HomeMy WebLinkAbout06-6596RICHARD F. STERN, ESQUIRE (03315)
STEVEN K. EISENBERG, ESQUIRE (75736)
BRADLEY D. SISLEY, ESQUIRE (200040)
STERN AND EISENBERG, LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
U.S. Bank, N.A., as Trustee for Morgan Stanley
Dean Witter Capital I Inc. Trust 2001-NC4, by its
attorney in fact, Ocwen Loan Servicing, LLC,
successor to Ocwen Federal Bank
1661 Worthington Road, Suite 100
West Palm Beach, FL 33409
v.
Helen J. Myers
2300 Market Street
Camp Hill, PA 17011
And
The United States of America c/o The U.S.
Attorney's Office
William T. Nealon Bldg.
235 N. Washington Avenue
Scranton, PA 18501
Civil Action Number:
(21 U; LC--FS2-S-n
COMPLAINT IN
MORTGAGE FORECLOSURE
CIVIL ACTION - MORTGAGE FORECLOSURE
NOTICE
This is an attempt to collect
a debt and any information obtained
will be used for that purpose.
You have been sued in Court. If you wish to defend the claims set forth in the following pages, you
must take action within twenty (20) days after this Civil Action and notice are served, by entering a
written appearance personally or by attorney and filing in writing with the Court your defense or
objections to the claims set forth against you.
You are warned that if you fail to do so the case may proceed without you and a judgment may be
entered against you by the Court without further notice for any money claimed in the Civil Action or
for any other claim or relief requested by the plaintiff. You may lose money or property of other rights
important to you.
J:\Anne\Complaints\Cumberland\Ocwen.Myers. 11.06. doc
YOU SHOULD TAKE THIS PAPER TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THIS OFFICE CAN PROVIDE
YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
800-990-9108
717-249-3166
3:\Anne\Complaints\Cumberland\Ocwen.Myers.11.06.doc
NOTICE
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ.,
YOU MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF YOU
DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING,
COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE YOU WITH WRITTEN
VERIFICATION OF THE DEBT, AS WELL AS THE NAME AND ADDRESS OF THE ORIGINAL
CREDITOR, IF DIFFERENT FROM THE CURRENT CREDITOR. OTHERWISE, THE DEBT
WILL BE ASSUMED TO BE VALID. IF YOU DO NOT DISPUTE THE DEBT, IT IS NOT AN
ADMISSION OF LIABILITY BY YOU.
IF YOU NOTIFY US IN WRITING WITHIN THE THIRTY (30) DAY PERIOD, WE WILL CEASE
COLLECTION OF THIS DEBT, OR ANY DISPUTED PORTION OF IT, UNTIL WE HAVE
OBTAINED THE REQUIRED INFORMATION AND MAILED IT TO YOU. ONCE WE HAVE
MAILED YOU THE REQUIRED INFORMATION, WE WILL CONTINUE THE COLLECTION
OF THIS DEBT.
THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR. THIS ACTION IS AN ATTEMPT
TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
J:\Anne\Complaints\Cumberland\Ocwen.Myers.11.06.doc
RICHARD F. STERN, ESQUIRE (03315)
STEVEN K. EISENBERG, ESQUIRE (75736)
BRADLEY D. SISLEY, ESQUIRE (200040)
STERN AND EISENBERG, LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
U.S. Bank, N.A., as Trustee for Morgan Stanley
Dean Witter Capital I Inc. Trust 2001-NC4, by its
attorney in fact, Ocwen Loan Servicing, LLC,
successor to Ocwen Federal Bank
1661 Worthington Road, Suite 100
West Palm Beach, FL 33409
v.
Helen J. Myers
2300 Market Street
Camp Hill, PA 17011
And
The United States of America c/o The U.S.
Attorney's Office
William T. Nealon Bldg.
235 N. Washington Avenue
Scranton, PA 18501
Civil Action Number:
COMPLAINT IN
MORTGAGE FORECLOSURE
COMPLAINT
CIVIL ACTION - MORTGAGE FORECLOSURE
1. Plaintiff is U.S. Bank, N.A., as Trustee for Morgan Stanley Dean Witter Capital I Inc.
Trust 2001-NC4, by its attorney in fact, Ocwen Loan Servicing, LLC, successor to Ocwen
Federal Bank (hereinafter referred to as "U.S. Bank, N.A., as Trustee, by its attorney in
fact, Ocwen Loan Servicing, LLC, successor to Ocwen Federal Bank") with offices
located at 1661 Worthington Road, Suite 100, West Palm Beach, FL 33409.
2. Defendant Helen J. Myers is an adult individual with a last-known address of 2300 Market
Street, Camp Hill, PA.
J:\Anne\Complaints\Cumberland\Ocwen.Myers. 11.O6.doc
3. The United States of America is a Defendant for notice purposes only for federal tax lien
against Helen J. Myers filed on 12/27/2005 under Case No. 2005-06727 in the amount of
$23,964.68.
4. Under date of 10/15/2001, Defendant Helen J. Myers executed and delivered to New
Century Mortgage Corporation a mortgage upon the premises 2300 Market Street, Camp
Hill, PA (the "Property") to secure the payment of the sum of $80,000.00. The said
mortgage is recorded in the Office for the Recording of Deeds in and for Cumberland
County on 10/22/2001 at Book 1736, page 1647 and is incorporated herein by reference as
though set forth at length herein. A copy of the legal description of the premises is
attached hereto and made a part hereof as Exhibit "A".
5. The said mortgage was assigned to U.S. Bank, N.A., as Trustee, by its attorney in fact,
Ocwen Loan Servicing, LLC, successor to Ocwen Federal Bank, the within Plaintiff, by
Assignment which was recorded on March 20, 2006 in Book 725, Page 3060.
6. Defendant Helen J. Myers is the real owner of premises 2300 Market Street, Camp Hill,
PA 17011.
7. In accordance with Act 91 of 1983, as amended, a combined notice providing the
information required by §403 of Act No. 6 of 1974, and Act 91, aforesaid, was sent to the
Defendant and no response was made in the appropriate period of time. A true and correct
copy of the aforesaid notice is attached hereto and made a part hereof as Exhibit "B".
8. The said loan is in default as a result of the failure to pay the monthly installments of
$838.00 due on July 1, 2006 and on the same day of each month thereafter.
9. The following is due on the loan:
PRINCIPAL BALANCE ....................................................... $77,705.69
INTEREST accrued thru 11/08/2006 of ............................... $4,193.17
Interest after 11/08/2006 shall accrue at the per diem
rate of $27.19.)
LATE CHARGES accrued thru 11/08/2006 of ..................... $546.96
Late charges after 11/08/2006 shall accrue at the monthly
rate of $41.90.)
ESCROW ADVANCES ........................................................ $10,497.77
FEES BILLED ....................................................................... $1,483.91
COSTS ................................................................................... $300.00
ATTORNEY'S FEE ..............................................................$3,900.00
TOTAL ..................................................................................$98,627.50
J:\Anne\Complaints\Cumberland\Ocwen.Myers.11.06.doc
The attorney fees set forth above are in conformity with the mortgage documents and
Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the
mortgage is reinstated prior to Sale, reasonable attorney fees will be charged based on work actually
performed.
WHEREFORE, Plaintiff, U.S. Bank, N.A., as Trustee, by its attorney in fact, Ocwen
Loan Servicing, LLC, successor to Ocwen Federal Bank requests this Court to enter judgment for
foreclosure of the mortgaged property for the sum of $77,705.69 plus interest thereon of $4,193.17
plus $27.19 per day from 11/08/2006 until judgment is paid in full, late charges of $546.96, plus late
charges of $41.90 per month from 11/08/2006 until judgment is paid in full, escrow advances of
$10,497.77, fees billed of $1,483.91, costs of $300.00, attorney's fees of $3,900.00 and all other
amounts set forth above, less any suspense as set forth above, together with record costs and any other
amounts to which Plaintiff is entitled to recover.
STERN AND EISENBERG LLP
BY:
BRADLEY SISLEY, ESQUI
Attorney f 6r Plaintiff
J:\Anne\Complaints\Cumberland\Ocwen. Myers. 11.06.doc
VERIFICATION
JESSICA DYBAS is the Foreclosure Facilitator of OCWEN LOAN
SERVICING LLC successor to Ocwen Federal Bank and is authorized to sign this
Verification on behalf of same, and states that she verifies the foregoing Civil Action-
Mortgage Foreclosure against Helen J. Myers and The USA and avers the
statements of fact therein contained are made subject to the penalties of 18 PA C.S.
Section 4904 relating to the unsworn falsification to authorities, and that same are true
upon the signer's personal knowledge or information and belief.
J SICA DYBAS
Foreclosure Facilitator
Date: November 8, 2006
i .. .. • .a .. .. ... F .n.. . .... .. x r..0 M ..y- .. ? .. . r ... . ... . ....... rte.
' :,egal 'Deacrigtion
i
ALL -bat cex:airx tract or piece of land pituate is the Borough of CmV Hill, Cozutty of
c-mberland and state o£ geaneylvania, more particularly bounded sad dasdriimd as
tol1r.w, to uit=
2=140 = at the =r-thwe0z cflrAer of Umilt= street, MOW -wentg-tbira Street, and ?
Market street; thextics in a nartherly directiou, along the vent aide of xamiltoa
Street, now Ivanty-third Street, two kurAred five (305) feet to a pointy thence
nraptwardlY, $,lorq iaada of D. Fdxin bundred
o Rc]ant ?golf? cne (bi4Lyud?cedfeet,
Aiaaty-g?c
lee$, to a point, tsenca aouttwardly i
and five arae•huxlredths (196.05) feet to a curb line = market streets thence
eastwaxdly, along the cyrb line of WAe earth aide of w#Wmt Street, cze bundxed
torcy-fc= 0.E4) feet, More Or lees, to the place of HFQIk)FDMO
BEW improved by a two a34 ozLS•lse.:f story brick dwelling and necessary outbuildings,
known ai and Numbered 2300 Market Street, Camp Hill, Pa.
44RP'V
D
........... ....__.;s
OCWEN Loan Servicing, LLC
12650 Ingenuity Drive
O C W E^N Orlando, Florida 32826
WWW.OCWEN.COM
August 31, 2006
VIA First Class Mail
VIA Certified Mail (return receipt requested)
Certified Number: 71069017515112483771
Reference Code: 0606
Helen J. Myers
2300 Market Street
Camp Hill, PA 17011 -0000
Loan Number: 100696665
Property Address: 2300 Market Street, Camp Hill, PA 17011-0000
PLEASE SEE THE ENCLOSED DOCUMENT
DACT91.10
This communal. << for attempting to collect a debt;
any 1 e, ° '""' i used for that purpose.
.0;
OCWEN Loan Servicing, LLC
12650 Ingenuity Drive
0 C W E N Orlando, Florida 32826
APPENDIX A
August 31, 2006
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
WWW.OCWEN.COM
This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific
information about the nature of the default is provided in the attached pages.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home.
This Notice explains how the program works.
To see if HEMAP can help you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN
THIRTY (30) DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you
when you meet with the Counseling Agency.
The name address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the
end of this Notice If you have any questions you may call the Pennsylvania Housing Finance Agency toll free at 1-800-
342-2397 (Persons with impaired hearing can call (717) 780-1869).
This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit
Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar
association may be able to heb you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A
CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION, OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO A ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. USTED PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL
PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM"
EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIIVIIR SU HIPOTECA.
HOMEOWNER'S NAME(S): Helen J. Myers
PROPERTY ADDRESS: 2300 Market Street,
Camp Hill, PA 17011-0000
LOAN ACCT. NO.: 100696665
ORIGINAL LENDER: NEW CENTURY MORTGAGE CORPORATION
CURRENT LENDER/SERVICER: OCWEN
DACT91.10
This communication is from a debt collector attempting to collect a debt;
any information obtained will be used for that purpose.
OCWEN Loan Servicing, LLC
12650 Ingenuity Drive
O'
O C W E N Orlando, Florida 32826 WWW.OCWEN.COM
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS.
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE
ASSISTANCE:
IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES
BEYOND YOUR CONTROL,
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY
THE PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE --Under the Act, you are entitled to a temporary stay of foreclosure on
your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-
to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING
MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE
ASSISTANCE YOU MUST BRING YOUR MORTGAGE- UP TO DATE. THE PART OF THIS NOTICE
CALLED"HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE
UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agency
listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this
meeting. The names addresses and telephone numbers of designated consumer credit counseling agencies for the county
in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face
meeting. Advise your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this
Notice (see following pages for specific information about the nature of your default.) 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 Homeowner's
Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's
Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the
end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you
in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be riled 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 YOUR APPLICATION 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 criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60)
days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued
against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania
Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE
FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE
CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance).
DACT91.10
This communication is from a debt collector attempting to collect a debt;
any information obtained will be used for that purpose.
OCWEN Loan Servicing, LLC
12650 Ingenuity Drive
.0 WWW.OCWEN.COM
o C W E N Orlando, Florida 32826
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property located at: 2300
Market Street, Camp Hill, PA 17011-0000
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts
are now past due:
2 payments in the amount of $ 838.00 from July 01, 2006 through August 31, 2006
DETAIL SUMMARY :
Principal and Interest ................................. $ 1,676.00
Interest Arrearage ..................................... $ 0.00
Escrow .................................................. $ 10,497.77
Late Charges ........................................... $ 505.06
Insufficient Funds Charges ........................... $ 25.00
Fees / Expenses ........................................ $ 1,013.57
Suspense Balance (CREDIT) ........................ $ 0.00
Interest Reserve Balance (CREDIT) ................ $ 0.00
TOTAL DUE .......................................... $ 13,717.40
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 $13,717.40, PLUS ANY MORTGAGE
PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments
must be made either by Money Gram Cashier's Check. Certified Check or Money Order made payable and sent to:
OCWEN
P.O. BOX 6440
CAROL STREAM, IL 60197-6440
IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the date of
this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire
outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in
monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender
also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property.
IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the
mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal
proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred up to
$50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually
incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender,
which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not
be required to pay attorney's fees.
OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all
other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the
THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and
prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paving 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.
DACT91.10
This communication is from a debt collector attempting to collect a debt;
any information obtained will be used for that purpose.
.......... .... OCWEN Loan Servicing, LLC
12650 Ingenuity Drive
O C W E N Orlando, Florida 32826
WWW.OCWEN.COM
EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriff s Sale of the
mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the
actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will
increase the longer you wait. You may find out at any time exactly what the required payment or action will be by
contacting the servicer.
HOW TO CONTACT THE SERVICER:
Name of Servicer: OCWEN
Address: P.O. BOX 24737
WEST PALM BEACH, FL 33416-4737
Phone Number: 800-310-9229
Fax Number: 407-737-6300
Contact: Performing Collections Dept.
EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged
property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove
you and your furnishings and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE - You may or X may not (CHECK ONE) sell or transfer your home to a buyer or
transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees
and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW
MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF
YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT
MORE THAN THREE (3) TIMES IN ANY CALENDAR YEAR)
TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER
LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER.
TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
DACT91.10
This communication is from a debt collector attempting to collect a debt;
any information obtained will be used for that purpose.
APPENDIX C
PENNSYLVANIA HOUSING FINANCE AGENCY
HOMBOWNER'S EbaROENCY MORTGAGE ASSISTANCE PROGRAM
CONSUMER CREDIT COUNSELING AGENCIES
(Rev. 6199)
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Wayrmsbng PA 15370 of dqo Valley 40 Fed Rkbardwo Avenue
714x52-2193 1671 Crcum Court Eart PA 19047
Whitcluill PA 13052 215)7504310
610x214011 or (800)220.2744(314) only AX (215)7504318
UtMSTRONG COUNTY AX (610)921-3932
CB
17CCS of Wemm Pemeylvanis, Ins. 'ty Normal Cmuslar. lne. 67 AB .y Ave, Y FL
217 E Plank Road 10 Box 244 Iddphia PA 19140
Ahoom PA 16602 (coma Square PA 19348 I5)4264025
;814)9444100 or (314)944-5747 610)444-3682 AX(21S)426-9122
AX (610)444-6243
]edit Camrdort of PA :ernenaidry Development Corp of FnAllerd
101 Wood Strad, Suite 906 620 Griscwn Street
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;412)3349954 or (900)737-2937 15)744-2990
-AX (412)336.9963 d-Fuhon Housing Smvices AX (215)7442012
, Bon 394
.dram Co. Commudty Action Program d PA 15537 aet Comselbg Service
127 W.W Street Box 197 _ 234129 I North Brad Sant
nd'mne PA 15701 814x23-7187
r hildelphia PA 19141
724)465-2657 15)7247500
-AX (724)465-5119 of Wesrem Ponmyl-ria, Ira. AX (215)324-9753
Plank Road
17
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3P,AVER MUNTY 1 814x44-BIOD or (814)944-5747 ISIS Market Suee1, Suite 1325
'Itiledelphin PA 19107
fiction Housin3, Ira. eymooe Ecmwndc Development Corporation 15)563-5665
125 6' Ave, Suite 950 954 Mary Grace Lam AX (215)S642666
'idsburgh PA 15219 aMslown PA 15901
X12)391-1956 814)5354556 ofDdawara VsBcy
-AX (412)3944512 :AX(814)539-1689 sews corporate Cmuer
606 Strom Road
4oucinE Opp.rWniliee of Bavm Cwmry, Tne edhaiation Office mole PA 19047
iW Qor lion St, S.K. 207 17 Mimi. Soot
Seaver, PA 45009 mtingdon PA 16652 of LcMgb Valley
724)728-7511 814)643-2343 671 Cresorst Court Ea
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4.usicrg Opportunities, Inc 610x214011 or (800)220-2733
133 Seventh Street RADFORD COUNTY AX (610)121-8932
PO Box 9
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755 York Rd. Suite 103 Whitebait PA 18052 Ccesou Squue PA 19349
WannioctarPA 19974 610)821.4011 or(SW)220-2733 610)444-3682
215044-9429 ;AX (610)9214932 AX(610)444-8243
FAX (215)9566344 of14 hiladelphia Council for Community Adv
Do North 17' So W, Suite 60D
I" E Dekxlb Pike
King orhumia PA 19406 400 Abington Exafedin Patsy Suite 1 laddphia PA 19103
8610)971-2210 Sunuuid PA 18411 15)567-7803
FAX (610)265-814 570)SS7A163 or (600)922-9537 AX (215)163.9941
AX (570)587-91349135
nmumiry Development Cary of Ftao?isrd
ILULER COUNTY 9 South 7' Snit ro4 Ministry
f PA 18360 Oriaaon Street
kcam Housing, has. 570)4204980 or (600)922-9537 'la lelphin PA 19124
25 6' Ave, Suite 950 AX (570)4204981 215)7442990
'rtsburgb PA IS219 AX (215)7442012
412)391-1956 or(4I2)281-2102 1 WMarket 5l
ilkes-Bam PA 19702
XX:S of Delaware Valley
AX (412)3914512 570)821-0637 -(800)922-9537 lull Btnlding
ousiog Opporhml0e, loc. AX (570)621-1765 90 E Market St. Suite 215
50 Corporate St, Suite 207 Veer Chetsa PA 19382
dmq. rt PA IS I32 631 S Athamn St, Suite 100 85)563.5665
!12)664-1590 We Colege PA 16801
AX (412)664.0873 14)238-3668 nsoriean credit Cwmdha Ludhte
AX (614)23&3669
OPPcthssitle. Inc. 5 Co= St
33 Sevo th Sheet an Bsoonudct opportunity or y county tesnlle PA 19320
10 BOX 9 63 Astur LA DO 8683212.6741
eKeaport PA 15134 ilkes-Bana PA IBM
412)664.1906 $70)8264510 a ($W)622-0359 55 York Rd, Suhe 103
AX (412)664067'1 AX (S70)829-166S--CALL BEPORE FAXING arumiustar PA 18974
570)4554994 HAZEL70N 15)444.9429
X3CS of Wmoro PA AX (570)455.5631-CALL BBFORE FAXING AX (215)956.6344
CA Bu'Idiug 570)6364090 7UNKHANNOCK
39 North Washingtun Street 44 E. Dekdb Pate
utter PA 16001 ' of Prnnia PA 19406
724)262.7812 610)971-2210
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Valley UamgAoyed Committee X:cS of Westw Peoosylvasia, htc.
20 E 9' Avenue I7 L Phak Road
omestnd PA 15120 Utocami PA 16602
COVN7Y
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412)462-9962 614)944-11100
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I Wood Street, Suite 906 138 Lincoln Shod letter PA 16001
'nsbrngh PA 15222 Box 1326 412)282-7812
412)338-9954 or (BOD)737-2933 illiampor' PA 17703
AX (412)336.9%3 570)3264587
;AX(570)3n-2i97 MEARFIELD
AMBRIA COUNTY omeut aucn Pennsylvania B-ww Develop- C°P°mlon
631 S Altmann St. Su ht 100 954 Mary Oraee Leon
ford-Fdton Housing gerrleas College PA 16801 PA 15901
ILD d1, Box 384 814)23/-3666 614)535.6556
verortPA I5537 - - AX (81!)236.3669 A7C (1114)539-1666
814)623-9129
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27 WatarSheet, Box 197 570)3264587 614)944=6100
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4)465-2657
ofWcstem PA
AX (724)465.5116 l9-ACollegePatappark t P p
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of Weskm PA ohnslo" PA 15904
19-A Cdkga Park Plea ketere Housing Corporation 814)539-0335
aLumwn PA 15904 North Broad Strut
hial'A 19130
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814)5394445 i
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15)765-1221 7 Wsue Street, Box 197
of Western PamAvanin, less. --AX(215)765-)427
ndimu PA 15701
Ptak Road
17 E 724)465-2657
.
Noona PA 16602 odgd Counseling Center AX (724)46f-51111
914)9444100 7 North Frnh Strad
- PA 19601
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-9X.(814)4445747 630)3717666 631 S Atherim Sy Suite 100
Enumerate Development Cmpora6oo AX (610)375-7830 tate College PA 16MI ,
954 Mary Grace lane 611)238-36611
d nsur" PA 15901 CE AX (814)232.3669
814)5354556 67 Aneghary Ave, 2° FL
•AX(814)539-1666 'kdelpbis PA 19140
15)42641025 N COUNTY
ablela ul Service, Inc. AX (215)4269122
)souring-Clinton Counties
35 East Main Street
onversot PA 15501 edis Fenowehip House m For Continually Action (STEP)
814) 445.9622 or (800)152-0148 _ 42 S Jackson St 139 Lincoln Snit
AX (814)443-3690 edia PA 19063 Box 1326
610565-0846 dliampott PA 17703
AX (610)565-0567 570)326-0597
AMERON COUNTY AX (5711)322-2197
"their Community Servke Inc.
athem Tier Comnudry Action Corp 39 E King Stied ?CCS of Nmdwsvm PA
box 369 Ps 17602 1 Basin sued
IS Wet 4' Strad 17)397-5162 or (2W)726-5062 M.O. only) dliamsport PA 17703
mporium PA 15834 AX (717)3994127 570)323-0627
814)4661161 AX (570)3236626
AX (S 14)486-0825 ncri- Red Cross of Cheda
sf orlhesm- Pennsylvania
of Western Pennsylvania, Inc. 729 Edgement Ave
PA 19013 631 S Adtestoa St, Suits 100
17 T Plant Road 610)47414114 s. College PA 16801
I oona PA 16602 914)239.3668
214)444-8I00 4orthwese Cotmsding Services AX (614)236.3669
AX (614)9445747 1 N Broad Sued
laddphia PA 19141
215)324-75W
ARBON COUNTY rA
X X (215)3242753
u ofDeinwere Va0ay t6le6od Savior Inc
515 Market Soma. Suite 1325 Cerra Avenue
It W Markel Bl laddphia PA 19107 PA 15501
Boa 1127 15)563-5665 9628
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570)821-0837 or (BO )M-9537
AX (570)821-1785
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S Jack= Bow igh Sow
100 Abington Psavtive Paris. Subc I .die PA 19063 wg PA 15370
Stonmit PA 18411
610)565-0846 4)252-2293
570)587-9163 or (00)92&9537 AX (610)565-8567
ayme county commonalty Acbm, AXmwy loo'
AX (570)587-913419(75 ,hiladalpim Council for Coomomiy Adv 37 North Beeson Avenue
. on Eecamoies Oppmomiry Of I. Cmmty 00 North 17' Strad, Suite 60D nionWam PA 15401
63 Amber Loon Maticiphin PA 19103 4)437.6050 m (S00)427-DM
i0ra-111ane PA 18702 15)567-7803 AX (412)437.4418
570)826-0510 our (900)822-0359 AX (215)963-9941
AX (570)829.1665-CALL BEFORE FAIONO or Wesley PA
570)4554994 HAZELTON Red Coos ofCbMW 99 Edimm Btreet
AX (570)455-5631-CALL BEFORE FAXMG 729 Pdgeroont Ave ioniwn PA 15401
570)8364090 TUNKHANNOCR MeowPA 19013 24)439-9939
610)874-1484
m Valley Unemployed Committee
WPORD COUNTY 4ortheext Concealing S-Ams 20 E. 9' Avenue
Mill N Barad Strew amcsk*d PA 15120
locker T. Washington Cemc Iadelpia PA 19141 412)462-9962
720 Holland Strom 15)8247500 .
' PA 16503 AX (215)324.6753
14)4531744
AX (614)453-5749 MCE
67 Alkdreny Ave, V Fl,
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I Ead 20` Sow 15)4768025 Bar 547
' PA 16510 AX (215)476.9122 arme PA 16365
814)296.0400 814)726-2400
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Bon 244
Erie Co wnwelty Action Commune 'normal Square PA 19348
9 Wm 9• Sow 610)4)8-3662 NKLM COMM
PA 16501 AX (610)444-6243
814)4591581 mocial Services Uolludled
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roup, Ministry ayarshm0 PA 17268
Roomlio Valley Urban Lenguc, Inc i6M Chisom Sow 17)762-3285
11m8aen Awnw, hr7addphis, PA 19124
artdl PA 16121 15)7442990 of wester, Pennsylvania, bra
_
412)881.5310 AX (215)744-21112 12 South Getup sued
oak PA 17403
xxS of De6ware Valley 17)8161176
,UMBERLAND COUNTY 20 North Pmvkk a Road
nd'ta PA 19063 Aaiun Cannosim of do Capita Reim
7CCS of Wessem Pennsylvania, for. 15)563.5665 514 Dory Sow
Lloglestmen Rod isirrisburg PA 17104
Jarosburg PA 17102 CCI 17)32.9757
17541-1757 75 Stafford Ave, Suite 1 AX(717)234-2227
AX (717)541.4670 alma PA 19097
610)87)-2210
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107 N 6' Stray larrislemS PA 17102
iu6sbwgPA 17101 kCC1 17)541-1757
17)234-5925 M E Delmlb Pike AX (717)5414670
AX (717)434.9459 Cing of Pnusia PA 19406 '
610)911-2210 GtiCCaWide
umemist Cou scilng services of Fankfm 1 a hod
1 Wed 31 Street I70I3
?wrfijk PA
ayoesboro PA 17268
COUNTY 7
17)243-3819
17)762-3285 AX (717)731-9589
ofs F. Keomdy Caner, Irrc
MCA oCCariisle MI Fad 20'Sam Red Crom--Hanova Chapter
OI G Strom !,k PA 16510 29 Carlisle Stroa
We PA 17013 814)1199-0400 iseene- PA 17331
717)243-3818 AX (914)898-1247 17)34.5925
AX (717)731-9589 -AX(717)637-3294
TierCorm oraiyAction Corp
?omamxnity Action Commission of the Capita Region BOX 389 rbm Lugar orMcuopolhan Harrisburg
514 Dory Sued 35 Wen 4' Stray 107 N 6' Stew
anisburt PA 17104 ampodomPA 15634 wridmrg PA 17101
717)232-9757 814)486.1161 17)2345925
AX (717)8342227 AX (614)/66-0825 AX (717)234-9459
kdame County Housing Authority Wants County Housing Authority
39143 Carlisle St 39-143 Carlisle SL
anysburg PA 17325 ettyshu%PA 17325
17)3341518 mka T. Washington Center 7175341518
AX (717)334.8326 720 Helfand Strom AX (717)334-8326
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S of Watem Pennsylvani., Inc. ch. F. Kennedy Center, Inc ford-Fulton Housing Services
Lingkswm Road MI East 20' Soot 1, Boa 394
shurg PA 17102 PA 16510 ses PA 15537
541-1757 814)898-0400 523-9129
(717)541-4670 AX (814)698-1243 (814523-7187
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N 6' sued AYFITE COUNTY oak PA 17403
sburg PA 17101 17)9461176
12345925 . cfum Nwsing, loc.
(717)2349459 25 6' Ave, Suite 950 atheriention Office
iltsburigh PA 15219 17 Mifflin Steal
412)391-1956 or (412)281.2102 untingdon PA 16652
AWARE COUNTY AX (412)3914512 814543-2343
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125 6" Am B?ube 950 400 Abin" B.?ve Pak Suite I North Crnoc Street
aim.brmgh PA 15219 Summitt PA 18411 «uvOle PA 17901
570)622-1995
:4 12)391-1956 or (412)221-2)M 570)587-9163 0 (600)4Y1-9537
AX (570)587-913419135 AX (570)622-0429
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W.yneabmg PA 15370
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714)852-2893
FAX (412)627-7713 B-244
Square PA 19348
1 W Market St
Mon Valley Unemployed Committee 610)1443682 Box 1127
111 s Bare PA 16702
620 E 9' Aveau AX (610)?44-8243 14637 or (608)922.9537
ormod ad PA 15120
412)462-9962 of Wcalau PeonrAvall* Imo -AX (S
AX (570)821-1765
AX (412)162-964 12 South Gorge Street
ale PA 17403
400 Abington Pxwudn Pak Suite 1
of WeaWe Pennsylvania, loo. 717))464176 naftSummittPA 18411
570)597.9163 or (800)922-9537
North
Square
Gadm Cerra Drive
xcs of Ldtigh Valley
AX (570)587-913419135
reembag PA 15601 671 Crescent Court End
'Ieh.O PA 16052
I Bak Strut
724)939-12PO 15)9214011 or (B00)220-2733 ilba nspon PA 17703
17) k (914) ONLY 570)323.6627
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136 I?unln Strut
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Mrod 34129
914)6 717)497-5192 a(SW)789-5062 10 Ben 1328
AX (814)623-7167
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Blianrpurt PA 17707
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570)326-0587
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17 Mifflin Street WRENCE CQUIWJY
antinaion PA 16652
of Wedeu Pansyknda, lmc ' Federal PIa Suite 406 F. Kerady Center, lee
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21 E.0 20
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12 ieskw Strad. Strife 227
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INDIANA COUNTY
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35 Was 4' Send
of Wrsfeu Pennsylvania, lea Valley Urban League, Inc. 'm PA 15834
North Gale SRUlne I lodinm Avenue 614)"&1161
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Gordan Center Drive mell PA 16121
reeniwrS PA 15601 724))81-5310
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Coystoot geoeo we Development CompmalM n Corporation S4 Suite 207
;hwnaaZDVallcy Urban League, Inc.
954 Mary Gape lame PA 15009
4)729-7202 1 Indiana A-
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814 35.6556 AX (412)728-7202
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_ _
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Water Snack Box 167
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39 North Washington Street
24)465- 5-15701
4)a2657
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AX (724)465-5116
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570)62.2-1995
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akratov,n PA 15904 abn CmanmitySwA=Jrc.
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914)539-6333 39 BKng Sued
P. 17602 '
17 E. Plank Road
17)397-5182 or (800)788-3062 Boas PA 16602
EFFEIWN CDUNIY AX (717)3994127 814)944-8100
AX (814)944.5747
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21 Ba120' Street
IGH COUNTY OF Notlnnsleo PA
XCS
' PA 16510
814)898-0100
of Lebigh Valley 631 S Atherton St. Suite 100
tale College PA )6901
AX (814)998-1243 71 decent Court Fad 614)278-3668
Whitehall PA 1912 AX (914) 238.3669
ndiara Co. Community, Action Pmgraa 610)8214011 or (800)220.2733
0rmimion Office
27 Water Strad. Box 187 570)&(B14)ONLY
AX (610)921-8932 a
17 Mifflin SOW
odiana PA 157D1 mlngdon PA 16652
24)465.2657
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25 Nato Centre Sena
of Wham- PA
i ottsville PA 17901
570)522-1995
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PA 16001 AX (570)622.0429
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570)921-0637 or (800)922.9537
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Wilkes-11- PA 18702
South r SUat
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( (814)944-5747 AX (570)821-1765 570) 420-BM or (800)922-9537
AX (570)4204981
aheiadon Off- 400 Abingmn E-tive Park SWtc 1
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400 Abington Executive Park Suite I
Mifflin Surat
tingdon PA 16652 570)587-9163 or (800)922-9537 "larks Summdlt PA 18411 ,
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,ICAWANNA COIJNfY 63 Amber Lane 'aimouEconomics Opportunity ofLureme County
ilk.-Bare PA 18702 63 Amber Lane
S of NordmLnem Pennsylvania 570)926-0510 a (600)822-0359 ilkec-Bane PA 16702
M Housing Corporation
North Stood Street
trmlphia PA 19130
)7651221
1427
'(215)765
S ofDdawoe Valley
is- Salomon Center
W Gemaolown Pilot, Saito 140
Utown PA 19401
)563.5665
:hwal Comseliog S-ima
I N Bond Street
defphia PA 19141
0324-750D
(215)3248753
saun)ty Action Development Commission
De1s1b Sum
iKtmvn PA 19401
1)2776363
:(610)277-2123
I w market St
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Jig-4to ,PA 18702
570)921-0837 or(800)922.9537
AX (570)921-1785
400 Abington Exnontive Park, Suite 1
3aft Stmrn)D PA 16411
S70)587.9163 or (800)922-9537
AX (570)587-91349135
I Basin Shea
IlianspM PA 17703
570)32341627
AX (570)3236626
iconomic Opportunity Cah)og of Sd*knl Carty
25 North Centre Street
WuWlcPA 17901
CCCS of W natural Perosyhwdi, Inc.
WW Linglemn'n Rod
Harrisburg PA 17102
717)5471757 -
?AX (717)5414670
Jrbw L." of Mehopoliton Hoodshwg
1107 N 6a Stod
Harrisburg PA 17101
717)2345925
-AX (717V34.9459
YWCA ofCdisk
101 G Sued
?jtriislc PA 17013
is Fellowship House
S Jackson Street
M. PA 19063
)565-0846
:(610)565-8567
:A
North IT Street, Suite; 600
addpbis PA 19103
S of Demme Valley
Chary H)1L Suite 215
ry Hill NJ 09002
)563-5665
sing Association of Delaware Valley
wawa smack Suite 601
delpw PA 19102
)5456010
(ZIS)79O9132
sing Assoddoo dDelaware Valley
North watts Shea
Jelphia PA 19123
P Murky
tar, sow
ddpida PA 19124
7442990
(215)7442012
Coon St
1rsvBk PA 19320
)5126!41
E Dtdnlb Pike
g of huada PA 19406
1)971-nlD
Yodc K Suite 103
otiooer PA 18974
(215)9566344
ker St
1127
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-0637 err (SOO)22.9537
0)921-1785
r(570)921-1785
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wg PA 18360 -OM or (800)9n-9537
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gtm Fnautive Pak, Suite 1
tnnsiti PA 19411
-9163 x(800)522-9337
)597-91349135
mnanelal Counseling Services of Fssnkiia
1 West 3• Sbeet
aynabom PA 17268
[717)762-3285
INeaheriestian Of6ee
?17 MiMin Snag
Hnotingdoo PA 16652
514)543-2343
Caononity Action Conmisaion of the Capital Reim
1514 Deny Shea
Harisbwg PA 17104
717)232-9757
?AX (717)2342227
?onm Horning Corporation
146 North Baud Street
'hOddphis PA 19130
'215)765-1221
sAX (215)765.1427
Jothweal Counseling Scr Acc
MI N Baud Street
'hiladclphia PA 19141
215)3247500
?AX (215)3248753
_CCS of Ddawae Valley
1515 Market Strut, Suite 1325
Philadelphia PA 19107
215)563-5665
PAX(215)563-7020
here Tier Community Action Corp
West 4• Street
omium PA 15834
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7)2329757
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954 Mary Gone Ion
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reencbuq PA 15601
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19-A College Park Pit=
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114)5396335
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31 North Curler Axerwe
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10)291-2101
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10)7245252
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nkhwtoeh PA 18657
gal Counseling Carter 3anstan Street. PO Box 399
North Fifth Sued ax (570)297-2799
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Anon Lane 570)25348941
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70)297-2101
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7 Cmfkm Street
dlxbom PA 16901
570)724-5252
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03 Warren Street, PO Box 709
uakhzmoek PA 16657
570)836.6640
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95 Ehmin Street, PO Bm 218
f my PA 16947
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4)4554561
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112)391-1956 or (412)281-2102
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2 Owdes, Cara Drive
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24)938-1290
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112)464-1590
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570)587-9163 or (800)422-9537
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13 Sevm& Shea
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N Wood Sacet, Suite 906
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)D Abington Executive Path, Suite t
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'0)587-9163 a (SW)922.9537
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570)297-2101
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4)852-2893
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E. 91 Avenue
mvtesd PA 15120
)462.9962
(412)462-9964
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East Main Street
sweet PA 15501
)445-9628 on (B00)452-0148
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RICHARD F. STERN, ESQUIRE
STEVEN K. EISENBERG, ESQUIRE
BRADLEY D. SISLEY, ESQUIRE
STERN AND EISENBERG LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
U.S. Bank, N.A., as Trustee for Morgan Stanley
Dean Witter Capital I Inc. Trust 2001-NC4, by its
attorney in fact, Ocwen Loan Servicing, LLC,
successor to Ocwen Federal Bank
Civil Action Number: 06-6596 Civil
Term
V.
Helen J. Myers and
The United States of America c/o The U.S.
Attornev's Office
MORTGAGE FORECLOSURE
PRAECIPE FOR ENTRY OF JUDGMENT AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Enter judgment in favor of Plaintiff and against Defendant Helen J. Myers for failure of said Defendant
to file a responsive pleading to the Complaint within twenty (20) days of service thereof.
PRINCIPAL BALANCE .......................................................$77,705.69
INTEREST accrued thru 11/08/2006 of ............................... $4,193.17
Interest after 11/08/2006 shall accrue at the per diem
rate of $27.19.)
LATE CHARGES accrued thru 11/08/2006 of .....................$546.96
Late charges after 11/08/2006 shall accrue at the monthly
rate of $41.90.)
ESCROW ADVANCES ........................................................ $10,497.77
FEES BILLED ....................................................................... $1,483.91
COSTS ................................................................................... $300.00
ATTORNEY'S FEE .............................................................. $3,900.00
3:\Anne\Sales\Cumberland\Ocwen.Myers.1.07. doc
Sub-Total Through Date of Complaint ............................$98,627.50
ACCRUED INTEREST after 11/08/2006 shall accrue
at the per diem
rate of $27.19 to January 23, 2007 ......................................... $2,066.44
ACCRUED LATE CHARGES Late charges
after 11/08/2006 accruing at the monthly rate of $41.90
through January 23, 2007 ....................................................... $83.80
TOTAL DUE THROUGH DATE OF REQUEST
FOR JUDGMENT ................................................................. $100,777.74
STERN AND EISENBERG LLP
BY:
BRADLEY,Z. SISLEY,
Attorney for Plaintiff
JAAnne\Sales\Cumberland\Ocwen. Myers. 1.07.doc
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RICHARD F. STERN, ESQUIRE
STEVEN K. EISENBERG, ESQUIRE
BRADLEY D. SISLEY, ESQUIRE
STERN AND EISENBERG LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
U.S. Bank, N.A., as Trustee for Morgan Stanley
Dean Witter Capital I Inc. Trust 2001-NC4, by its
attorney in fact, Ocwen Loan Servicing, LLC,
successor to Ocwen Federal Bank
V.
Helen J. Myers and
The United States of America c/o The U.S.
Office
Civil Action Number: 06-6596 Civil
Term
MORTGAGE FORECLOSURE
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA:
SS
COUNTY OF MONTGOMERY
I, the undersigned, being duly sworn according to law, deposes and says, to the best of his
knowledge, information and belief, Defendant's:
Last-known address is
2300 Market Street, Camp Hill, PA 17011
2. Is over the age of twenty-one.
3. Is not now nor has been within the last six (6) months in the Armed Services of the
United States as defined in the Soldiers' Civil Relief Act of 1940, as amended.
COMMONWEALTH C" ' f,LNNSYL,VANIA
NOTARI-^J_ SEAL
HELEN CAPASSO, Notary Public
Jenkintown Boro.. Montgomery County
My Commission Expires October 21, 2008
Sworn to and subscribed bef re me
this , Day of
, 2007.
2 tz,: ?j
STERN AND EISENBERG LLP
BY:
TRADLEY D. SIS
Attorney or Plaintiff
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RICHARD F. STERN, ESQUIRE
STEVEN K. EISENBERG, ESQUIRE
BRADLEY D. SISLEY, ESQUIRE
STERN AND EISENBERG LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
U.S. Bank, N.A., as Trustee for Morgan Stanley
Dean Witter Capital I Inc. Trust 2001-NC4, by its
attorney in fact, Ocwen Loan Servicing, LLC,
successor to Ocwen Federal Bank
Civil Action Number: 06-6596 Civil
Term
V.
Helen J. Myers and
The United States of America c/o The U.S.
MORTGAGE FORECLOSURE
Office
CERTIFICATION UNDER RULE 237.1
I, the undersigned attorney on the writ and attorney for Plaintiff, hereby certify that a ten-day
notice of intention to enter judgment by default was sent to Defendant in accordance with Pa. R.C.P.
No. 237.1., a true and correct copy of which is attached hereto.
STERN AND EISENBERG LLP
BY:
BRADLEY . SISLEY
Attorney for Plaintiff
J:\Anne\Sales\Cumberland\Ocwen. Myers.1.07. doc
10
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
U.S. BANK, N.A., as Trustee,
By its attorney in fact,
Ocwen Loan Servicing, LLC, successor
To Ocwen Federal Bank
VS.
HELEN J. MYERS AND
THE UNITED STATES OF AMERICA
To: Helen J. Myers
2300 Market Street
Camp Hill, PA 17011
Date of Notice: January 9, 2007
NO. 06-6596 CIVIL TERM
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS
YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY
BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR
PROPERTY OR OTHER IMPORTANT RIGHTS. [YOU SHOULD TAKE THIS NOTICE TO A
LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO
OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL
HELP)
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.
ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
COURT ADMINISTRATOR
4TH FL., CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 240-6200
STERN AND EISENBERG LLP
BYJ4/-??`
RICHARD F. STERN
Attorney for Plaintiff
The Pavilion
261 Old York Road, Suite 410
Jenkintown, PA 19046
(215) 572-8111
I. D. #03315
J:\ANGELA\TEN DAY\CUMBERLAND\OCWEN.MYERS.CUMBERLAND.10.DAY.1.07.DOC
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
r
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Caption:
U.S. Bank, N.A., as Trustee for Morgan
Stanley Dean Witter Capital I Inc. Trust
2001-NC4, by its attorney in fact, Ocwen
Loan Servicing, LLC, successor to Ocwen
Federal Bank vs.
Helen J. Myers a d _"_
0
TO THE PROTHONOTARY OF THE SAID COURT:
( ) Confessed Judgment
( x) Other
File No. 06-6596 Civil Tern
Amount Due $100,777.74
Interest from 1/23/07 at the per diem rate of
$27.19 until judgment is paid ill
Atty's Comm
Costs
The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or
account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed
pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the Sheriff of Cumberland
for debt, interest and costs, upon the following described property of the defendant(s)
2300 Market Street, Camp Hill, PA 17011 (See full legal description attached)
County,
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of County, for debt, interest and
costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real
estate, supply six copies of the description; supply four copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
(Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the
defendant(s) described in the attached exhibit.
Date January 23, 2007 Signature:
Print Name: Bradle Sisle Es re
e av ion, ad
Address: Suite 410
Attorney for
Telephone:
Supreme Court ID No.:
Jenkintown, PA 19046
Plaintiff
(215) 572-8111
200040
(over)
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;,egal Description
ALL `bat 3extain t.-act or piece of laud Ritua.ts ix the Borough cf Cm* Sill, County of
Cumberland and stare of Panw7lvania, more particularly botuded and aes=ibnd as
fol2ca, to vita
BBG7 "-= at the narthweet cs:ner of Ramiltaa street, now :5=ty-third Street, and
Market Street; r.2?euca is a uortheriy ditectiort, along the east aide of Uxilton ?
Street, nounly=ty-third Street, two hu4&ed five (209) feet to a point; thauae
waotwaray, T,.IMV laude of D. Mvia DeVA, one hundred fatty-faux (1441, fact, mere or
lase, no a point; thence soutbxardty along lot of MUM Egolf, one uUndred ninety-si.x
and f.fve are-handredths (196.05) rent to a curb line ova Mmeket Streets tbance
eastwardly, zO=g the cgrb line of the north side of :east street, aas bu=Ired
tot-xy-tout (5.") feet, more or less, to the glace of nqz ,
SS= improved by a two and ane-lself story brick dwelling and aecaceary outbuildings,
kaom ai and numbered 2306 Xarket street, Camp Hill, 8a.
•
3
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-6596 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due U.S. BANK, N.A., AS TRUSTEE FOR MORGAN
STANLEY DEAN WITTER CAPITAL I INC. TRUST 2001-NC4, BY ITS ATTORNEY IN FACT,
OCWEN LOAN SERVICING, LLC, SUCCESSOR TO OCWEN FEDERAL BANK, Plaintiff (s)
From HELEN J. MYERS
(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 ?j
garnishee and is enjoined as above stated.
Amount Due $100,777.74 L.L. $.50 I
Interest FROM 1/23/07 AT THE PER DIEM RATE OF $27.19 UNTIL JUDGMENT IS PAID IN
FULL
Atty's Comm %
Atty Paid $181.31
Plaintiff Paid
Date: JANUARY 31, 2007
(Seal)
Due Prothy $1.00
Other Costs
e?1?749-ea
Curti R. Long, P on tary
By:
Deputy
REQUESTING PARTY:
Name BRADLEY D. SISLEY, ESQUIRE
Address: THE PAVILION, 201 OLD YORK ROAD
SUITE 410
JENKINTOWN, PA 19046
Attorney for: PLAINTIFF
Telephone: 215-572-8111
Supreme Court ID No. 200040
N I
RICHARD F. STERN, ESQUIRE
STEVEN K. EISENBERG, ESQUIRE
BRADLEY D. SISLEY, ESQUIRE
STERN AND EISENBERG LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTowN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
U.S. Bank, N.A., as Trustee for Morgan Stanley
Dean Witter Capital I Inc. Trust 2001-NC4, by its
attorney in fact, Ocwen Loan Servicing, LLC,
successor to Ocwen Federal Bank
Civil Action Number: 06-6596 Civil
Term
V.
Helen J. Myers and
The United States of America c/o The U.S.
Attorney's Office
MORTGAGE FORECLOSURE
CERTIFICATE UNDER ACT 91 OF 1983
It is hereby certified that the Sheriffs Sale scheduled in the above-captioned matter is not
protected under the Homeowner's Emergency Assistance And Mortgage Foreclosure Act, P.L. 1688,
No. 621 because notice, as required, was sent to Defendant and no timely response was made.
STERN AND EISENBERG LLP
BY:
BRADL Y D. SISLE
Attorney for Plaintiff'
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RICHARD F. STERN, ESQUIRE
STEVEN K. EISENBERG, ESQUIRE
BRADLEY D. SISLEY, ESQUIRE
STERN AND EISENBERG LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FAcsmu,E: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
U.S. Bank, N.A., as Trustee for Morgan Stanley
Dean Witter Capital I Inc. Trust 2001-NC4, by its
attorney in fact, Ocwen Loan Servicing, LLC,
successor to Ocwen Federal Bank
Civil Action Number: 06-6596 Civil
Term
V.
Helen J. Myers and
The United States of America c/o The U.S.
Attorney's Office
MORTGAGE FORECLOSURE
CERTIFICATION OF ADDRESS
It is hereby certified that the last known addresses of the parties are as follows:
U.S. Bank, N.A., as Trustee, by its attorney in fact,
Ocwen Loan Servicing, LLC, successor to Ocwen Federal Bank
1661 Worthington Road, Suite 100
West Palm Beach, FL 33409
(Plaintiff)
Helen J. Myers
2300 Market Street
Camp Hill, PA 17011
(Defendant)
The United States of America c/o The U.S. Attorney's Office
William T. Nealon Bldg.
235 N. Washington Avenue
Scranton, PA 18501
(Defendant)
STERN AND EIS BERG LLP
BY:
BRADLE. SISLEY
Attorne for Plaintiff
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RICHARD F. STERN, ESQUIRE
STEVEN K. EISENBERG, ESQUIRE
BRADLEY D. SISLEY, ESQUIRE
STERN AND EISENBERG LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKiNTowN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
U.S. Bank, N.A., as Trustee for Morgan Stanley
Dean Witter Capital I Inc. Trust 2001-NC4, by its
attorney in fact, Ocwen Loan Servicing, LLC,
successor to Ocwen Federal Bank
Civil Action Number: 06-6596 Civil
Term
V.
Helen J. Myers and
The United States of America c/o The U.S.
MORTGAGE FORECLOSURE
s Office
AFFIDAVIT PURSUANT TO RULE 3129.1
I, the undersigned attorney for Plaintiff in the above caption, sets forth as of the date the Praecipe for
the Writ of Execution was filed, the following information concerning the real property located at 2300
Market Street, Camp Hill, PA.
1. Name and address of Owner(s) or Reputed Owner(s):
Helen J. Myers
2300 Market Street
Camp Hill, PA 17011
2. Name and address of Defendant(s) in the judgment:
Helen J. Myers
2300 Market Street
Camp Hill, PA 17011
3. Name and last known address of every judgment creditor whose judgment is a record lien on the
real property to be sold:
Internal Revenue Service
Federated Investors Tower
Thirteenth Floor, Suite 1300
1001 Liberty Avenue
Pittsburgh, PA 15222
J:\Anne\Sales\Cumberland\Ocwen.Myers.1.07. doc
44
4. Name and address of the last recorded holder of every mortgage of record:
NIA
5. Name and address of every other person who has any record lien on the property:
N/A
6. Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale:
N/A
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:
Domestic Relations Tax Claim Bureau
Cumberland County Cumberland County Courthouse
13 North Hanover Street One Courthouse Street
Carlisle, PA 17013 Carlisle, PA 17013
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.
Date: January 23, 2007
STERN AND EISENBERG LLP
BY:
BRADL Y D. SISLEY
Attorney for Plaintiff
J:\Anne\Sales\CumberlandlOcwen.Myers.1.07. doc
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RICHARD F. STERN, ESQUIRE
STEVEN K. EISENBERG, ESQUIRE
BRADLEY D. SISLEY, ESQUIRE
STERN AND EISENBERG LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSDYME: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
U.S. Bank, N.A., as Trustee for Morgan Stanley
Dean Witter Capital I Inc. Trust 2001-NC4, by its
attorney in fact, Ocwen Loan Servicing, LLC,
successor to Ocwen Federal Bank
V.
Helen J. Myers and
The United States of America c/o The U.S.
Attorney's Office
Civil Action Number: 06-6596 Civil
Term
MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Helen J. Myers The United States of America c/o The U.S. Attorney's Office
2300 Market Street William T. Nealon Building
Camp Hill, PA 17011 235 North Washington Avenue
Scranton, PA 18501
Your real estate at 2300 Market Street, Camp Hill, PA is scheduled to be sold at Sheriffs Sale on
Wednesday, June 13, 2007 at 10:00 A.M., at Sheriffs Office, Cumberland County Courthouse,
Carlisle, PA 17013 (location of sale) to enforce the court judgment of $100,777.74 obtained by U.S.
Bank, N.A., as Trustee, by its attorney in fact, Ocwen Loan Servicing, LLC, successor to Ocwen
Federal Bank against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be canceled if you pay to Stern and Eisenberg, LLP the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may call Stern and
Eisenberg LLP, telephone (215) 572-8111.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,
if the judgment was improperly entered. You may also ask the Court to postpone the sale for good
cause.
J:\Anne\Sales\Cumberland\Ocwen.Myers.1.07. doc
.. 0
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you will
have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid by calling Stem and Eisenberg LLP, telephone (215) 572-8111.
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 Stern and Eisenberg LLP, telephone (215) 572-8111.
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 on a date specified by the
Sheriff no later than 30 days after the sale date. 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 date of filing
of said schedule. You should check with the Sheriffs Office by calling (717) 240-6390 to determine
the actual date of filing of said schedule.
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.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
800-990-9108
717-249-3166
3:\Anne\Sales\Cumberland\Ocwen.Myers.1.07. doc
V .
RICHARD F. STERN, ESQUIRE
STEVEN K. EISENBERG, ESQUIRE
BRADLEY D. SISLEY, ESQUIRE
STERN AND EISENBERG LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACsgynE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
U.S. Bank, N.A., as Trustee for Morgan Stanley
Dean Witter Capital I Inc. Trust 2001-NC4, by its
attorney in fact, Ocwen Loan Servicing, LLC,
successor to Ocwen Federal Bank
V.
Helen J. Myers and
The United States of America c/o The U.S.
s Office
Civil Action Number: 06-6596 Civil
Term
MORTGAGE FORECLOSURE
RE: PREMISES: 2300 Market Street, Camp Hill, PA
Dear Sir or Madam:
Please be advised that I represent the above creditor that has a judgment against the above Defendant.
As a result of a default, the above referenced premises, also described on the attached sheet, will be
sold by the Sheriff of Cumberland County on Wednesday, June 13, 2007 at 10:00 A.M. at Sheriffs
Office, Cumberland County Courthouse, Carlisle, PA 17013 (subject to change without further notice).
The sale is being conducted pursuant to the judgment in the amount of $100,777.74 together with
interest, costs (and such other allowed amounts) thereon entered in the above matter in favor of
Plaintiff against the above-named Defendant(s) who is/are also the real owner of said premises. I have
discovered that you may have a lien and/or interest in the premises to be sold. This notice is given so
that you can protect your interest, if any, in the lien you have on the premises. If you have any
questions regarding the type of lien or the effect of the Sheriff s Sale upon your lien, we urge you to
CONTACT YOUR ATTORNEY, as we are not permitted to give you legal advice.
A Schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30
days after the sale date and the distribution will be made in accordance with the schedule unless
exceptions are filed thereto within ten (10) days thereafter.
January 23, 2007 ST AND EISEN ERG LLP
BY:
BRADLEY . SISLEY
Attorney for Plaintiff
J:\Anne\Sales\Cumberfand\Ocwen.Myers. 1.07. doc
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VZ tUat certaixt Cwact or piees of land #itua.ts in the Bovaugh of emV Hill, amaty of
Cumberland at-d state of rou"ylveaia, more particularly bounded and deaoribad as
f ollowa, to vit 2 ,
BBG at rise antheost corner of Hamilton st rest, now '.i =ty-third Straeti, and
karket Btrfet; th= o in a = th=ly diteatiou, the west aide of Ramiltom
Street, now 2veuty-third street, two fired five (20S) feet to a points then a
wgatvardZy, slc>sg lands of D. X&dzs Deals, cue burAzed forty-taut (144; fees, mere or
lose, to at point; taancet sovthvasdty 4ong lot of AdM4 Eg*lt, Cne hunch;; aaiaery-nix
and five =-a-buu redths 1196.051 feet to a curb 1Sne on XWxet stxeett tbauce {
eaatmardly, along the curb line of the north aide of Maeloet street, cne bundred
forty-four tMA) leer, mars ei, lemE, to the place of SWIM=,
2=0 isproved by a two a rA aua-Ulf story brick dwelling and r.ECec$ary outbdI4iugs,
kao ne as and numbered 2306 Mvxket Meet, Camp Sill, Pa,
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL ACTION-LAW
RICHARD F. STERN, ESQUIRE
STERN AND EISENBERG LLP
The Pavilion
261 Old York Road, Suite 410
Jenkintown, PA 19046
(215) 572-8111
I.D. #03315
U.S. BANK, N.A.,
as Trustee, by its attorney in fact,
Ocwen Loan Servicing, LLC, successor
to Ocwen Federal Bank
VS. : NO. 06-6596 CIVIL
HELEN J. MYERS AND
The United States of America
c/o The U.S. Attorney's Office
CERTIFICATE OF SERVICE
I, RICHARD F. STERN, attorney for the within Plaintiff, hereby
notice of the
Sheriff s Sale was mailed to the Defendants by certified mail, return receipt re flested on March
14, 2007.
I further certify that notice of the Sheriff's Sale was mailed to each lie*lder by regular,
first-class, postage prepaid mail on March 14, 2007 as evidenced by copy of c4dificates of
mailing attached.
STERN AND EISENBERG
f,y
BY:
RICHARD F. STERN
Attorney for Plaintiff
3/19/07
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U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Received From:
woe oiece of ordinary mail addressed to. i
Internal Revenue Service
Federated Investors Tower
Thirteenth Floor, Suite 1300
1001 Liberty Avenue
Pittsburgh, PA 15222
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SHERIFF'S RETURN - REGULAR
CASE NO: 2006-06596 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
U S BANK N A
VS
MYERS HELEN J ET AL
SHANNON SHERTZER , Sheriff or Deputy Sheriff f
Cumberland County,Pennsylvania, who being duly sworn acco ing to law,
says, the within COMPLAINT - MORT FORE was served upon
MYERS HELEN J the
DEFENDANT , at 1643:00 HOURS, on the 1st day of Dec(
at 2300 MARKET STREET
CAMP HILL, PA 17011 by handing to
a true and attested copy of COMPLAINT - MORT FORE
r , 2007
togo?ther with
and at the same time directing Her attention to the conte4s thereof.
Sheriff's Costs: So Answers:
Docketing 18.00
Service 12.32 .?C
Affidavit .00
Surcharge 10.00 R. Thomas Kline
.00
4- Y 40.32 01/05/2007
STERN & EISENBERQ
Sworn and Subscibed to By:
before me this day
of A.D.
Deputy Sffer
c
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2006-06596 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
U S BANK N A
VS
MYERS HELEN J ET AL
R. Thomas Kline , Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT to wit:
UNITED STATES OF AMERICA THE
but was unable to locate Them in his bailiwick. He therefore
deputized the sheriff of LACKAWANNA County, Penn lvania, to
serve the within COMPLAINT - MORT FORE
On January 5th , 2007 , this office was in rece
attached return from LACKAWANNA
Sheriff's Costs: So answe
Docketing 6.00
Out of County 9.00
Surcharge 10.00 R. Thomas Kli
Postage 1.59 Sheriff of Cumberland
Lackawanna County 32.40
58. 99
01/05/2007
STERN & EISENBERG
Sworn and subscribe to before me
this day of ,
of the
ty
A. D.
In The Court of Common Pleas of Cumberland County, P ennsylvania
US Bank NA
vs. '
Helen J.Myers et al
SERVE: The United States of America No. 06-659 civil
Now November 16, 2006 , I, SHERIFF OF CUMBERLAND C TY, PA, do
hereby deputize the Sheriff of Lackawanna County to execut e this Writ, this
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland C ty, PA
,!In6
Affid
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Now, , 20 , at o'clock served the
within
upon
at
by handing to
a copy of the original
and made known to the conte thereof.
So answers
,
Ln
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C r
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= Sheriff of County, PA
COSTS
Sworn and subscribed before SERVICE $
me this day of , 20 MILEAGE
AFFIDAVIT
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-00560 T
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF LACKAWANNA
US BANK NA
VS
U.S.A. C/O US ATTYS OFICE
C') M hk < N c? e _ ??u
C to to `, ` ? to
GLENN CAPMAN , Deputy Sheriff of Lackawan,
County, Pennsylvania, who being duly sworn according to la,
says, the within COMPLAINT MORT. FORE. was served upon
TT C n r~ /n TT q ATTY' S OFFICE
County
the
DEFENDANT at 0010:45 Hour, on the 29th day of November , 2006
at 235 N.WASHINGTON AVE
SCRANTON, PA 18501 by handing to
KAREN MUSLOSKI,RECEPTIONIST
a true and attested copy of COMPLAINT MORT. FORE.
and at the same time directing Her attention to the conte? s thereof.
Sheriff's Costs: So Answers:
Docketing U .00 John Szymanski, Sheriff_
Service d .00
Affidavit .00
00 -
Surcharge
00 Deputy er
.00 00/00/0000
me this togelther with
Sworn and Subscribed to before
U.S. Bank, N.A., as Trustee for Morgan Stanley In the Court of Common Pleas of
Dean Witter Capital I Inc. Trust 2001-NC4, by Cumberland County, Pennsylvania
Its attorney in fact, Ocwen Loan Servicing, LLC Writ No. 2006-6596 Civil Term
Successor to Ocwen Federal Bank
VS
Helen J. Myers and The United States of America
c/o The U.S. Attorney's Office
Cpl. Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that on
March 22, 2007 at 2023 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: Helen J. Myers,
by making known unto Helen Myers, personally, at 2300 Market Street, Camp Hill, Cumberland
County, Pennsylvania its contents and at the same time handing to her personally the said true and
correct copy of the same.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a
diligent search and inquiry for the within named defendant, to wit: The United States of America
c/o The U.S. Attorney's Office, but was unable to locate them in his bailiwick. He therefore
deputized the Sheriff of Lackawanna County, Pennsylvania to serve the within Real Estate Writ,
Notice of Sale and Description according to law.
Lackawanna County Return: And Now, March 28, 2007 at 1500 hrs served the within Real
Estate Writ, Notice of Sale and Description upon The United States of America c/o The U.S.
Attorney's Office by handing to Mary Beth Mikolayczak, adult in charge, a true and correct copy of
the same and making known unto her the contents thereof at the William T. Nealon Building, 235
N. Washington Ave., Scranton, Pennsylvania 18501. So answers: John Szymanski, Sheriff of
Lackawanna County.
Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on April
12, 2007 at 0906 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 Helen J. Myers, located at 2300
Market Street, Camp Hill, 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 defendants, to wit: Helen J.
Myers and The United States of America c/o The U.S. Attorney's Office, by regular mail to their
last known address of 2300 Market Street, Camp Hill, PA 17011 and The William T. Nealon
Building, 235 N. Washington Ave., Scranton, PA 18501, respectively. These letters were mailed
under the date of April 24, 2007 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 instruction from Attorney Bradley Sisley.
Sheriff s Costs:
Docketing 30.00
Poundage 70.00
Advertising 15.00
Posting Handbills 15.00
Mileage 28.80
Levy 15.00
Surcharge 30.00
Prothonotary 1.00
Law Library .50
Out of County 9.00
Lackawanna County 27.40
Share of Bills 16.17
Law Journal 355.00
Patriot News 297.89
$ 910.76 f !,/G -il0 7
So Answer ..
R. Thomas Kline, Sheriff
BY ?J a C vv??
Real Estate puty
p-0 -5-2 pq 'I
93.SLo
0
RICHARD F. STERN, ESQUIRE
STEVEN K. EISENBERG, ESQUIRE
BRADLEY D. SISLEY, ESQUIRE
STERN AND EISENBERG LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKNTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACsuvnE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
U.S. Bank, N.A., as Trustee for Morgan Stanley
Dean Witter Capital I Inc. Trust 2001-NC4, by its
attorney in fact, Ocwen Loan Servicing, LLC,
successor to Ocwen Federal Bank
Civil Action Number: 06-6596 Civil
Term
V.
Helen J. Myers and
The United States of America c/o The U.S.
MORTGAGE FORECLOSURE
Office
AFFIDAVIT PURSUANT TO RULE 3129.1
I, the undersigned attorney for Plaintiff in the above caption, sets forth as of the date the Praecipe for
the Writ of Execution was filed, the following information concerning the real property located at 2300
Market Street, Camp Hill, PA.
1. Name and address of Owner(s) or Reputed Owner(s):
Helen J. Myers
2300 Market Street
Camp Hill, PA 17011
2. Name and address of Defendant(s) in the judgment:
Helen J. Myers
2300 Market Street
Camp Hill, PA 17011
3. Name and last known address of every judgment creditor whose judgment is a record lien on the
real property to be sold:
Internal Revenue Service
Federated Investors Tower
Thirteenth Floor, Suite 1300
1001 Liberty Avenue
Pittsburgh, PA 15222
J:\Anne\Sales\Cumberland\Ocwen.Myers.1.07.doc
4. Name and address of the last recorded holder of every mortgage of record:
N/A
5. Name and address of every other person who has any record lien on the property:
N/A
6. Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale:
N/A
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:
Domestic Relations Tax Claim Bureau
Cumberland County Cumberland County Courthouse
13 North Hanover Street One Courthouse Street
Carlisle, PA 17013 Carlisle, PA 17013
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.
Date: January 23, 2007
STERN AND EISENBERG LLP
BY:
BRADL Y D. SISLEY
Attorney for Plaintiff
J:\Anne\Sales\Cumberland\Ocwen.Myers. 1.07.doe
RICHARD F. STERN, ESQUIRE
STEvEN K. EISENBERG, ESQUIRE
BRADLEY D. SISLEY, ESQUIRE
STERN AND EISENBERG LLP
THE PAviLioN
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
U.S. Bank, N.A., as Trustee for Morgan Stanley
Dean Witter Capital I Inc. Trust 2001-NC4, by its
attorney in fact, Ocwen Loan Servicing, LLC,
successor to Ocwen Federal Bank
Civil Action Number: 06-6596 Civil
Term
V.
Helen J. Myers and
The United States of America c/o The U.S.
Attorney's Office
MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Helen J. Myers The United States of America c/o The U.S. Attorney's Office
2300 Market Street William T. Nealon Building
Camp Hill, PA 17011 235 North Washington Avenue
Scranton, PA 18501
Your real estate at 2300 Market Street, Camp Hill, PA is scheduled to be sold at Sheriffs Sale on
Wednesday, June 13, 2007 at 10:00 A.M., at Sheriffs Office, Cumberland County Courthouse,
Carlisle, PA 17013 (location of sale) to enforce the court judgment of $100,777.74 obtained by U.S.
Bank, N.A., as Trustee, by its attorney in fact, Ocwen Loan Servicing, LLC, successor to Ocwen
Federal Bank against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be canceled if you pay to Stern and Eisenberg, LLP the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may call Stern and
Eisenberg LLP, telephone (215) 572-8111.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,
if the judgment was improperly entered. You may also ask the Court to postpone the sale for good
cause.
J:\Anne\Sales\Cumberland\Ocwen.Myers. 1.07.doc
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you will
have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid by calling Stem and Eisenberg LLP, telephone (215) 572-8111.
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 Stem and Eisenberg LLP, telephone (215) 572-8111.
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 on a date specified by the
Sheriff no later than 30 days after the sale date. 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 date of filing
of said schedule. You should check with the Sheriffs Office by calling (717) 240-6390 to determine
the actual date of filing of said schedule.
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.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
800-990-9108
717-249-3166
JAAnne\Sales\Cumberland\Ocwen. Myers.1.07.doc
RICHARD F. STERN, ESQUIRE
STEVEN K. EISENBERG, ESQUIRE
BRADLEY D. SISLEY, ESQUIRE
STERN AND EISENBERG LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
U.S. Bank, N.A., as Trustee for Morgan Stanley
Dean Witter Capital I Inc. Trust 2001-NC4, by its
attorney in fact, Ocwen Loan Servicing, LLC,
successor to Ocwen Federal Bank
V.
Helen J. Myers and
The United States of America c/o The U.S.
Office
Civil Action Number: 06-6596 Civil
Term
MORTGAGE FORECLOSURE
RE: PREMISES: 2300 Market Street, Camp Hill, PA
Dear Sir or Madam:
Please be advised that I represent the above creditor that has a judgment against the above Defendant.
As a result of a default, the above referenced premises, also described on the attached sheet, will be
sold by the Sheriff of Cumberland County on Wednesday, June 13, 2007 at 10:00 A.M. at Sheriff s
Office, Cumberland County Courthouse, Carlisle, PA 17013 (subject to change without further notice).
The sale is being conducted pursuant to the judgment in the amount of $100,777.74 together with
interest, costs (and such other allowed amounts) thereon entered in the above matter in favor of
Plaintiff against the above-named Defendant(s) who is/are also the real owner of said premises. I have
discovered that you may have a lien and/or interest in the premises to be sold. This notice is given so
that you can protect your interest, if any, in the lien you have on the premises. If you have any
questions regarding the type of lien or the effect of the Sheriff s Sale upon your lien, we urge you to
CONTACT YOUR ATTORNEY, as we are not permitted to give you legal advice.
A Schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30
days after the sale date and the distribution will be made in accordance with the schedule unless
exceptions are filed thereto within ten (10) days thereafter.
January 23, 2007
STS AND EISEN ERG LLP
BY: -?
BRADLEY . SISLEY
Attorney for Plaintiff
J:\Anne\Sales\Cumberlan d\Ocwen. Myers. 1.07.doc
:legal Descrigtioa
ALx, that xrtsiA cract or Pleas of lead aitnate i72 the 84XCLi01 of ash Kill, Co=ty of
Cimberlaad acd state of BenvAylvania, more particularly bounded KrA deacrii;ed as
follow, to wits
22QrY "-= at the n=chw"r ce-rncr of Umi.ltoa street, maw :wr=ty-third street, and
Market atreet; thence is a =rtberly dixectiou, along the Beat aide of u iltou
street, Tow 1ve=p-third Street, two !hundred five (3051 feet to a poiet= then a ;
waotwarAy, x1ang lands of D. Rdwiu Dean, ana buudred forty'-tor (.442 feet, mere or
leee, to s point, thence sautbwxdly along lot of Adieu '89olf, cne btudxad aimety-six
and five =-e-buwdredtha (196.05) lest to P. curb line 4a Mmexat &treett tbance i
eaatwardly, zi log the eyrb line of the narth side of .gazImt surogt, =a bu--.&ed I
fo:^ty-tout f..K2 feet, Mors by lem to the place of WAlRbTOG,
$KnM iarsnved by a two rnd dnet-Wf story brick dxellLng and awacsary outboAdings,
kv.-Otmt aE " numbered 3300 Market Street, Camp Rill, Pa.
10
RICHARD F. STERN, ESQUIRE
STEVEN K. EISENBERG, ESQUIRE
BRADLEY D. SISLEY, ESQUIRE
STERN AND EISENBERG LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOwN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACS9,11LE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
U.S. Bank, N.A., as Trustee for Morgan Stanley
Dean Witter Capital I Inc. Trust 2001-NC4, by its
attorney in fact, Ocwen Loan Servicing, LLC,
successor to Ocwen Federal Bank
Civil Action Number: 06-6596 Civil
Term
V.
Helen J. Myers and
The United States of America c/o The U.S.
MORTGAGE FORECLOSURE
Office
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Helen J. Myers The United States of America c/o The U.S. Attorney's Office
2300 Market Street William T. Nealon Building
Camp Hill, PA 17011 235 North Washington Avenue
Scranton, PA 18501
Your real estate at 2300 Market Street, Camp Hill, PA is scheduled to be sold at Sheriffs Sale on
Wednesday, June 13, 2007 at 10:00 A.M., at Sheriffs Office, Cumberland County Courthouse,
Carlisle, PA 17013 (location of sale) to enforce the court judgment of $100,777.74 obtained by U.S.
Bank, N.A., as Trustee, by its attorney in fact, Ocwen Loan Servicing, LLC, successor to Ocwen
Federal Bank against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be canceled if you pay to Stern and Eisenberg, LLP the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may call Stern and
Eisenberg LLP, telephone (215) 572-8111.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,
if the judgment was improperly entered. You may also ask the Court to postpone the sale for good
cause.
J:\Anne\Sales\Cumberland\Ocwen.Myers. 1.07.doc
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you will
have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid by calling Stem and Eisenberg LLP, telephone (215) 572-8111.
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 Stern and Eisenberg LLP, telephone (215) 572-8111.
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 on a date specified by the
Sheriff no later than 30 days after the sale date. 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 date of filing
of said schedule. You should check with the Sheriffs Office by calling (717) 240-6390 to determine
the actual date of filing of said schedule.
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.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
800-990-9108
717-249-3166
JAAnne\Sales\Cumberland\Ocwen. Myers.1.07.doc
:,egal Description
ALL that -er`.ain tract or piece of land aitvate it the Borough of Cusp Kill, County of j
Cumberland and State of Ponamylva ia, more particularly bounded and deza=Vmd as
f ollco, to ' it a
saar?M"m at Lbe =rt t c== of Ramilton street. now :wmty-third Street, and
tearket 9treat; the=e is a, ncrtberly &.tection, aloug the asst aide of Hamilton ?
Street. tow Iventy-third 9treat, two hutdred five (205) feet to a poihtj then e
wsatwaray, rilmV lands of D. R&-Jzs Doma, oua huadsed fcttV-four f14411 fem, mere or
lest, to a paint; r-sauce soutbkardly 4ong lot of Ad W4 Bgolf, me U%uKl: ed uincxy-six
and flvs axa-hundradthe 1196.05) feet to z curb line = knecct Street[ thence i
eastwtrdly, zacing the cysts Luse of the north side of :earl tt street, tae hundred
fo.-ty-four 4.,Eil faet, more or lean, to the place of 8&rUWDM,
BZnM ii*ro ad by a two and aua-Wf story brick d.?alliug sad macessaay outbaildiw3d,
kaown ai: and uumbe-red 23Ga Market Street, Camp Hill, Pa.
7
4
3
1,'V'RIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 06-6596 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due U.S. BANK, N.A., AS TRUSTEE FOR MORGAN
STANLEY DEAN WITTER CAPITAL I INC. TRUST 2001-NC4, BY ITS ATTORNEY IN FACT,
OCWEN LOAN SERVICING, LLC, SUCCESSOR TO OCWEN FEDERAL BANK, Plaintiff (s)
From HELEN J. MYERS
(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 $100,777.74 L.L. $.50
Interest FROM 1/23/07 AT THE PER DIEM RATE OF $27.19 UNTIL JUDGMENT IS PAID IN
FULL
Atty's Comm % Due Prothy $1.00
Atty Paid $181.31 Other Costs
Plaintiff Paid
Date: JANUARY 31, 2007
ltr'-44
Curtis A. Long, P otary
(Seal) By:
Deputy
REQUESTING PARTY:
Name BRADLEY D. SISLEY, ESQUIRE
Address: THE PAVILION, 201 OLD YORK ROAD
SUITE 410
JENKINTOWN, PA 19046
Attorney for: PLAINTIFF
Telephone: 215-572-8111
Supreme Court ID No. 200040
Real Estate Sale # 76
On March 14, 2007 the Sheriff levied upon the
defendant's interest in the real property situated in
Camp Hill Borough, Cumberland County, PA
Known and numbered as 2300 Market Street,
Camp Hill, more fully described on Exhibit "A"
filed with this writ and by this reference
incorporated herein.
Date: March 14, 2007 By
Real Esta a Sergeant
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:
April 20, 27, May 4, 2007
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.
i Marie Coyne, ditor
SWORN TO AND SUBSCRIBED before me this
4 day of May, 2007 _
NOTARIAL SEAL
LOIS E. SNYDER, Notary Public
Carlisle Boro, Cumberland County
My Commission Expires March 5, 2009
RZAL 'PATS SAW NO. 76
Writ No. 2006-6596 Civil
U.S. Bank, NA, as Trustee for
Morgan Stanley Dean Witter
Capital I, Inc. Trust 2001-NC4,
by its attorney in fact, Ocwen
Loan Servicing LLC successor to
Ocwen Federal Bank
VS.
Helen J. Myers and
The United States of America
c/o The U.S. Attorney's Office
Atty.: Bradley Sisley
Legal Description
ALL that certain tract or piece of
land situate in the Borough of Camp
Hill, County of Cumberland and
State of Pennsylvania, more particu-
larly bounded and described as fol-
lows, to wit:
BEGINNING at the northwest
corner of Hamilton Street, now
Twenty-third Street, and Market
Street; thence in a northerly direc-
tion, along the west side of Hamilton
Street, now Twenty-third Street,
two hundred five (205) feet to a
point; thence westwardly, along
lands of D. Edwin Dean, one hun-
dred forty-four (144) feet, more or
less, to a point; thence southwardly
along lot of Adam Egolf, one hun-
dred ninety-six and five one-hun-
dredths (196.05) feet to a curb line
on Market Street; thence east-
wardly, along the curb line of the
north side of Market Street, one
hundred forty-four (144) feet, more
or less, to the place of BEGINNING.
BEING improved by a two and
one-half story brick dwelling and
necessary outbuildings, known and
numbered 2300 Market Street,
Camp Hill. PA.
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
Shannon D. Billhime, being duly sworn according to law, deposes and says:
That she is a Staff Accountant with 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 18th and 25th day(s) of April and the
2nd day(s) of May 2007. 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
SALE#76
Sworn to and subscribe y we:bi%$OV*MN@f 16107 A.D.
Notarial Seal
'rerry L. Russell, Notary Public
City of Harrisburg, Dauphin County
LJy gommission Expires June 6, 2010
j / Mem r, Penns nip ?lssociati;n of Notaries
/ NO RY PUBLIC
CUMBERLAND COUNTY SHERIFF'S OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
IN THE COURT OF r MMON PLEAS OF CUMBERLAND C- ' 1NTY, PENNSYLVANIA
CIVIL DIVISION
E a PRAECIPE FOR WRIT OF EXECUTION
Caption:
U.S. Bank, N.A., as Trustee for Morgan
Stanley Dean Witter Capital I Inc. Trust
2001-NC4, by its attorney in fact, Ocwen
Loan Servicing, LLC, successor to Qcwen
Federal Bank vs.
( ) Confessed Judgment
( x) Other
File No. 06-6596 Civil Tern
Amount Due $100,777.74
Helen J. Myers and Interest from 1/23/07 at the per diem rate of
The United States of America $27.19 until judgment is pa in fu-
IT-c/o The U.S. Attorney's Office : Atty's Comm
Costs
TO THE PROTHONOTARY OF THE SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or
account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed
pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the Sheriff of Cumberland County,
for debt, interest and costs, upon the following described property of the defendant(s)
2300 Market Street, Camp Hill, PA 17011 (See full legal description attached)
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of County, for debt, interest and
costs, as above, directing attachment against the above named garnishee(s) for the following property (if real
estate, supply six copies of the description; supply four copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
(Indicate) Index this writ against the garnishee(s) as a lis pendens against real
defendant(s) described in the attached exhibit.
Date December 21, 2007 Signature:
Print Name:
Address: Stern and Eisenberg
2" 'Id--1'e!E ?Gad, S"to A10
Jenkintown, PA 19046
Attorney for: Plaintiff
Telephone: (215)572-8111
Supreme Court ID No.: 200040
(over)
70
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Legal DescriptioA
ALL that aortaira tract or pieao of land p:Lt:[ to iz the eotough of Came RU L' ao=ry of
t,=berlamdi and state of Pm=sylvaaia, more partieui.ar'!y bounded and deac=ibed as
tDILGRO. to wit:3 ,
29 X0 at the aarthwegttc coffer of klamUtma Street, taow .VeaT-thiw'a Street, acrd '
Market 8tseetp rbenoe in s uaxth=ly di7cation, slang the war-1; aide of amiltom ?
Street, now Icy-third Street, trio fired five (205) feet to a poszt; then e
waotvardty, 0.om lands of D. 8&do Do=. one k Allred loaty-faun (144; feast, more or
lose, to a paint; rbeuce soutumvilly along lot of Adwo Egolt, sae btuKbed iaiaexy-Six
and live cues-biudredthm (196.45) feet to a curb JjAe as tAe=t &etcet f thence i
eaatwardty, aioug the cw b 11-me of the aarth side of IMlarImt Street, cae hu.-rdred
fotry-four (5.E4) fact, more or leas, to the place Of Smibiwm,
Sgnt3 iMpt.oVad by E two and due-Ulf story brick dwalliug and recassary outbuildinep,
kwon ai and numbered 2300 X=ket Meet, Camp Hill, Pa.
440M . i
3
RICHARD F. STERN, ESQUIRE
STEVEN K. EISENBERG, ESQUIRE
BRADLEY D. SISLEY, ESQUIRE
STERN AND EISENBERG LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
U.S. Bank, N.A., as Trustee for Morgan Stanley
Dean Witter Capital I Inc. Trust 2001-NC4, by its
attorney in fact, Ocwen Loan Servicing, LLC,
successor to Ocwen Federal Bank
Civil Action Number: 06-6596 Civil
Term
V.
Helen J. Myers and
The United States of America c/o The U.S.
Attorney's Office
MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO RULE 3129.1
I, the undersigned attorney for Plaintiff in the above caption, sets forth as of the date the Praecipe
for the Writ of Execution was filed, the following information concerning the real property
located at 2300 Market Street, Camp Hill, PA.
1. Name and address of Owner(s) or Reputed Owner(s):
Helen J. Myers
2300 Market Street
Camp Hill, PA 17011
2. Name and address of Defendant(s) in the judgment:
Helen J. Myers
2300 Market Street
Camp Hill, PA 17011
3. Name and last known address of every judgment creditor whose judgment is a record lien on
the real property to be sold:
Internal Revenue Service
Federated Investors Tower
Thirteenth Floor, Suite 1300
1001 Liberty Avenue
Pittsburgh, PA 15222
4. Name and address of the last recorded holder of every mortgage of record:
J:\SUPRIYA\SALES\CUMBERLAND\OCWEN.MYERS.RELIST.12.07.DOC
N/A
5. Name and address of every other person who has any record lien on the property:
N/A
6. Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
N/A
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:
Domestic Relations Tax Claim Bureau
Cumberland County Cumberland County Courthouse
13 North Hanover Street One Courthouse Street
Carlisle, PA 17013 Carlisle, PA 17013
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.
Date: December 21, 2007
STERN AND
BY:
BRADLEY D.
Attorney for PI;
LLP
3:\SUPRIYA\SALES\CUMBERLAND\OCWEN.MYERS.RELIST.12.07.DOC
Q
Q
C=3
^r r ;
CD "?
RICHARD F. STERN, ESQUIRE
STEVEN K. EISENBERG, ESQUIRE
BRADLEY D. SISLEY, ESQUIRE
STERN AND EISENBERG LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FAcsnvmE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
U.S. Bank, N.A., as Trustee for Morgan Stanley
Dean Witter Capital I Inc. Trust 2001-NC4, by its
attorney in fact, Ocwen Loan Servicing, LLC,
successor to Ocwen Federal Bank
V.
Helen J. Myers and
The United States of America c/o The U.S.
Attorney's Office
To:
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
Helen J. Myers The United States of America
2300 Market Street William T. Nealon Building
Camp Hill, PA 17011 235 North Washington Avenue
Scranton, PA 18501
Your real estate at 2300 Market Street, Camp Hill, PA is scheduled to be sold at Sheriffs Sale
on Wednesday, JUNE11, 2008 at 10:00 A.M., at Sheriffs Office, Cumberland County
Courthouse, Carlisle, PA 17013 (location of sale) to enforce the court judgment of $100,777.74
obtained by U.S. Bank, N.A., as Trustee, by its attomey in fact, Ocwen Loan Servicing, LLC,
successor to Ocwen Federal Bank against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be canceled if you pay to Stern and Eisenberg, LLP the back payments, late
charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may
call Stern and Eisenberg LLP, telephone (215) 572-8111.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to postpone the
sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
Civil Action Number: 06-6596 Civil
Term
MORTGAGE FORECLOSURE
J:\SUPRIYA\SALES\CUMBERLAND\OCWEN.MYERS.RELIST.12.07.DOC
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may
find out the price bid by calling Stern and Eisenberg LLP, telephone (215) 572-8111.
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 Stern and Eisenberg LLP, telephone (215) 572-8111.
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 on a date specified by
the Sheriff no later than 30 days after the sale date. 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 date of filing of said schedule. You should check with the Sheriffs Office by
calling (717) 240-6390 to determine the actual date of filing of said schedule.
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.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
800-990-9108
717-249-3166
J:\SUPRIYA\SALES\CUMBERLAND\OC WEN.MYERS.RELIST.12.07.DOC
RICHARD F. STERN, ESQUIRE
STEVEN K. EISENBERG, ESQUIRE
BRADLEY D. SISLEY, ESQUIRE
STERN AND EISENBERG LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FAcsikaLE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
U.S. Bank, N.A., as Trustee for Morgan Stanley
Dean Witter Capital I Inc. Trust 2001-NC4, by its
attorney in fact, Ocwen Loan Servicing, LLC,
successor to Ocwen Federal Bank
V.
Helen J. Myers and
The United States of America c/o The U.S.
Attorney's Office
Civil Action Number: 06-6596 Civil
Term
MORTGAGE FORECLOSURE
RE: PREMISES: 2300 Market Street, Camp Hill, PA
Dear Sir or Madam:
Please be advised that I represent the above creditor that has a judgment against the above
Defendant. As a result of a default, the above referenced premises, also described on the
attached sheet, will be sold by the Sheriff of Cumberland County on Wednesday, June 13, 2007
at 10:00 A.M. at Sheriffs Office, Cumberland County Courthouse, Carlisle, PA 17013 (subject
to change without further notice).
The sale is being conducted pursuant to the judgment in the amount of $100,777.74 together with
interest, costs (and such other allowed amounts) thereon entered in the above matter in favor of
Plaintiff against the above-named Defendant(s) who is/are also the real owner of said premises. I
have discovered that you may have a lien and/or interest in the premises to be sold. This notice
is given so that you can protect your interest, if any, in the lien you have on the premises. If you
have any questions regarding the type of lien or the effect of the Sheriff s Sale upon your lien, we
urge you to CONTACT YOUR ATTORNEY, as we are not permitted to give you legal advice.
A Schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later
than 30 days after the sale date and the distribution will be made in accordance with the schedule
unless exceptions are filed thereto within ten (10) days thereafter.
December 21, 2007
BY:
STERN
BRADLEY D.,$JR
Attorney for Plainti
LLP
J:\SUPRIYA\SALES\CUMBERLAND\OCWEN.MYERS.RELIST.12.07.DOC
aegal Drscrigtioa
AM tut --cxta= tract or gi6cs of laved Situates in the Borough of cxV Bill, CourXy of ,
rspbazlsad =d state of Peau sylvania, more particularly bounded and deacribnd as
fold, to ait3 ,
22MMMIM at the northwest s o~r = of Rumiltma 81 rect, mov Nerity-tbirn Street, as
MrkeLt M=W; thence in s :sotto Iy dixeetioa, alcmg the rest aide Of 5as4ltou
St3nmt, now 7v=tY-third Street, two huxdred five (205) feet to a pout; thence
WA0twardty, along lands of D. 8dii.n DeaA, one hundred forty-fc= (144; feet, maze or
lest-:, to s pcdzt; women soutbuardly aloug lot of AdIam mgolf, cos hUndrsd rdafty-Six
and live ane-hUxIredtbB (196.05) 'feet to a curb Liza on Muket street, thence i
eaatwardly, alaag the cgXb Lies of the anrth side of 1.14nimt atse gt, one hu.&ed ?
fo.`^ty-tour 0.") feet, mor* or lest-, to the plane of BF.E'zmvm,
B&M iVrotrxl by a two am4 arses-Wf story brick dwelling and ammagaay outb¢ildi gs,
laomt at- a rA numbexed 2306 Xmice:t h'tr-eet, CWV Hill, Pa,
+i?rn
10
3
RICHARD F. STERN, ESQUIRE
STEvEN K. EISENBERG, ESQUIRE
BRADLEY D. SISLEY, ESQUIRE
STERN AND EISENBERG LLP
THE PAvn,ION
261 OLD YORK ROAD, SUITE 410
JENKINTowN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACsnvELE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
U.S. Bank, N.A., as Trustee for Morgan Stanley
Dean Witter Capital I Inc. Trust 2001-NC4, by its
attorney in fact, Ocwen Loan Servicing, LLC,
successor to Ocwen Federal Bank
V.
Helen J. Myers and
The United States of America c/o The U.S.
Attomev's Office
Civil Action Number: 06-6596 Civil
Term
MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Helen J. Myers The United States of America
2300 Market Street William T. Nealon Building
Camp Hill, PA 17011 235 North Washington Avenue
Scranton, PA 18501
Your real estate at 2300 Market Street, Camp Hill, PA is scheduled to be sold at Sheriffs Sale
on Wednesday, JUNE11, 2008 at 10:00 A.M., at Sheriffs Office, Cumberland County
Courthouse, Carlisle, PA 17013 (location of sale) to enforce the court judgment of $100,777.74
obtained by U.S. Bank, N.A., as Trustee, by its attorney in fact, Ocwen Loan Servicing, LLC,
successor to Ocwen Federal Bank against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be canceled if you pay to Stern and Eisenberg, LLP the back payments, late
charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may
call Stern and Eisenberg LLP, telephone (215) 572-8111.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to postpone the
sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
J:\SUPRIYA\SALES\CUMBERLAND\OCWEN.MYERS.RELIST. 12.07.DOC
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may
find out the price bid by calling Stem and Eisenberg LLP, telephone (215) 572-8111.
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 Stem and Eisenberg LLP, telephone (215) 572-8111.
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 on a date specified by
the Sheriff no later than 30 days after the sale date. 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 date of filing of said schedule. You should check with the Sheriffs Office by
calling (717) 240-6390 to determine the actual date of filing of said schedule.
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.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
800-990-9108
717-249-3166
J:\SUPRIYA\SALES\CUMBERLAND\OCWEN.MYERS.RELIST.12.07.DOC
1
J ,
;,cgal DM-Rczi,ptioa
ATtL •.#rat xr'.j? e-aet or Pieos of land yitnate in tl?e eorongh of CaUP Hill, Cb=ktp of f
C•amberland and state of I=usyjvaai4, more particularly bounded and dcacri?e3 as
follm. to wit: ,
SBG= MG at tba nart r drier of Ummiltoa street, ww
Ma :5aesltg-tf3irti BtSeet, =d
x7cet Bcz,eet ; the=* in a stesthcrly di.tactian, along the wgst side of F3mtltoa
Ltvgmt, Aav Wmuty-Wdrd Street, txo hu4dred five (205) feet to ac point, tkeune
asptwardrtv, 11009 lands of D. R&dn Dcam, ona hundred forty-fouz (144) feet, ante or '
leM, to s Paint; theuea eovtbuardly 4ong lot of Ad km Egolf, sae hundred uiaety-sisc
and five =ca-bWlrefthm {196.05) feet to a curb line = Ples.Yret strcet? tbewe i
eastwudly, Clang the cwrb Bete of tits earth side of :haft Street, sae bu--.&ed ?
foray-four 0.") fan, more or lees, to the place Of 8EEtugm,
i
BE= iWovcA by & two and atu -W r story brick dwelling and raceasary outbailcittgs,
kmom as and =umbe ed 230-6 M=ket Meet, C=np Hill, Pa.
10
3
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-6596 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due U.S. BANK, N.A., as Trustee for MORGAN STANLEY
DEAN WITTER CAPITAL 1 INC. TRUST 2001-NC4, by its attorney in fact, OCWEN LOAN
SERVICING, LLC, successor to OCWEN FEDERAL BANK, Plaintiff (s)
From HELEN J. MYERS and THE UNITED STATES OF AMERICA c/o THE U.S.
ATTORNEY'S OFFICE
(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 $100,777.74
L.L.
Interest from 1/23/07 at the per diem rate of $27.19 until judgment is paid in full
Atty's Comm %
Atty Paid $1,113.57
Plaintiff Paid
Date: 1/02/08
(Seal)
REQUESTING PARTY:
Due Prothy $2.00
Other Costs
A 38
Proth notary
By: p
Deputy
Name BRADLEY D. SISLEY, ESQUIRE
Address: STERN AND EISENBERG
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PA 19046
Attorney for: PLAINTIFF
Telephone: 215-572-8111
Supreme Court ID No. 200040
.s STEVEN K. EISENBERG, ESQUIRE
BRADLEY D. SISLEY, ESQUIRE
STERN AND EISENBERG LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
U.S. Bank, N.A., as Trustee for Morgan Stanley
Dean Witter Capital I Inc. Trust 2001-NC4, by its
attorney in fact, Ocwen Loan Servicing, LLC,
successor to Ocwen Federal Bank
V.
Helen J. Myers and
The United States of America c/o The U.S.
Office
Civil Action Number: 06-6596 Civil
Term
MORTGAGE FORECLOSURE
AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1
I, the undersigned attorney for Plaintiff in the above caption, sets forth as of the date the Praecipe
for the Writ of Execution was filed, the following information concerning the real property
located at 2300 Market Street, Camp Hill, PA.
1. Name and address of Owner(s) or Reputed Owner(s):
Helen J. Myers
2300 Market Street
Camp Hill, PA 17011
2. Name and address of Defendant(s) in the judgment:
Helen J. Myers
2300 Market Street
Camp Hill, PA 17011
3. Name and last known address of every judgment creditor whose judgment is a record lien on
the real property to be sold:
Internal Revenue Service
Federated Investors Tower
Thirteenth Floor, Suite 1300
1001 Liberty Avenue
Pittsburgh, PA 15222
Capital One Bank
C/o James C. Warmbrodt
Weltman, Weinberg & Reis Co., L.P.A.
436 Seventh Avenue, Suite 2718
Pittsburgh, PA 15219
J:\SUPRIYA\SALES\CUMBERLAND\OC WEN.MYERS. RELIST.12.07.DOC
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL ACTION-LAW
RICHARD F. STERN, ESQUIRE
STERN AND EISENBERG LLP
The Pavilion
261 Old York Road, Suite 410
Jenkintown, PA 19046
(215) 572-8111
I.D. #03315
U.S. BANK, N.A.,
as Trustee, by its attorney in fact,
Ocwen Loan Servicing, LLC, successor
to Ocwen Federal Bank
VS. : NO. 06-6596 CIVIL
HELEN J. MYERS AND
The United States of America
c/o The U.S. Attorney's Office
CERTIFICATE OF SERVICE
I, RICHARD F. STERN, attorney for the within Plaintiff, hereby certify that
notice of the Sheriff's Sale was mailed to the Defendants by certified mail, return
receipt requested on April 8, 2008.
I further certify that notice of the Sheriff's Sale was mailed to each lienholder
by regular, first-class, postage prepaid mail on April 8, 2008 as evidenced by copy
of certificates of mailing attached.
STERN AND EISENBERG LLP
BY: '??
RICHARD F. STERN
Attorney for Plaintiff
4/9/08
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL ACTION-LAW
RICHARD F. STERN, ESQUIRE
STERN AND EISENBERG LLP
The Pavilion
261 Old York Road, Suite 410
Jenkintown, PA 19046
(215) 572-8111
I . D. #03315
U.S. BANK, N.A.,
as Trustee, by its attorney in fact,
Ocwen Loan Servicing, LLC, successor
to Ocwen Federal Bank
VS. : NO. 06-6596 CIVIL
HELEN J. MYERS AND
The United States of America
c/o The U.S. Attorney's Office
CERTIFICATE OF SERVICE
I, RICHARD F. STERN, attorney for the within Plaintiff, hereby certify that
notice of the Sheriffs Sale was mailed to the Defendants by certified mail, return
receipt requested on April 8, 2008 and received by the Defendant, Helen J. Myers
on April 23, 2008 as evidenced by a copy of certified mail receipts and signed
green card attached.
STERN AND EISENBERG LLP
BY:
RICHARD F. STERN'
Attorney for Plaintiff
4/28/08
to
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item 4 if Restricted Delivery is desired.
¦ Print your name and address on the reverse
so that we can return the card to you.
¦ Attach this card to the back of the mailpiece,
or on'the front if space permits.
1. Article Addressed to:
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U.S. Bank N.A. as Trustee for Morgan Stanley In the Court of Common Pleas of
Dean Witter Capital 1 Inc. Trust 2001-NC4 Cumberland County, Pennsylvania
By its attorney in fact, Ocwen Loan Servicing, Writ No. 2006-6596 Civil Term
Successor to Ocwen Federal Bank
VS
Helen J. Myers and The United States of America
c/o The U.S. Attorney's Office
Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on
April 28, 2008 at 1638 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: Helen J. Myers
by making known unto Helen Myers personally, at 2300 Market St., Camp Hill, Cumberland
County, Pennsylvania its contents and at the same time handing to her personally the said true and
correct copy of the same.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a
diligent search and inquiry for the within named defendant, to wit: The United States of America,
but was unable to locate them in his bailiwick. He therefore deputized the Sheriff of Lackawanna
County, Pennsylvania to serve the within Real Estate Writ, Notice of Sale and Description
according to law.
Lackawanna County Return: And now, the 27th day of March 2008 at 0920 hours served
the within Real Estate Writ, Notice of Sale and Description upon The United States of America c/o
The U.S. Attorney's Office by making known unto Mary Beth Mikolayczak, secretary, at William
T. Nealon Building, 235 North Washington Ave., Scranton, PA 18501 its contents and at the same
time handing to her personally the said true and correct copy of the same.
Tim Black, Deputy Sheriff, who being duly sworn according to law, states that on April 02,
2008 at 1400 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 Helen J. Myers located at 2300
Market Street, Camp Hill, 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: Helen J. Myers
by regular mail to her last known address of 2300 Market Street, Camp Hill, PA 17011. This letter
was mailed under the date of April 29, 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 Richard Stern.
Sheriff s Costs:
Docketing 30.00
Poundage 2,060.00
Advertising 15.00
Posting Handbills 15.00
Prothonotary 2.00
Mileage 43.20
Levy 15.00
Surcharge 30.00
Out of County 9.00
Lackawanna County 32.40
Law Journal 355.00
Patriot News 317.56
Share of Bills 14.73
$ 2,938.89
7l.23l0js `.
ce 0l9iV
So Answers:
R. Thomas Kline, Sheriff
BY
Real Estate geant
-?t
RICHARD F. STERN, ESQLmE
STEVEN K. EISEN&'ERG, ESQUIRE
BRADLEY D. SISLEY, EsQumE
STERN AND EISENBERG LLP
THE PAW ION
261 OLD YORK ROAD, SUrrE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215),572-8111
FACs%mE: (215) 572-5025
(COUNSEL FOR PLAJNTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
U.S. Bank, N.A., as Trustee for Morgan Stanley
Dean Witter Capital I Inc. Trust 2001-NC4, by its
attorney in fact, Ocwen Loan Servicing, LLC,
successor to Ocwen Federal Bank
Civil Action Number: 06-6596 Civil
Term
V.
Helen J. Myers and
The United States of America c/o The U.S.
MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO RULE 3129.1
I, the undersigned attorney for Plaintiff in the above caption, sets forth as of the date the Praecipe
for the Writ of Execution was filed, the following information concerning the real property
located at 2300 Market Street, Camp Hill, PA.
1. Name and address of Owner(s) or Reputed Owner(s):
Helen J. Myers
2300 Market Street
Camp Hill, PA 17011
2. Name and address of Defendant(s) in the judgment:
Helen J. Myers
2300 Market Street
Camp Hill, PA 17011
3. Name and last known address of every judgment creditor whose judgment is a record lien on
the real property to be sold:
Internal Revenue Service
Federated' Investors Tower
Thirteenth Floor, Suite 1300
1001 Liberty Avenue
Pittsburgh, PA 15222
4. Name and address of the last recorded holder of every mortgage of record:
J:\SUPRIYA\SALES\CUM13ERLAND\OCWEN.MYERS.RELIST.12.07.DOC
I
N/A
5. Name and address of every other person who has any record lien on the property:
N/A
6. Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
N/A
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:
Domestic Relations Tax Claim Bureau
Cumberland County Cumberland County Courthouse
13 North Hanover Street One Courthouse Street
Carlisle, PA 17013 Carlisle, PA 17013
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.
BY:
Attorney for
Date: December 21, 2007
STERN AND EISENBERG LLP
D.
J:\SUPRIYA\SALES\CUMBERLAND\OCWEN.MYERS.RELIST.12.07.DOC
RICHARD F. STERN, ESQUIRE
STEVEN K. EISENBERG, ESQUIRE
BRADLEY D. SISLEY, ESQUIRE
STERN AND EISENBERG LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSDAILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
U.S. Bank, N.A., as Trustee for Morgan Stanley
Dean Witter Capital I Inc. Trust 2001-NC4, by its
attorney in fact, Ocwen Loan Servicing, LLC,
successor to Ocwen Federal Bank
V.
Helen J. Myers and
The United States of America c/o The U.S.
Attornev's Office
Civil Action Number: 06-6596 Civil
Term
MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Helen J. Myers The United States of America
2300 Market Street William T. Nealon Building
Camp Hill, PA 17011 235 North Washington Avenue
Scranton, PA 18501
Your real estate at 2300 Market Street, Camp Hill, PA is scheduled to be sold at Sheriffs Sale
on Wednesday, JUNE11, 2008 at 10:00 A.M., at Sheriff's Office, Cumberland County
Courthouse, Carlisle, PA 17013 (location of sale) to enforce the court judgment of $100,777.74
obtained by U.S. Bank, N.A., as Trustee, by its attorney in fact, Ocwen Loan Servicing, LLC,
successor to Ocwen Federal Bank against you.
NOTICE OF OWNER'S RIGHTS
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be canceled if you pay to Stern and Eisenberg, LLP the back payments, late
charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may
call Stern and Eisenberg LLP, telephone (215) 572-8111.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to postpone the
sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILT, BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
J:\SUPRIYA\SALES\CUMBERLAND\OCWEN.MYERS.RELIST.12.07.DOC
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may
find out the price bid by calling Stern and Eisenberg LLP, telephone (215) 572-8111.
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 Stern and Eisenberg LLP, telephone (215) 572-8111.
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 fight 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 on a date specified by
the Sheriff no later than 30 days after the sale date. 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 date of filing of said schedule. You should check with the Sheriffs Office by
calling (717) 240-6390 to determine the actual date of filing of said schedule.
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.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
800-990-9108
717-249-3166
J:\SUPRIYA\SALES\CUMBERLAND\OC WEN.MYERS.RELIST.12.07.DOC
RICHARD F. STERN, ESQUIRE
STEVEN K. EISENBERG, ESQUIRE
BRADLEY D. SISLEY, ESQUIRE
STERN AND EISENBERG LLP
TEE PAVILION
261 OLD YORK ROAD, SUNS 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMH.E: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
U.S. Bank, N.A., as Trustee for Morgan Stanley
Dean Witter Capital I Inc. Trust 2001-NC4, by its
attorney in fact, Ocwen Loan Servicing, LLC,
successor to Ocwen Federal Bank
V.
Helen J. Myers and
The United States of America c/o The U.S.
Office
Civil Action Number: 06-6596 Civil
Term
MORTGAGE FORECLOSURE
RE: PREMISES; 2300 Market Street, Camp Hill. PA
Dear Sir or Madam:
Please be advised that I represent the above creditor that has a judgment against the above
Defendant. As aresult of a default, the above referenced premises, also described on the
attached sheet, will be sold by the Sheriff of Cumberland County on Wednesday, June 13, 2007
at 10:00 A.M. at sheriffs Office, Cumberland County Courthouse, Carlisle, PA 17013 (subject
to change without further notice).
The sale is being conducted pursuant to the judgment in the amount of $100,777.74 together with
interest, costs (arid such other allowed amounts) thereon entered in the above matter in favor of
Plaintiff against the above-named Defendant(s) who is/are also the real owner of said premises. I
have discovered that you may have a lien and/or interest in the premises to be sold. This notice
is given so that you can protect your interest, if any, in the lien you have on the premises. If you
have any questions regarding the type of lien or the effect of the Sheriff s Sale upon your lien, we
urge you to CONTACT YOUR ATTORNEY, as we are not permitted to give you legal advice.
A Schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later
than 30 days after the sale date and the distribution will be made in accordance with the schedule
unless exceptions; are filed thereto within ten (10) days thereafter.
December 21, 2007
STERN
BY:
BRADLEY D.
Attorney for PI
LLP
J:\SUPRIYA\SALES\CUMBERLAND\OCWEN.MYERS.RELIST.12.07.DOC
r... •... r. ...v ..YL v..Y.n..S. w... rl • ..•?..•..s n .IVY ...w..... .1 • ... • .., ....r. •.: r.rYS- __
;1? Dear-r'igtiaa
AM 4-bat . -ax-tain trae' t or gisos of ltad pttuats iz the eotcsah of Cmv xuL, acwty of
C=bwlaad and Stare of Besfsx1vaai4, more p=rticnlarly bmoded sad described as
golf, to slit 2 ,
MMMM at tb a na do"t cam= of M miltoe s=aet, MW .wenty-third 6treet, sad
Nat)P-t sttreet; thes=e is s uorrtbrxly diseotiaa, Ll mg them rent sida of X"iIt=
rtxest, ww Thy-Utird Street. txo hutted five (205) fett to a pal=; tke=r
wsrtwur4r, QjMV lands of D. "d Dean, ame h nulzed forty-four (144) fact, mare or
lest, to s paiat; rhetrca eoutbW=ay 4=9 lot of Adw a agolt, rye bt mtmd viactV71Z
and five. Data-budredtba 1196.0b) 'feet to a euxb liva ca matimt utz*etr tbcaca !!
eastwaxdly, miang the cyrh It" of time aexth aide Of MatIftt ets+eet, tae hu' sd
fatty-foot' 0.") fact, more ov lane, to the place Of mu wm'
BZM iWovad by a: two atA *=-Wf story brick dwelling and racacsasy outbmUd3.Wp
ka= as " =mberred 23to Market mvveet, Camp gill, Pa.
G
444M i
4
RICHARD F. STERN, ESQUIRE
STEVEN K. EISENBERG, ESQUIRE
BRADLEY D. SISLEY, ESQUIRE
STERN AND EIsENBERG LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINToWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACsnAiLE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
U.S. Bank, N.A., as Trustee for Morgan Stanley
Dean Witter Capital I Inc. Trust 2001-NC4, by its
attorney in fact, Ocwen Loan Servicing, LLC,
successor to Ocwen Federal Bank
V.
Helen J. Myers and
The United States of America c/o The U.S.
Attorney's Office
Civil Action Number: 06-6596 Civil
Term
MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Helen J. Myers The United States of America
2300 Market Street William T. Nealon Building
Camp Hill, PA 17011 235 North Washington Avenue
Scranton, PA 18501
Your real estate at 2300 Market Street, Camp Hill, PA is scheduled to be sold at Sheriffs Sale
on Wednesday, JUNE11, 2008 at 10:00 A.M., at Sheriffs Office, Cumberland County
Courthouse, Carlisle, PA 17013 (location of sale) to enforce the court judgment of $100,777.74
obtained by U.& Bank, N.A., as Trustee, by its attorney in fact, Ocwen Loan Servicing, LLC,
successor to Ocwen Federal Bank against you.
NOTICE OF OWNER'S RIGHTS
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be canceled if you pay to Stem and Eisenberg, LLP the back payments, late
charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may
call Stern and Eisenberg LLP, telephone (215) 572-8111.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to postpone the
sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an, attorney to assert your rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILE, BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
J:\SUPRIYA\SALES\CUMBERLAND\OCWEN.MYERS.RELIST.12.07.DOC
,
l
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may
find out the price bid by calling Stem and Eisenberg LLP, telephone (215) 572-8111.
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 Stem and Eisenberg LLP, telephone (215) 572-8111.
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 on a date specified by
the Sheriff no later than 30 days after the sale date. 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 date of filing of said schedule. You should check with the Sheriffs Office by
calling (717) 240-6390 to determine the actual date of filing of said schedule.
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.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
800-990-9108
717-249-3166
J:\SUPRIYA\SALES\CUMBERLAND\OCWEN.MYERS.RELIST.12.07.DOC
aegal Daacrigt:ioa
AM *Lbat narta n tract or piaoe of land #itua.te in the eo=muh of C=q Bfll, {,b=ry of I
C=ber]and and stays of pm=sylvaaia, more particularly bound d sad daoorihed as
gollcn?, to Kits
en=ac at the sa t cater of Hamilton stscet, a0M :'eeaT-thud Straat, and ?
Mrket BErcet; the=* iU s uextberly direction, k1mv rho vast aide Of Xmiltom
strimt, moor 1rauty-third 9txaet, two hi=dred five (2051 fact to a poUP-1 th*=r-
vaotluatx 4y, &Iong lands of F. 8ded Deaii, ome btmUmd fomy-fay (3.4411 feet, mole or
less, to a pc"t; the a caoutavamdly along lot of fd o moolf, me htumdred pinery-six
and flve =- -bod'•efth¦ t196.05) foet to a Caleb 1104 oa MarlDft Street; thence
esstrardly, wavaq the cyrb lies of the uerth aide of MWmt Surest, =a bundvA
forty-four ().KJ feet, vor.* or Ieee, to the plum of 88%3 ,
i
B&M iWavead by E two a a4 sae-Ulf story brick dwelling and aamcsary orutbaildivp,
kamm ai and m mbe-red 2346 Xmieet 6treet, Camp Hill, Pa.
'qm .
•
3
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-6596 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due U.S. BANK, N.A., as Trustee for MORGAN STANLEY
DEAN WITTER CAPITAL 1 INC. TRUST 2001-NC4, by its attorney in fact, OCWEN LOAN
SERVICING, LLC, successor to OCWEN FEDERAL BANK, Plaintiff (s)
From HELEN J. MYERS and THE UNITED STATES OF AMERICA c/o THE U.S.
ATTORNEY'S OFFICE
(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 $100,777.74
L.L.
Interest from 1%23/07 at the per diem rate of $27.19 until judgment is paid in full
Atty's Comm %
Due Prothy $2.00
Atty Paid $1,113.57 Other Costs
Plaintiff Paid
Date: 1/02/08
Proth notary
(Seal) By:
Deputy
REQUESTING PARTY:
Name BRADLEY D. SISLEY, ESQUIRE
Address: STERN AND EISENBERG
261 OLD YORK ROAD, SUITE 410
JENIGNTOWN, PA 19046
Attorney for: PLAINTIFF
Telephone: 215-572-8111 `
Supreme Court ID No. 200040
Real Estate Sale # 51
On March 5, 2008 the Sheriff levied upon the
defendant's interest in the real property situated in
the Borough of Camp Hill, Cumberland County, PA
Known and numbered as 2300 Market Street, Camp Hill,
more fully described on Exhibit "A"
filed with this writ and by this reference
incorporated herein.
Date: March 5, 2008 By
Real Estat Sergeant
b d E - NIA' i
Gfit`"tl
(.
bd '.111 WO aNv id38Wt13
AWNS 3W1 A 3313: 0
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the,publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
M, ay 2, May 9, and May 16, 2008
Affiant futther 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.
944--a =
Marie Coyne,
SWORN TO AND SUBSCRIBED before me this
16 day of May. 2008
Z I Jz) /'/. -C?
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BORO, CUMBERLAND COUNTY
My Commission Expires Apr 28, 2010
gas Noft" am W. 51
Writ No. 2006-6596 Civil
U.S. Bank, N.A., as Trustee for
Morgan Stanley Dean Witter
Capital 1 Inc. Trust 2001-NC4, by
its attorney in fact, Ocwen Loan
Servicing, LLC, successor to
Ocwen Federal Bank
VS.
Helen J. Myers and The United
States of America c/o The U.S.
Attorney's Office
Atty.: Bradley Sisley
LEGAL DESCRIPTION
ALL that certain tract or piece of
land situate in the Borough of Camp
Hill, County of Cumberland and State
of Pennsylvania, more particularly
bounded as described as follows,
to wit:
BEGINNING at the northwest
corner of Hamilton Street, now
Twenty-third Street, and Ma set
Street; thence in a nortimly w rec-
ti on, along the wat aide at Rea ton
Street, now Twenty-third Stremt, two
hundred five (205) feet to a point;
thence westwardly, along lands of D.
Edwin Dean, one hundred forty-four
(144) feet, more or less, to a point;
thence southwardly along lot of Adam
Egolf, one hundred ninety-six and
five one-hundredths (196.05) feet to
a curb line on Market Street; thence
eastwardly, along the curb line of
the north side of Market Street, one
hundred forty-four (144) feet, more or
less, to the place of BEGINNING.
BEING improved by a two and
one-half story brick dwelling and
necessary outbuildings, known as
and numbered 2300 Market Street,
Camp Hill, PA.
"rbe Patriot-News Co.
812 Market St.
Harrisburg, PA 17101
Inquiries - 717-255-8292
CUMBERLAND COUNTY SHERIFFS OF
CUMBERLAND COUNTY COURT HOUSE
the Patriot-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, baing 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 lor 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:
04/23/08
04/30/08
05/07/08
Sworn to an?ubribed f ore me this 27 day of May, 2008 A.D.
CIO
Notary Pub c
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Chyde L. Sheppard, Notary Public
City Of Harrisburg, Dauphin County
W Commission Expires May 29, 2010
Member, Pennsylvania Association of Notaries
Real Estate Sale #51
Writ No. 2006-6596 Civil Term
U S. Ba,ik, N.A., as Trustee for
Morgan Stanley Dean Witter
?apital 1 Inc. Trust 2001-NC4, by
its attorney in fact, Ocwen Loan
Servicing, LLC, successor to
Ocwen Federal Bank
VS
Helen J. Myers and The United
States of America c/o The U.S.
Attorney's Office
Attorney: Bradley Sisley
DESCRIPTION
ALL that certain tract or piece of land situate in
the borough of Camp Hill. County of
Cumberland and State of Pennsylvania, more
particularly bounded as described as follows, to
wit:
BEGINNING at the northwest comer of
Hamilton Street. now Twenty-third Street, and
Market Street; thence in a northerly direction.
along the west side of Hamilton Street, now
Twenty-third Street, two hundred five (205) feet
to a point; thence westwardly, along lands of D.
Edwin Dean. one hundred forty-four (141) feet.
more or less, to a point; thence southwardly
alone lot of Adam Egotf. one hundred ninety-six
and five one-hundredths (196.05) feet to a curb
line on Market Street; thence eastwardly, along
the curb line of the north side of Market Street,
one hundred forty-four (141) feet, more or less.
to the place of BEGINNING.
BEING improved by a two and one-half story
hrick dwelling and necessary outbuildings,
known and numbered as 23M Market Street.
Camp Hill. Pay.
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL ACTION-LAW
STEVEN K. EISENBERG, ESQUIRE
STERN AND EISENBERG LLP
The Pavilion
261 Old York Road, Suite 410
Jenkintown, PA 19046
(215) 572-8111
I.D. #75736
U.S. Bank, N.A., as Trustee for Morgan Stanley
Dean Witter Capital I Inc. Trust 2001-NC4, by its
attorney in fact, Ocwen Loan Servicing, LLC,
successor to Ocwen Federal Bank
Civil Action Number: 06-6596 Civil
Term
V.
Helen J. Myers and
The United States of America c/o The U.S.
MORTGAGE FORECLOSURE
Office
ORDER TO SATISFY JUDGMENT
Please satisfy the judgment in the above captioned matter upon payment of your costs only.
STERN AND El NBERG
B
STEVEN K. EISE BERG
Attorney for Plaintiff
6/6/08
`rt
rW ?