.0161
31
NaMet8lreet
uh7SNeAt
9
WAdrs-Ba e
re, PA 18702 CCG Wslem PennsylvalNa inc. o
5k1rw6s ur
18360
Ph: 570-82 AR
A Ame
5764208980
2-m 339
h Was
339 N rt
on Street
A M
Ph 0
9517
Fa X 70.8
Fax: 57045211--1781785 , PA 16MI 16001
Buller. P 57GAIM
Fax 576420-8981
ph: 412-282x812
The 72Aab CPnter of NOrlhpastsm PA Moke Street
$A W.
MaS John F. Kennedy Cella, 1nu e
Bens. PA 18702
Wilkes-Barre. ic
2 2
Post Me Post e ox 18 t e S
heet
S 57
ft 670412
Tm/. PA 1604
947
1 1651
Ede, PA 10 2-11W
Plc 8 G
i
H1: 576297-2181
Ph:: 814
144).90-MW FA
t-I7a
Fax: 5'70821-1785
Fat 576297-2799 Fax: 8148961243
The Trehab Center d NE PA
Getman Sbeo WARREN COUNTY iBseintrasum
peat allies Box 389 DookerT Washington Center Past offea eox2l0
Duahoret PA 18814 1720 Mand Street Troy, PA 15047
Ph 576928-9668 Edia, PA 16503 Ph 576297-2101
Fax 5769280144 Ph: 814-4533744 Fa: 570297.2799
Fax: 8144585749
17 CAMM teet 17 Cr4Ran Street
Wellsboro, PA 16631 Greater Erie COtnmufBlY ACliar WoflsbcrcPA 16901
Vtr
b7tr7245252 GDM6000 Ph, 5
Ph: 5700--7 7245252
Fax
Fax 5707245783 18
i8 Wes19`Street Fax: 5761245783
Effie, PA 16501
Ph: 814459-4581
Fax 8144560161
103 warren Street
PON OMCG B x709,
Yi1M11erawsk, PA 10057
Pte BN83s8840 -
Fae FW364382
Germpk
Past Dike e Box 359
DushmA PA 18014 .
Ph: 576928.9688
Fax 570.928-8144
931 Man Street
Flonesdi le, PA 18431
Ph: 570.253.8941
Far pn259.: ell
7 Lake Avenue
Box 339
Monimee, PA 18801
Ph: 5762193338
PK 808.982-4045
Far 570,276-1889
WESTMORELAND COUNTY
Action Horsing, Inc.
4256PAvenue
State 950
P'itlsbagh, PA 15219
Ph: 412-391-1956
Pre 412.281.2102
C«nmuruly Action So th vest
22west Hipp Sheet
Waynesburg, PA 15370
Ph: 724852-2893
CCCSd Weslern Penaeyv et,,•n,.
i North Gate Square
2 Garden Center Delve
Gresneburg, PA 45WI
Ph: 72: 33a-1s?0
Housing Oppoeonitles. inc.
133 Seven Street
McKmPon, PA 15132
Pte 412-941590
Fax 4/2-684-0873
Keyd"Sogmmic Development
Caparaticn
1954 Mary Grace Lane
J&MWWIN PA 15901
Pte 8145168558
Far 814599-1688
Tabwa dsen4ceskw-
535 East Main Step
Strnerset, PA 15501
W. 814-4469828
Ph: BODAM-0148
Far 814443-3690
199 Edson 81"
Ulkntoxn, PA 15401
Phe 724-43"%g
Irri naCo CamnulityAcllon Program
827 Wafer Street
Box 1W
rn&aga PA 15701
Ptc 7244852651
Fwc 724465-5118
MM-VaAey Onemp" Corew e
120 E 9° Averute
Hornell", PA 15120
Ph 412-462-9962
F8c 412-462-9984
CrerA Counselors d PA
401 Wood SWOO
suite 905
Pi8sW*. PA 15222
Ph 412-33&9954
Ph: 806737.2933
Fax 412-338-9963
Cnlwen ECatarira OpfwdWtfty d
LLMNO"
w&oaw%PA 18701
Pte 5 7 6 82 8 0510
Plc ODClM-0350
Far 670429-1885-Call before Wing
Plc 570-4554994-Pa sKon
Far 570.455-5531- Call before laxin0
Pic 570-838-4090-Tunkhannock
CCCS of Nonhea6lern PA
14W Abir9t n Executive Park
S'1a I
Cam," 5wbmih, PA 1041 t
Ph: 570-507-9I63
Ph: 008922.9537
Fax: 570-581-9134
Fax 570-587-9135
31 W.MeAe1 Sheet
W74te5-evre, PA 18702
Ph: 570 821083,
Ph: MO-922-9537
Fax 570-821-1785
ThTremal Center of NE PA
7 Lake Avenue
Sax 339
Montrose, PA 18801
Ph 576-278-3338
Ph: 8069884045
Few 576278-1889
IBS Eknka Street
Pose Orlice Bull 218
Toy, PA 15947
Pie 570@97.210t
Fax 570-297-2799
47 Crzom Sew
Weltsboro, PA IeWl
Ph 570-724-5252
Far 570.724-5783
103 Warren Steel
Pori OIRCe Bat 709
Tunkhannock, PA 18657
Pk 570836.6840
Fax: 570.836-6432
Gemun greet
PCs( Ofte Box 309
DudW PA 18614
Ph: 570928-WM
Fat 570-928-8144
931 Man Sired
Honesdale, PA 18431
Pn: 576253.8941
Fat: 5762534817
YORK COLIN"
American, Red Cans-Ii'a om ChOPIW
529 08dhle Sleep
Henna, PA 17331
Ph: 717.837$58
Fax 717-637.3294
Hausieg bunco of Yak
118 North George SiRp
York PA 17401
Pk 717-0541541
Fax 717-8457934
CCC8 dwestem Pennsylvania Inc.
2009 Lieglestovm Fioad
Hartsdag. PA 17102
Ph: 717-MI-1757
fax 717.541-4670
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York, PA 17403
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SHERIFF'S RETURN - REGULAR
CASE NO: 2006-01459 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
MILLER SALLY J
SGT.JODY SMITH Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
MILLER SALLY J the
DEFENDANT at 1105:00 HOURS, on the 28th day of March , 2006
at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE
CARLISLE, PA 17013 by handing to
SALLY J MILLER
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 24.64
Affidavit .00
Surcharge 10.00
.00
52.64
Sworn and Subscribed to before
me this 11 b day of
?bD4 A. D.
So Answers:
R. Thomas Kline
03/29/2006
GOLDBECK MCCAFFERTY MCKEEVER
3 ?)
Deputy Sheriff
Prothonotary
In the Court of Common Pleas of Cumberland County
DEUTSCHE BANK NATIONAL TRUST COMPANY, FOR
THE BENEFIT OF THE CERTIFICATEHOLDERS OF
MORGAN STANLEY ABS CAPITAL I INC.
7105 Corporate Drive
PTX B-35
Plano, TX 75024-3632
Plaintiff
VS.
SALLY J. MILLER
(Mortgagor(s) and Record Owner(s))
402 West Main Street
Walnut Bottom, PA 17266
Defendant(s)
PRAECIPE FOR JUDGMENT
No. 06-1459
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE
OF COLLECTING THE DEBT.
Enter the Judgment in favor of Plaintiff and against SALLY J. MILLER by default for want of an Answer.
Assess damages as follows:
Debt
interest - 09/11/2005 to 08/22/2006
Total
(Assessment of Damages attached)
$109,436.96
I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO
BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT.
I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment
is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the
filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 ?k"
Joseph oldbeck,Jr.
Attorney Tidr Plaintiff
I.D.#16132
AND NOW ???J[7 Judgment is entered in favor of
DEUTSCHE BANK NATIONAL TRUST COMPANY, FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF
MORGAN STANLEY ABS CAPITAL I INC. and against SALLY J. MILLER by default for want of an Answer and
damages assessed in the sum of $109,436.96 as per the above certification. &d74
Protb notary
Rule of Civil Procedure No. 236 - Revised
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DEUTSCHE BANK NATIONAL TRUST COMPANY, FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF
MORGAN STANLEY ABS CAPITAL I INC.
7105 Corporate Drive
PTX B-35
Plano, TX 75024-3632
Plaintiff
No. 06-1459
VS.
SALLY J. MILLER
(Mortgagors and Record Owner(s))
402 West Main Street
Walnut Bottom, PA 17266
Defendant(s)
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE
PURPOSE OF COLLECTING THE DEBT.
NOTICE
Notice is given that a judgment in the above-captioned matter has been entered against you.
Curt Long
Prothono
By.
If you have any questions concerning the above, please contact:
Joseph A. Goldbeck, Jr.
Goldbeck McCafferty & McKeever
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
CWD-5768
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED
FOR THE PURPOSE OF COLLECTING THE DEBT.
DATE OF THIS NOTICE: April 18, 2006
TO:
SALLY J. MILLER
402 W. Main Street
Walnut Bottom, PA 17266-9718
DEUTSCHE BANK NATIONAL TRUST COMPANY, FOR THE BENEFIT OF
THE CERTIFICATEHOLDERS OF MORGAN STANLEY ABS CAPITAL I INC.
7105 Corporate Drive
PTX B-35
Plano, TX 75024-3632
Plaintiff'
VS.
SALLY J. MILLER
(Mortgagor(s) and Record Owner(s))
402 West Main Street
Walnut Bottom, PA 17266
Defendant(s)
TO: SALLY J. MILLER
402 W. Main Street
Walnut Bottom, PA 17266-9718
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Action of
Mortgage Foreclosure
Tern
No. 06-1459
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAMED 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 (10) DAYS FROM THE DATE OF THIS NOTICE, A
JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR
OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 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.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
- 4a w ii A Gafcf6ecf jz
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 5000 - 701 Market Street.
Philadelphia, PA 19106 215-825-6318
VERIFICATION OF NON-MILITARY SERVICE
The undersigned, as the representative for the Plaintiff
corporation within named do hereby verify that I am authorized
to make this verification on behalf of the Plaintiff corporation
and that the facts set forth in the foregoing verification of
Non-Military Service are true and correct to the best of my
knowledge, information and belief. I understand that false
statements therein are made subject to penalties of 18 Pa. C.S.
4904 relating to unsworn falsification to authorities.
1. That the above named Defendant, SALLY J. MILLER, is
about unknown years of age, that Defendant's last known
residence is 402 W. Main Street, Walnut Bottom, PA 17266-9718,
and is engaged in the unknown business located at unknown
address.
2. That Defendant is not in the Military or Naval Service
of the United States or its Allies, or otherwise within the
provisions of the Soldiers' and Sailors' Civil Relief Action of
Congress of 1940 and its Amendments.
Date: 03%
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY,
FOR THE BENEFIT OF THE
CERTIFICATEHOLDERS OF MORGAN STANLEY
ABS CAPITAL I INC.
7105 Corporate Drive
PTX B-35
Plano, TX 75024-3632
Plaintiff
VS.
SALLY J. MILLER
(Mortgagor(s) and Record owner(s))
402 West Main Street
Walnut Bottom, PA 17266
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION LAW
ACTION OF MORTGAGE FORECLOSURE
No. 06-1459
ORDER FOR JUDGMENT
Please enter Judgment in favor of DEUTSCHE BANK NATIONAL TRUST COMPANY, FOR THE
BENEFIT OF THE CERTIFICATEHOLDERS OF MORGAN STANLEY ABS CAPITAL I INC., and against
SALLY J. MILLER for failure to file an Answer in the above action within (20) days (or sixty (60) days if
defendant is the United States of America) from the date of service of the Complaint, in the sum of $109,436.96.
Joseph oldbeck, Jr.
Attorne r Plaintiff
I hereby certify that the above names are correct and that the precise residence address of the judgment
creditor is DEUTSCHE BANK NATIONAL TRUST COMPANY, FOR THE BENEFIT OF THE
CERTIFICATEHOLDERS OF MORGAN STANLEY ABS CAPITAL I INC. 7105 Corporate Drive PTX B-35
Plano, TX 75024-3632 and that the name(s) and last known address(es) of the Defendant(s) is/are SALLY J.
MILLER, 402 W. Main Street Walnut Bottom, PA 17266-9718;
GOL AC McCAFFERTY & McKEEVER
BY: J h A. Goldbeck, Jr.
Attorney for Plaintiff
ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly assess the damages in this case to be as follows:
Principal Balance $95,194.59
Interest from 09/11/2005 through $7,127.60
08/22/2006
Reasonable Attorney's Fee $4,759.73
Late Charges $383.79
Costs of Suit and Title Search $900.00
Escrow $1,071.25
Total
$109,436.96
lal?
GOLDB cCAFFERTY & MCKEEVER
BY: Josep A. Goldbeck, Jr.
Attorney for Plaintiff
AND NOW, this ot/ ' `-day of PUT , 2006 damages are assessed as above.
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IV PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
Joseph A. Goldbeck, Jr.
Attomey I.D.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY,
FOR THE BENEFIT OF THE
CERTIFICATEHOLDERS OF MORGAN STANLEY
ABS CAPITAL I INC.
7105 Corporate Drive
PTX B-35
Plano, TX 75024-3632
SALLY J. MILLER
IN THE COURT OF COMMON PLEAS
of Cumberland County
VS.
Plaintiff
Mortgagor(s) and Record Owner(s)
402 West Main Street
Walnut Bottom, PA 17266
TO THE PROTHONOTARY:
Defendant(s)
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 06-1459
PRAECIPE FOR WRIT OF EXECUTION
Issue Writ of Execution in the above matter:
Interest from
09/11/2005 to
08/22/2006 at
7.9000%
Amount Due
(Costs to be added)
$109,436.96
IV r
GOLDB cCAFFERTY & McKEEVER
BY: Jose A. Goldbeck, Jr.
Attorney for Plaintiff
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All that certain tract of land with improvements thereon erected, situate in South Newton Township,
Cumberland County, Pennsylvania, bounded and described as follows:
Beginning at a point at the intersection of the Oakville Road; thence along the centerline of the said
Walnut Bottom Road, South 64 degrees West, a distance of 212.5 feet to a point; thence along other
lands now or formerly of Fred Rosenberry, North 20 degrees 30 minutes West, a distance of 145 feet to
a stake; thence along other lands now or formely of Rehobeth Community Center, North 72 degrees 35
minutes East, a distance of 207.5 feet to a point on the centerline of the said Oakville Road, South 22
degrees 42 minutes East, a distance of 114 feet to the point or place of beginning.
TAX PARCEL NO. 41-32-2292
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-1459 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY,
FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF MORGAN STANLEY ABS
CAPITAL I INC., Plaintiff (s)
From SALLY J. MILLER
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $109,436.96
Interest FROM 9111/05 TO 8/22/06 AT 7.9000%
Arty's Comm %
Arty Paid $134.64
Plaintiff Paid
Date: AUGUST 28, 2006
L.L. $.50
Due Prothy $1.00
Other Costs
CURTIS Urt NG
Prothonotary
(Seal)
By:
Deputy
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK, JR., ESQUIRE
Address: SUITE 5000 - MELLON
CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106-1532
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ID No. 16132
Goldbeck McCafferty & McKeever
BY: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, FOR THE BENEFIT OF THE
CERTIFICATEHOLDERS OF MORGAN STANLEY
ABS CAPITAL I INC.
7105 Corporate Drive
PTX B-35
Plano, TX 75024-3632
Plaintiff
VS.
SALLY J. MILLER
(Mortgagor(s) and Record Owner(s))
402 West Main Street
Walnut Bottom, PA 17266
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Defendant(s)
No. 06-1459
AFFIDAVIT PURSUANT TO RULE 3129
DEUTSCHE BANK NATIONAL TRUST COMPANY, FOR THE BENEFIT OF THE CERTIFICATEHOLDERS
OF MORGAN STANLEY ABS CAPITAL I INC., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr.,
Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real
property located at:
402 West Main Street
Walnut Bottom, PA 17266
1.Name and address of Owner(s) or Reputed Owner(s):
SALLY J. MILLER
402 W. Main Street
Walnut Bottom, PA 17266-9718
2. Name and address of Defendant(s) in the judgment:
SALLY J. MILLER
402 W. Main Street
Walnut Bottom, PA 17266-9718
3. Name and last (mown address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
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06-1459
e
r GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, FOR THE BENEFIT OF THE
CERTIFICATEHOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC.
7105 Corporate Drive
PTX B-35
Plano, TX 75024-3632
VS.
SALLY J. MILLER
Mortgagor(s) and Record Owner(s)
402 West Main Street
Walnut Bottom, PA 17266
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Plaintiff
Term
No. 06-1459
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: MILLER, SALLY
SALLY J. MILLER
402 W. Main Street
Walnut Bottom, PA 17266-9718
Your house at 402 West Main Street, Walnut Bottom, PA 17266 is scheduled to be sold at
Sheriffs Sale on Wednesday, December 06, 2006, at 10:00 AM, in Commissioners Hearing Rm 2nd FL
Courthouse to enforce the court judgment of $109,436.96 obtained by DEUTSCHE BANK NATIONAL
TRUST COMPANY, FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
06-1459
1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY,
FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF MORGAN STANLEY ABS CAPITAL I
INC., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you
must pay call: 215-627-1322
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
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 below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
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.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY,
FOR THE BENEFIT OF THE
CERTIFICATEHOLDERS OF MORGAN STANLEY
ABS CAPITAL I INC.
7105 Corporate Drive
PTX B-35
Plano, TX 75024-3632
VS.
SALLY J. MILLER
(Mortgagor(s) and Record owner(s))
402 West Main Street
Walnut Bottom, PA 17266
IN THE COURT OF COMMON PLEAS
Plaintiff
of Cumberland County
CIVIL ACTION LAW
ACTION OF MORTGAGE FORECLOSURE
No. 06-1459
Defendant(s)
ORDER FOR JUDGMENT
Please enter Judgment in favor of DEUTSCHE BANK NATIONAL TRUST COMPANY, FOR THE
BENEFIT OF THE CERTIFICATEHOLDERS OF MORGAN STANLEY ABS CAPITAL I INC., and against
SALLY J. MILLER for failure to file an Answer in the above action within (20) days (or sixty (60) days if
defendant is the United States of America) from the date of service of the Complaint, in the sum of $109,436.96.
Joseph Al. oldbeck,Jr.
Attorne r Plaintiff
I hereby certify that the above names are correct and that the precise residence address of the judgment
creditor is DEUTSCHE BANK NATIONAL TRUST COMPANY, FOR THE BENEFIT OF THE
CERTIFICATEHOLDERS OF MORGAN STANLEY ABS CAPITAL I INC. 7105 Corporate Drive PTX B-35
Plano, TX 75024-3632 and that the name(s) and last known address(es) of the Defendant(s) is/are SALLY J.
MILLER, 402 W. Main Street Walnut Bottom, PA 17266-9718;
?kjt
GOL C McCAFFERTY & McKEEVER
BY: J 40h A. Goldbeck, Jr.
Attorney for Plaintiff
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attomey I.D.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
CWD-5788
CF: 03/15/2006
SD: 12/06/2006
$109,436.96
DEUTSCHE BANK NATIONAL TRUST COMPANY,
FOR THE BENEFIT OF THE
CERTIFICATEHOLDERS OF MORGAN STANLEY
ABS CAPITAL I INC.
7105 Corporate Drive
PTX B-35
Plano, TX 75024-3632
Plaintiff
VS.
SALLY J. MILLER
Mortgagor(s) and
Record Owner(s)
402 West Main Street
Walnut Bottom, PA 17266
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 06-1459
CERTIFICATE OF SERVICE
PURSUANT TO Pa.R.C.P. 3129.2 (c) (2)
Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the
Defendants of the Notice of Sheriff Sale was made by:
( Personal Service by the Sheriffs Office%ex.Petwh a (copy of return attached).
( ) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached).
( ) Certified mail by Sheriffs Office.
( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record
(proof of mailing attached).
( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment
attached).
( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record.
IF SERVICE WAS ACCOMPLISHED BY COURT ORDER.
( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached).
( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached).
( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified
Mail attached).
Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been
made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached).
The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S.
Section 4904.
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BY .7os h A. Go dbe r.
Att me or Plaintiff
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Deutsche Bank National Trust Company, for the In the Court of Common Pleas of
Benefit of the Certificate Holders of Morgan Cumberland County, Pennsylvania
Stanley ABS Capital Inc. Writ No. 2006-1459 Civil Term
VS
Sally J. Miller
Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on
September 15, 2006 at 1835 hours, he served a true copy of the within Real Estate Writ, Notice and
Description, in the above entitled action, upon the within named defendant, to wit: Sally J. Miller,
by making known unto Joe Miller, adult son of Sally J. Miller, at 402 W. Main Street, Walnut
Bottom, Cumberland County, Pennsylvania its contents and at the same time handing to him
personally the said true and correct copy of the same.
William Cline, Deputy Sheriff, who being duly sworn according to law, states that on
October 13, 2006 at 1109 hours, he posted a true copy of the within Real. Estate Writ, Notice, Poster
and Description, in the above entitled action, upon the property of Sally J. Miller located at 402 W.
Main St., Walnut Bottom, Cumberland County, Pennsylvania according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the
above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff
mailed a notice of the pendency of the action to the within named defendant, to wit: Sally J. Miller,
by regular mail to her last known address of 402 W. Main Street, Walnut Bottom, PA 17266. This
letter was mailed under the date of October 10, 2006 and never returned to the Sheriffs Office.
So Answers:
r ??
R. Thomas Kline, Sheriff
BY CCU
Real Estate ergeant
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6320
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, FOR THE BENEFIT OF THE
CERTIFICATEHOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC.
7105 Corporate Drive
PTX B-35
Plano, TX 75024-3632
Plaintiff
VS.
SALLY J. MILLER
Mortgagor(s) and Record Owner(s)
402 West Main Street
Walnut Bottom, PA 17266
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
Term
No. 06-1459
DEUTSCHE BANK NATIONAL TRUST COMPANY, FOR THE BENEFIT OF THE CERTIFICATEHOLDERS
OF MORGAN STANLEY ABS CAPITAL I INC., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr.,
Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real
property located at:
402 West Main Street
Walnut Bottom, PA 17266
1.Name and address of Owner(s) or Reputed Owner(s):
SALLY J. MILLER
402 W. Main Street
Walnut Bottom, PA 17266-9718
2. Name and address of Defendant(s) in the judgment:
SALLY J. MILLER
402 W. Main Street
Walnut Bottom, PA 17266-9718
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
4. Name and address of the last recorded holder of every mortgage of record:
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
402 West Main Street
Walnut Bottom, PA 17266
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
DATED: November 21, 2006
K McCAFFERTY & r
A. Goldbeck, Jr., Esq.
Plaintiff
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Deutsche Bank National Trust Company, for the In the Court of Common Pleas of
Benefit of the Certificate Holders of Morgan Cumberland County, Pennsylvania
Stanley ABS Capital Inc. Writ No. 2006-1459 Civil Term
VS
Sally J. Miller
Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on
September 15, 2006 at 1835 hours, he served a true copy of the within Real Estate Writ, Notice and
Description, in the above entitled action, upon the within named defendant, to wit: Sally J. Miller,
by making known unto Joe Miller, adult son of Sally J. Miller, at 402 W. Main Street, Walnut
Bottom, Cumberland County, Pennsylvania its contents and at the same time handing to him
personally the said true and correct copy of the same.
William Cline, Deputy Sheriff, who being duly sworn according to law, states that on
October 13, 2006 at 1109 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster
and Description, in the above entitled action, upon the property of Sally J. Miller located at 402 W.
Main St., Walnut Bottom, Cumberland County, Pennsylvania according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the
above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff
mailed a notice of the pendency of the action to the within named defendant, to wit: Sally J. Miller,
by regular mail to her last known address of 402 W. Main Street, Walnut Bottom, PA 17266. This
letter was mailed under the date of October 10, 2006 and never returned to the Sheriff s Office.
R.. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is
returned STAYED per instructions from Attorney Joseph Goldbeck.
Sheriffs Costs:
Docketing 30.00
Poundage 12.23
Advertising 15.00
Posting Bills 15.00
Law Library .50
Prothonotary 1.00
Mileage 26.40
Certified Mail 9.56
Levy 15.00
Surcharge 20.00
Law Journal 203.00
Patriot News 240.26
Share of Bills 15.94
Postpone Sale 20.00
$623.89
R. Thomas Kline, Sheriff
BY??
Real Esta Sergeant
I ..? d
/Eec,. J ? ?' 71
•t
Goldbeck McCafferty & McKeever
BY: Joseph A. Goldbeck, Jr.
Attorney I.D. # 16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, FOR THE BENEFIT OF THE
CERTIFICATEHOLDERS OF MORGAN STANLEY
ABS CAPITAL I INC.
7105 Corporate Drive
PTX B-35
Plano, TX 75024-3632
Plaintiff
vs.
SALLY J. MILLER
(Mortgagor(s) and Record Owner(s))
402 West Main Street
Walnut Bottom, PA 17266
No. 06-1459
r
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
DEUTSCHE BANK NATIONAL TRUST COMPANY, FOR THE BENEFIT OF THE CERTIFICATEHOLDERS
OF MORGAN STANLEY ABS CAPITAL I INC., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr.,
Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real
property located at:
402 West Main Street
Walnut Bottom, PA 17266
LName and address of Owner(s) or Reputed Owner(s):
SALLY J. MILLER
402 W. Main Street
Walnut Bottom, PA 17266-9718
2. Name and address of Defendant(s) in the judgment:
SALLY J. MILLER
402 W. Main Street
Walnut Bottom, PA 17266-9718
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
{
r
4. Name and address of the last recorded holder of every mortgage of record:
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
402 West Main Street
Walnut Bottom, PA 17266
(attach separate sheet if more space is needed)
I verity that the statements made in this affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
DATED: August 22, 2006
GOLDB K McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
__ 1 ? ? ?? ?S3;e`,?r ?kuL?
4'? E? •Cst
_"i a
06-1459
r
GOLDBECK MCCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, FOR THE BENEFIT OF THE
CERTIFICATEHOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC.
7105 Corporate Drive
PTX B-35
Plano, TX 75024-3632
vs.
SALLY J. MILLER
Mortgagor(s) and Record Owner(s)
402 West Main Street
Walnut Bottom, PA 17266
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Plaintiff
Defendant(s
Term
No. 06-1459
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: MILLER, SALLY
SALLY J. MILLER
402 W. Main Street
Walnut Bottom, PA 17266-9718
Your house at 402 West Main Street, Walnut Bottom, PA 17266 is scheduled to be sold at
Sheriffs Sale on Wednesday, December 06, 2006, at 10:00 AM, in Commissioners Hearing Rm 2nd FL
Courthouse to enforce the courtjudgment of $109,436.96 obtained by DEUTSCHE BANK NATIONAL
TRUST COMPANY, FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff s Sale you must take immediate action:
s
06-1459
1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY,
FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF MORGAN STANLEY ABS CAPITAL I
INC., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you
must pay call: 215-627-1322
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
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 below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
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.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
0
All that certain tract of land with improvements thereon erected, situate in South Newton Township,
Cumberland County, Pennsylvania, bounded and described as follows:
Beginning at a point at the intersection of the Oakville Road; thence along the centerline of the said
Walnut Bottom Road, South 64 degrees West, a distance of 212.5 feet to a point; thence along other
lands now or formerly of Fred Rosenberry, North 20 degrees 30 minutes West, a distance of 145 feet to
a stake; thence along other lands now or formely of Rehobeth Community Center, North 72 degrees 35
minutes East, a distance of 207.5 feet to a point on the centerline of the said Oakville Road, South 22
degrees 42 minutes East, a distance of 114 feet to the point or place of beginning.
TAX PARCEL NO. 41-32-2292
WRIT OF EXECUTION and/oV ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-1459 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY,
FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF MORGAN STANLEY ABS
CAPITAL I INC., Plaintiff (s)
From SALLY J. MILLER
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof,
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $109,436.96
Interest FROM 9/11/05 TO 8/22/06 AT 7.9000%
Atty's Comm %
Atty Paid $134.64
Plaintiff Paid
Date: AUGUST 28, 2006
(Seal)
L.L. $.50
Due Prothy $1.00
Other Costs
CURTIS . LONG
Prothonotary
By:
Deputy
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK, JR., ESQUIRE
Address: SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106-1532
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ID No. 16132
Real Estate Sale # 59
On September 11, 2006 the Sheriff levied upon the
defendant's interest in the real property situated in
South Newton Township, Cumberland County, PA
Known and numbered as 402 W. Main St.,
Walnut Bottom, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: September 11, 2006
By: 0
Real Estate Sergeant
C./
a R.
1
M
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ss.
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
October 20, October 27 and November 3, 2006
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
Marie
SWORN TO AND SUBSCRIBED before me this
3 day of November, 2006
1-4, 41 __ I I
NOTARIAL SEAL
LOIS E. SNYDER, Notary Public
Carlisle Boro, Cumberland County
My Commission Expires March 5, 2009
REAL ESTATE SALE NO. 59
Writ No. 2006-1459 Civil
Deutsche Bank National Trust
Company, for the Benefit of the
Certificate Holders of Morgan
Stanley ABS Capital Inc.
vs.
Sally J. Miller
Atty.: Joseph Goldbeck
All that certain tract of land with
improvements thereon erected, situ-
ate in South Newton Township,
Cumberland County, Pennsylvania,
bounded and described as follows:
Beginning at a point at the inter-
section of the Oakville Road; thence
along the centerline of the said Wal-
nut Bottom Road, South 64 degrees
West, a distance of 212.5 feet to a
point; thence along other lands now
or formerly of Fred Rosenberry,
North 20 degrees 30 minutes West,
a distance of 145 feet to a stake;
thence along other lands now or for-
merly of Rehobeth Community Cen-
ter, North 72 degrees 35 minutes
East, a distance of 207.5 feet to a
point on the centerline of the said
Oakville Road, South 22 degrees 42
minutes East, a distance of 114 feet
to the point or place of beginning.
TAX PARCEL NO. 41-32-2292.
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Joseph A. Dennison, being duly sworn according to law, deposes and says:
That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the
laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market
Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-
News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market
Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were
established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever
since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published
in their regular daily and/or Sunday/ Metro editions which appeared in the 25th day(s) of October and the 1st and
8th day(s) of November 2006. That neither he nor said Company is interested in the subject matter of said printed
notice or advertising, and that all of the allegations of this statement as to the time, place and character of
publication are true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed
and adopted severally by the stockholders and board of directors of the said Company and subsequently duly
recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M",
Volume 14, Page 317.
PUBLICATION ..................... ... 1...E 1?ZZ2.........................
COPY Sworn to and subsc ' e ore me t
I W
SALE #59
Seal
Tama i usseil, Notary public
city a Harrisb g, Dauphin County
y Commissi Expires , 2010
Member, Penns van,. s ion of Notaries
NOTARY PUBLIC
CUMBERLAND COUNTY SHERIFF'S OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
REAL EBWE MA tt
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oat s-8 11[ 11 7tM
cotetp, 4
Csrltllat oigM wm at Mnnan
SMONVANS
capildim.
Va.
Dl',pIN4T'?QN
ALL THAT CFITAIN tract of lad with
impovemeets tha" MCIK situate in South
Newton Towas County,
Pennsylvania, boaedetl ad de9aibed as
follows:
Beginning at a point at the intauction of the
Oakville Road; thence along the ceatraiine of
the said walnut Boatmo Road, south 64 degrees
West, a diftom of 2125 fed to a pe 'tbe m
along odw leads now or f0nne'1y of fw
Rosenberg, North 20 dcguas 30 mnata West,
a distance of 145 fiat is a staff; a *q
odiff lands aver a- famm4 of, Rtdtoi"
Comfy Center, N 72 d*eea 35
minutes E a divace of 2975 fea w a ptnut
on the cestuffia f & said OdW& Read,
South 22 set 4? wka m East, R=di mw of
114feet *Atpa+ir aOw of .
Ta Pbolt 41-33.
'CIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
jeck, Jr.
x16132
Mellon Independence Center
.et Street
tphia, PA 19106-1532
215-u27-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY,
FOR THE BENEFIT OF THE
CERTIFICATEHOLDERS OF MORGAN STANLEY
ABS CAPITAL I INC.
7105 Corporate Drive
PTX B-35
Plano, TX 75024-3632
Plaintiff
vs.
SALLY J. MILLER
Mortgagor(s) and Record Owner(s)
402 West Main Street
Walnut Bottom, PA 17266
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 06-1459
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
Interest from
08/23/2006 to Date of
Sale at 7.9000%
(Costs to be added)
$109,436.96
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All that certain tract of land with improvements thereon erected, situate in South Newton Township,
Cumberland County, Pennsylvania, bounded and described as follows:
Beginning at a point at the intersection of the Oakville Road; thence along the centerline of the said
Walnut Bottom Road, South 64 degrees West, a distance of 212.5 feet to a point; thence along other
lands now or formerly of Fred Rosenberry, North 20 degrees 30 minutes West, a distance of 145 feet to
a stake; thence along other lands now or formely of Rehobeth Community Center, North 72 degrees 35
minutes East, a distance of 207.5 feet to a point on the centerline of the said Oakville Road, South 22
degrees 42 minutes East, a distance of 114 feet to the point or place of beginning.
TAX PARCEL NO. 41-32-2292
4 "Is
Goldbeck McCafferty & McKeever
BY: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, FOR THE BENEFIT OF THE
CERTIFICATEHOLDERS OF MORGAN STANLEY
ABS CAPITAL I INC.
7105 Corporate Drive
PTX B-35
Plano, TX 75024-3632
Plaintiff
vs.
SALLY J. MILLER
(Mortgagor(s) and Record Owner(s))
402 West Main Street
Walnut Bottom, PA 17266
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORI:CLOSURL
Defendant(s)
No. 06-1459
AFFIDAVIT PURSUANT TO RULE 3129
DEUTSCHE BANK NATIONAL TRUST COMPANY, FOR THE BENEFIT OF THE CERTIFICATEHOLDERS
OF MORGAN STANLEY ABS CAPITAL I INC., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr.,
Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real
property located at:
402 West Main Street
Walnut Bottom, PA 17266
1.Name and address of Owner(s) or Reputed Owner(s):
SALLY J. MILLER
402 W. Main Street
Walnut Bottom, PA 17266-9718
2. Name and address of Defendant(s) in the judgment:
SALLY J. MILLER
402 W. Main Street
Walnut Bottom, PA 17266-9718
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
4. Name and address of the last recorded holder of every mortgage of record:
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
402 West Main Street
Walnut Bottom, PA 17266
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the b st o my personal knowledge or
information and belief. I understand that false statements herein are made subject to t e pe alties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
f`
DATED: October 9, 2007
GOLDBECK Mc FE & McKEEVER
BY: Joseph A. Go eck r., sq.
Attorney for Plain if
--- i3
t+J
A
1 06-1459
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6318
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, FOR THE BENEFIT OF THE
CERTIFICATEHOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC.
7105 Corporate Drive
PTX B-35
Plano, TX 75024-3632
vs.
SALLY J. MILLER
Mortgagor(s) and Record Owner(s)
402 West Main Street
Walnut Bottom, PA 17266
Plaintiff
Defendant(s)
Term
No. 06-1459
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: MILLER, SALLY
SALLY J. MILLER
402 W. Main Street
Walnut Bottom, PA 17266-9718
Your house at 402 West Main Street, Walnut Bottom, PA 17266 is scheduled to be sold at
Sheriffs Sale on Wednesday, March 05, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL
Courthouse to enforce the court judgment of $109,436.96 obtained by DEUTSCHE BANK NATIONAL
TRUST COMPANY, FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
To prevent this Sheriffs Sale you must take immediate action:
P
1
06-1459
1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY,
FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF MORGAN STANLEY ABS CAPITAL I
INC., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you
must pay call our office at 215-825-6329 or 1-866-413-2311 and
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
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 below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
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.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
06-1459
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: 717-243-9400 or.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
5). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at homeretentioncr??goldbeeklaw.com.
Call Judy at 215-825-6329 or fax 215-825-6429. The figure and/or package you
requested will be mailed to the address that you request or faxed if you leave a message
with that information. The attorney in charge of our firm's Homeowner Retention
Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418.
Please reference our Attorney File Number of CWD-5788.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
UNITED STATES BANKRUPTCY COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
IN RE: SALLY J. MILLER
Debtor(s)
BK. NO. 1-06-bk-02772 MDF
CHAPTER 7
COUNTRYWIDE HOME LOANS INC.
V.
SALLY J. MILLER
and
Markian R. Slobodian
Trustee
ORDER
AND NOW, upon the filing of a Certification of Default by the Moving Party in accordance with the
Stipulation of the parties approved on June 29, 2007 it is ORDERED AND DECREED that:
The Automatic Stay of all proceedings, as provided under Section 362 of the Bankruptcy Reform Act of
1978 (The Code) I 1 U.S.C. Section 362, is modified to allow COUNTRYWIDE HOME LOANS INC., and
its successor in title to proceed with the execution process through, among other remedies but not limited to
Sheriff's Sale regarding the premises 402 West Main Street Walnut Bottom,PA 17266 and a possessory
action if necessary.
By file won`t'
71
B p badge (30K)
This document is electrontcally signed and filed on the same date.
Dated: September 4, 2007
Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY,
FOR THE BENEFIT OF THE CERTIFICATEHOLDERS
OF MORGAN STANLEY ABS CAPITAL I INC.
7105 Corporate Drive
PTX B-35
Plano, TX 75024-3632
Plaintiff
vs.
SALLY J. MILLER
Mortgagor(s) and Record Owner(s)
402 West Main Street
Walnut Bottom, PA 17266
Defendant(s)
IN THE COURT OF
COMMON PLEAS
of Cumberland Count:,'
CIVIL ACTION - LAW
ACTION OF
MORTGAGE FORECLOSURE
NO. 06-1459
REAL
I, Joseph A. Goldbeck, Jr., Esquire hereby certify that I am the attorney o record for the Plaintiff in this
action, and I further certify that this property is subject to Act 91 of 1983 and the lai tiff has complied with all
the provisions of the Act. j
Joseph A. Gold ck,
Attorney for pl tiff
N
CD
i
cn
K)
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-1459 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY,
For the Benefit of the CERTIFICATEHOLDERS OF MORGAN STANLEY ABS CAPITAL I INC.,
Plaintiff (s)
From SALLY J. MILLER
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $109,436.96
Interest from 8123/06 to date of sale at 7.9000%
Atty's Comm %
Atty Paid $780.03
Plaintiff Paid
Date: 10/10/07
(Seal)
L.L.
Due Prothy $2.00
Other Costs
P, INA
s
C is R. Long, Prothonota
By:
Deputy
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK, JR., ESQUIRE
Address: GOLDBECK, MCCAFFERTY & MCKEEVER
SUITE 5000--MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106-1532
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ID No. 16132
GOLDBECK McCAFFERTY & McKEEVER
IF BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
CWD-5788
CF: 03/15/2006
SD: 03/05/2008
$109,436.96
DEUTSCHE BANK NATIONAL TRUST COMPANY,
FOR THE BENEFIT OF THE
CERTIFICATEHOLDERS OF MORGAN STANLEY
ABS CAPITAL I INC.
7105 Corporate Drive
PTX B-35
Plano, TX 75024-3632
Plaintiff
VS.
SALLY J. MILLER
Mortgagor(s) and
Record Owner(s)
402 West Main Street
Walnut Bottom, PA 17266
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 06-1459
CERTIFICATE OF SERVICE
PURSUANT TO Pa.R.C.P. 3129.2 (c) (2)
Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the
Defendants of the Notice of Sheriff Sale was made by:
Personal Service by the Sheriffs Office/
( ) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached).
( ) Certified mail by Sheriffs Office.
( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record
(proof of mailing attached).
( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment
attached).
( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record.
IF SERVICE WAS ACCOMPLISHED BY COURT ORDER.
( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached).
( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached).
( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified
Mail attached).
Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been
made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached).
The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S.
Section 4904.
Respectfully submitted,
o`
B . Joseph A. Goldbeck, Jr.
Attorney for Plaintiff
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GOLDBECK MCCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, FOR THE BENEFIT OF THE
CERTIFICATEHOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC.
7105 Corporate Drive
PTX B-35
Plano, TX 75024-3632
Plaintiff
VS.
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
SALLY J. MILLER
Mortgagor(s) and Record Owner(s)
402 West Main Street
Walnut Bottom, PA 17266
Defendant(s)
Term
No. 06-1459
SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129
DEUTSCHE BANK NATIONAL TRUST COMPANY, FOR THE BENEFIT OF THE CERTIFICATEHOLDERS
OF MORGAN STANLEY ABS CAPITAL I INC., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr.,
Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real
property located at:
402 West Main Street
Walnut Bottom, PA 17266
1.Name and address of Owner(s) or Reputed Owner(s):
SALLY J. MILLER
402 W. Main Street
Walnut Bottom, PA 17266-9718
2. Name and address of Defendant(s) in the judgment:
SALLY J. MILLER
402 W. Main Street
Walnut Bottom, PA 17266-9718
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
• PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
4. Name and address of the last recorded holder of every mortgage of record:
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale: .
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
402 West Main Street
Walnut Bottom, PA 17266
ADAMS, JANE, ESQUIRE
64 South Pitt Street
Carlisle, p 17013
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unworn falsification to authorities.
DATED: January 28, 2008
G DBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
r.>
rr, a
G N
?;
-c o
.r- -<
Deutsche Bank National Trust Company, for the In the Court of Common Pleas of
Benefit of the Certificateholders of Morgan Cumberland County, Pennsylvania
Stanley ABS Capital I Inc. Writ No. 2006-1459 Civil Term
VS
Sally J. Miller
Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on
December 20, 2007 at 1013 hours, he served a true copy of the within Real Estate Writ, Notice and
Description, in the above entitled action, upon the within named defendant, to wit: Sally J. Miller,
by making known unto Matthew Miller, adult in charge for Sally J. Miller, at 1853 Walnut Bottom
Road, Newville, Cumberland County, Pennsylvania its contents and at the same time handing to
him personally the said true and correct copies of the same.
Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on January
10, 2008 at 1444 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and
Description, in the above entitled action, upon the property of Sally J. Miller located at 402 West
Main Street, Walnut Bottom, Cumberland County, Pennsylvania according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the
above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff
mailed a notice of the pendency of the action to the within named defendant, to wit: Sally J. Miller
by regular mail to her last known address of 1853 Walnut Bottom Road, Newville, PA 17241. This
letter was mailed under the date of January 8, 2008 and never returned to the Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is
returned STAYED per letter of request from Attorney Joseph Goldbeck.
Sheriffs Costs:
Docketing 30.00
Poundage 15.53
Advertising 15.00
Posting Handbills 15.00
Mileage 23.04
Levy 15.00
Surcharge 20.00
Prothonotary 2.00
Law Journal 355.00
Patriot News 285.17
Share of Bills 16.17
$ 791.91
So Answe &?
R. Thomas Kline, Sheriff
7
BY-J6
Real Estate ergeant
V 31Z "t I or Q,
9;? C1
a 0 4 5'G3
Y
Goldbeck McCafferty & McKeever
BY: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, FOR THE BENEFIT OF THE
CERTIFICATEHOLDERS OF MORGAN STANLEY
ABS CAPITAL I INC.
7105 Corporate Drive
PTX B-35
Plano, TX 75024-3632
Plaintiff
vs.
SALLY J. MILLER
(Mortgagor(s) and Record Owner(s))
402 West Main Street
Walnut Bottom, PA 17266
No. 06-1459
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
DEUTSCHE BANK NATIONAL TRUST COMPANY, FOR THE BENEFIT OF THE CERTIFICATEHOLDERS
OF MORGAN STANLEY ABS CAPITAL I INC., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr.,
Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real
property located at:
402 West Main Street
Walnut Bottom, PA 17266
1.Name and address of Owner(s) or Reputed Owner(s):
SALLY J. MILLER
402 W. Main Street
Walnut Bottom, PA 17266-9718
2. Name and address of Defendant(s) in the judgment:
SALLY J. MILLER
402 W. Main Street
Walnut Bottom, PA 17266-9718
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
4. Name and address of the last recorded holder of every mortgage of record:
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
402 West Main Street
Walnut Bottom, PA 17266
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the b st o my personal knowledge or
information and belief. I understand that false statements herein are made subject to a pe alties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
DATED: October 9, 2007
GOLDBECK Mc FE & McKEEVER
BY: Joseph A. Go eck r., sq.
Attorney for Plaintif
06-1459
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6318
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, FOR THE BENEFIT OF THE
CERTIFICATEHOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC.
7105 Corporate Drive
PTX B-35
Plano, TX 75024-3632
VS.
SALLY J. MILLER
Mortgagor(s) and Record Owner(s)
402 West Main Street
Walnut Bottom, PA 17266
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Plaintiff
Defendant(s;
Term
No. 06-1459
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: MILLER, SALLY
SALLY J. MILLER
402 W. Main Street
Walnut Bottom, PA 17266-9718
Your house at 402 West Main Street, Walnut Bottom, PA 17266 is scheduled to be sold at
Sheriffs Sale on Wednesday, March 05, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL
Courthouse to enforce the court judgment of $109,436.96 obtained by DEUTSCHE BANK NATIONAL
TRUST COMPANY, FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
06-1459
1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY,
FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF MORGAN STANLEY ABS CAPITAL I
INC., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you
must pay call our office at 215-825-6329 or 1-866413-2311 and
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
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 below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
I . If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
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.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
J*
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
06-1459
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: 717-243-9400 or.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
5). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at homeretention(a goldbecklaw com.
Call Judy at 215-825-6329 or fax 215-825-6429. The figure and/or package you
requested will be mailed to the address that you request or faxed if you leave a message
with that information. The attorney in charge of our firm's Homeowner Retention
Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418.
Please reference our Attorney File Number of CWD-5788.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
All that certain tract of land with improvements thereon erected, situate in South Newton Township,
Cumberland County, Pennsylvania, bounded and described as follows:
Beginning at a point at the intersection of the Oakville Road; thence along the centerline of the said
Walnut Bottom Road, South 64 degrees West, a distance of 212.5 feet to a point; thence along other
lands now or formerly of Fred Rosenberry, North 20 degrees 30 minutes West, a distance of 145 feet to
a stake; thence along other lands now or formely of Rehobeth Community Center, North 72 degrees 35
minutes East, a distance of 207.5 feet to a point on the centerline of the said Oakville Road, South 22
degrees 42 minutes East, a distance of 114 feet to the point or place of beginning.
TAX PARCEL NO. 41-32-2292
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 06-1459 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY,
For the Benefit of the CERTIFICATEHOLDERS OF MORGAN STANLEY ABS CAPITAL I INC.,
Plaintiff (s)
From SALLY J. MILLER
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof,
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $109,436.96 L.L.
Interest from 8/23/06 to date of sale at 7.9000%
Atty's Comm % Due Prothy $2.00
Atty Paid $780.03 Other Costs
Plaintiff Paid
Date: 10/10/07
C is R. Long, Prothonotaig-
(Seal) By:
Deputy
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK, JR., ESQUIRE
Address: GOLDBECK, MCCAFFERTY & MCKEEVER
SUITE 5000--MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106-1532
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ID No. 16132
Real Estate Sale # 23
On October 31, 2007 the Sheriff levied upon the
defendant's interest in the real property situated in
South Newton Township, Cumberland County, PA
Known and numbered as 402 West Main Street,
Walnut Bottom, more fully described on Exhibit "A"
filed with this writ and by this reference `
incorporated herein.
Date: October 31, 2007 By: \J
Real Estate ergeant
W Patriot-News Co.
812 Market St.
Harrisburg, PA 17101
Inquiries - 717-255-8292
CUMBERLAND COUNTY SHERIFFS OF
CUMBERLAND COUNTY COURT HOUSE
the Pdtflot"News
Now you know
CARLISLE PA 17013
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin) ss
Joseph A. Dennison, being duly sworn according to law, deposes and says:
That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of
Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News
newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that
The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and
all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither he nor said Company is
interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time,
place and character of publication are true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317.
PUBLICATION COPY
This ad ran on the date(s) shown below:
01/30108
02/06/08
02/13/08
D.
COMMONWEALTH OF PENNSYLVANIA
Notaria? Seel
Sherrie L. i isner, Notary Public
CtyOfHemisburq, 0u,,)Nn Courdy
x ree Nov. 26, 2011
Member, Pennsylvania As's?ciation of Notarles
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ss.
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
January 25, February 1 and February 8, 2008
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
SWORN TO AND SUBSCRIBED before me this
8day of February, 2008
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BORO, CUMBERLAND COUNTY
My Commission Expires Apr 28, 2010
1UL WTIkM &UX NO. 23
Writ No. 2006-1459 Civil
Deutsche Bank National Trust
Company, for the Benefit of the
Certificateholders of Morgan
Stanley ABS Capital I Inc.
vs.
Sally J. Miller
Atty.: Joseph Goldbeck
DESCRIPTION
All that certain tract of land with
improvements thereon erected,
situate in South Newton l ownamp,
Cumberland County, Pennsylvania,
bounded and described as follows:
Beginning at a point at the inter-
section of the Oakville Road; thence
along the centerline of the said Wal-
nut Bottom Road, South 64 degrees
West, a distance of 212.5 feet to a
point; thence along other lands now
or formerly of Fred Rosenberry, North
20 degrees 30 minutes West, a dis-
tance of 145 feet to a stake; thence
along other lands now or formely of
Rehobeth Community Center, North
72 degrees 35 minutes East, a dis-
tance of 207.5 feet to a point on the
centerline of the said Oakville Road,
South 22 degrees 42 minutes East,
a distance of 114 feet to the point or
place of beginning.
TAX PARCEL NO. 41-32-2292.