HomeMy WebLinkAbout06-6670GOLDBECK McCAFFERTY & McKEEVER
By: JOSEPH A. GOLDBECK, JR.
ATTORNEY I.D. #16132
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
(215) 825-6318
WWW.GOLDBECKLAW.COM
ATTORNEY FOR PLAINTIFF
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE ON BEHALF OF THE CERTIFICATE
HOLDERS OF MORGAN STANLEY ABS CAPITAL I
INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
VS.
TERESA TROUT
BART A. TROUT
Mortgagors and Real Owners
508 Herman Avenue
Lemoyne, PA 17043
Defendants
Term
No. , -&6-)0
CIVIL ACTION: MOR3`r.H:
"MI-Q8URF
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages,
you must take action within twenty (20) days after the Complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further notice for any money claim in the Complaint
of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
AVISO
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS
QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO
DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL
PT,JNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA
DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL
PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A
FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES
DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER
DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES.
USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN
ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA
PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO.
SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE
INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS
ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT
A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you
still may be able to SAVE YOUR HOME FROM FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-
9400 or.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes.
4). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home
Retention options.
5). Call or contact our office to request the amount to bring the account current, or payoff the mortgage
or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email
at homeretentionagoldbecklaw.com. Call Judy at 215-825-6329 or fax 215-825-6429. The figure and/or
package you requested will be mailed to the address that you request or faxed if you leave a message with that
information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be
reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of CWD-6627.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
This Action of Mortgage Foreclosure will continue unless you take action to stop it.
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE ON BEHALF OF
THE CERTIFICATE HOLDERS OF MORGAN STANLEY ABS CAPITAL I INC. TRUST 2004-
HE9, MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2004 HE9, 7105 Corporate Drive,
PTX C-35 Plano, TX 75024.
2. The names and addresses of the Defendants are TERESA TROUT, 508 Herman Avenue, Lemoyne, PA
17043-1822 and BART A. TROUT, 508 Herman Avenue, Lemoyne, PA 17043-1822, who are the
mortgagors and real owners of the mortgaged premises hereinafter described.
3. On July 21, 2004 mortgagors made, executed and delivered a mortgage upon the Property hereinafter
described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. AS NOMINEE FOR
ACCREDITED HOME LENDERS INC., which mortgage is recorded in the Office of the Recorder of
Deeds of Cumberland County as Book 1874, Page 4713. The mortgage has been assigned to:
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE ON BEHALF OF THE
CERTIFICATE HOLDERS OF MORGAN STANLEY ABS CAPITAL I INC. TRUST 2004-HE9,
MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2004 HE9 by assignment of Mortgage,
which has been lodged for recording. The Mortgage and assignment(s) are matters of public record and
are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g);
which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents
are matters of public record.
4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit
"A" ("Property").
5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid
for June 01, 2006 and each month thereafter and by the terms the Mortgage, upon default in such
payments for a period of one month or more, the entire principal balance and all interest due and other
charges are due and collectible.
6. The following amounts are due to Plaintiff on the Mortgage:
Principal Balance ....................................................................................$95,535.17
Interest from 05/01/2006 through 11/30/2006 at 7.9900% .......................$4,474.74
Per Diem interest rate at $20.91
Reasonable Attorney's Fee at 5% of Principal Balance
as more fully explained in the next numbered paragraph ...................$4,776.76
Late Charges from 06/01/2006 to 11/30/2006 .............................................$255.95
Monthly late charge amount at $42.66
Costs of suit and Title Search ......................................................................$900.00
Monthly Escrow amount $257.10
$105,942.62
7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less
than the amount demanded based on work actually performed. The Attorney's Fees requested are in
conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up
to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at
Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount
demanded in the Action.
8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the
Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such
right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy
proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal
liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property
pursuant to Pennsylvania law.
9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has
been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the
Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s)
attached hereto as Exhibit "B". The Defendants have not had the required face-to-face meeting within
the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants
through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit
Counseling Agency.
WHEREFORE, Plaintiff demands a de terns judgment in mortgage foreclosure in the sum of $105,942.62,
together with interest at the rate of $20.91, per day and other expenses, costs and charges incurred by the
Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law
until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property.
GO ECI?McCAFFERTY & McKEEVER
BY: IT O I
EPH A. GOLDBECK, 7R., ESQUIRE
ATTO Y FOR PLAINTIFF
J
VERIFICATION
I, JILLEALENTINE, as the representative of
the Plaintiff corporation within named do hereby verify that I am
authorized to and do make this verification on behalf of the
Plaintiff corporation and the facts set forth in the foregoing
Complaint are true and correct to the best of my knowledge,
information and belief. I understand that false statements therein
are made subject to the penalties of 18 Pa. C.S. 4904 relating to
unsworn falsification to authorities.
Date II .)I '??
rjy8et__-.
JILL ttt?, SR. VICE PRESIDENT
#36130635 - BART TROUT
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Eyhibit (B
ACT 91 NOTICE
DATE OF NOTICE: October 13, 2006
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THE PURPOSE OF COLLECTING THE DEBT.
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 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) 780-1869.1
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 any attorney in your area. The local bar association may be able
to help 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 notification obtenga una traduccion
immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al
numero mencionada arriba. Puedes 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 redimir su hipoteca.
Prepared by: GOLDBECK McCAFFERTY & McKEEVER
Suite 5000 - Mellon Independence Center.
701 Market Street
Philadelphia, PA 19106
Fax (215) 627-7734
Date: October 13, 2006
TO: TERESA TROUT
Homeowners Name: TERESA TROUT and BART A. TROUT
Property Address: 508 Herman Avenue, Lemoyne, PA 17043
Loan Account No.: 36130635
Original Lender: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. AS
NOMINEE FOR ACCREDITED HOME LENDERS INC.
Current Lender/Servicer: COUNTRYWIDE HOME LOANS INC.
HOMEOWNERS'
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 designated 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 agencies listed at the end of this notice, the lender may NOT take action against you
for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of
designated consumer credit counseling agencies for the county in which the property is located are set
forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your
lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the
reasons set forth later in this Notice (see following pages for specific information about the nature of
your default.) 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 filed or postmarked within thirty (30) days of your fact-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.)
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: 508 Herman Avenue, Lemoyne, PA 17043 IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months
and the following amounts are now past due:
(a) Monthly payment from 06/01/2006 thru 10/13/2006
(5 mos. at $968.18/month) $4,840.90
(b) Late charges from 06/01/2006 thru 10/13/2006
(5 mos. at $42.66/month) $213.29
(c) Other charges; Escrow, Inspec., NSF Checks
(d) Other provisions of the mortgage obligation, if any
(e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $5,054.19
HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the
date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH
IS 5 0$ . 54.19, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME
DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check,
certified check or money order made payable and sent to:
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX C-35
Plano, TX 75024
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 brings legal proceedings against you, you will still be required to pay the
reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are
started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender
even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which
may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY
period. you will not be required to pay attorney's fees.
OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the
default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have
the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale.
You may do so by paying the total amount then past due, plus any late or other charges then due,
reasonable attorney's fees and costs connected with the foreclosure sale and my other costs connected
with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements
under the mortcaae. Curing your default in the manner set forth in this notice will restore your
mortgage to the same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a
Sheriffs Sale of the mortgaged property could be held would be approximately four 4) to 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 by contacting the
lender.
HOW TO CONTACT THE LENDER:
Name of Lender: COUNTRYWIDE HOME LOANS INC.
Address: 7105 Corporate Drive
PTX C-35
Plano, TX 75024
Phone Number: 972-526-6000
Contact Person: Michelle Cooper
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 sell or transfer your home to a buyer or transferee who
will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees
and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
* TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE
DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF
THIS DEBT.
* TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
* TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO
DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT
HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY
CALENDAR YEAR.)
* TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
* TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH
ACTION BY THE LENDER.
* TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
Contact Person: Michelle Cooper
Phone Number: 972-526-6000
PENNSYLVANIA HOUSING FINANCE AGENCY
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
CONSUMER CREDIT COUNSELING AGENCIES
CUMBERLAND COUNTY
CCCS OF WESTERN PENNSYLVANIA INC.
2000 Linglestown Road
Harrisburg, PA 17102
(717)541-1757
URBAN LEAGUE OF METROPOLITAN HARRISBURG
2107 N. 6th Street
Harrisburg, PA 17101
(717) 234-5925
FAX (717) 234-9459
COMMUNITY ACTION COMM OF THE CAPITAL REGION
1514 Derry Street
Harrisburg, PA 17104
(717) 232-9757
FAX 234-2227
FINANCIAL COUNSELING SERVICES OF FRANKLIN
31 West 3rd Street
Waynesboro, PA 17268
(717) 762-3285
YWCA OF CARLISLE
301 G Street
Carlisle, PA 17013
(717)243-3818
FAX (717) 731-9589
ADAMS COUNTY HOUSING AUTHORITY
139-143 Carlisle Street
Gettysburg, PA 17325
(717)334-1518
FAX (717) 334-8326
Counhywi&.
"ONE LOANS
PO Pua: 9048
`".1-ula, CA 92589-9048
Send Payments To:
PO BOX 660694
Dallas, TX 752 6 6-0 6 94
Send Correspondence to:
PO Box 5170, MS 51/3146
Simi Valley, CA 93065
VBI I??iIIYI? l?llllllllllllll?llll
7113 8257 1470 7503 6634
Bart Trout
568 HERMAN AVE
LEMOYNE, PA 1 704 3-1 8 22
06060-OLQPAl
PRESORTED
First-Class Mail
U.S. Postage
and Fees Paid
WSO
1 CounhyWde•
HOME LOANS
P.O. Box 660694
Dallas, TX 75266-0694
Send Payments to:
PO Box 660694
Dalfas, TX 75266-0694
August 1, 2006
Certified Mail:
7113 8257 1470 7503 6634
Return Reciept Requested
Regular Mail
Bart Trout
508 HERMAN AVE
LEMOYNE, PA 17043-1822
Account No.: 36130635
Property Address:
508 Herman Avenue
Lemoyne, PA
Current Servicer:
Countrywide Home Loans, Inc.
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific
information about the nature of the default is provided in the attached pages.
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (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 30 DAYS OF
THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency.
The names, addresses and phone numbers of Consumer Credit Counseling Agencies servinq your County are listed at
the and of this Notice. if you have any guestions, you may call the Pennsylvania Housing Finance Agency toll free at
1-800-342-2397. (Persons with impaired hearing can call 1-717-780-1869).
This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit
Counseling Agency may be able to help answer them. You may also want to contact an attorney in your area. The
local bar association may be able to help you find a lawyer.
LA NOTIFICA06N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECi,HO A CONTINUAR
VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIVN OBTENGA UNA
TRADUCCI6N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN
CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU
CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
HOMEOWNER'S NAMEi Bart Trout
PROPERTY ADDRESS: 508 Herman Avenue
Lemoyne, PA
LOAN ACCT. NO.. 36130635
ORIGINAL LENDER:
CURRENT LENDERISERVICER
Countrywide Home Loans. Inc.
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
Please write your acootnt number on all checks and correspondence.
'Ne may Gmrge you a fee for airy payment returned or rejected by ?gour financel instituInn, subject to appM.able haw.
• Make your check payable to Account Number: 36130635-0 Balance Due for charges listed above: $2,640.61 as of 91112000.
Countrywide Hare Loafs Bad Trout
•
your accountnumberon
yoour check or money order
your
506 Herman Avenue Pease updat-il inkxmati- therever?s4de .phis muffin
• Write in any additional amounts
you are including (M total is addytkmal
more than $5000, please send e" gal
certified dlecki BLQW
• Dont attach your check tothe Fjdnti,nal
payment coupon
Es,.ra
D:
. .ntnc'itdocorrespondence Countrywide
. nt sold wash PO BOX 660694
Oho
Dallas. TX 75266-06£1
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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 THIRTY (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 agencies listed at
the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The
names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the
property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your
lender immediately of Your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see
following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this
problem with the lender, you have the right to apply for financial assistance from the Homeowners Emergency Mortgage
Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program
Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer
credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the
Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your
face-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER
TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY
AND 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
ATTEMPTTO COLLECTTHE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at:
508 Herman Avenue Lemoyne, PA
IS SERIOUSLY IN DEFAULT because
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now
past due
Monthly Payments: June, 2006 August, 2006 (3 mos. @ $837.61 /month) $2,512.83
Late Charges: June, 2006 July, 2006 (2 mos. @ $42.66/month) $85.32
Other Late Charges: Total Late Charges: $42.66
Uncollected Costs: $0.00
Partial Payment Balance: ($0.00)
TOTAL DUE: $2,640.81
YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable)
HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING
THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,640.81, PLUS ANY MORTGAGE PAYMENTS AND
LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD.
Payments must be made either by cashier's check, certified check or money order made payable and sent to:
E-mail use: Providing your e-mail address below will allow us to send you information on your account
Account Number: 36130635
Bart Trout E-mail address
How we post your payments: All accepted
payments of principal and interest will be applied fi
the longest outstanding installment due, unless
otherwise expressly prohibited or limited by law. If
you submit an amount in addition to your scheduled
monthly amount, we will apply your payments as
follows: (I) to a[standing monthly payments of
principal and interest, (0 escrow deficiencies, (iii) late
charges and other amounts you ewe in connection
with you loan and livl to reduce the outstanding
principal balance of ycu lean. Please specifS? if you
?aant an additional amount applied to future
payments, rather than principal reduction.
Postdated checks: Countrywide's policy is to not
accept postdated checks, unless specifically agreed
to by a loan counselor or technician.
Countrywide at P.O. Box 660694, Dallas, TX 75266-0694
You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter. (Do not use if
not applicable)
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the
lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of
this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full
payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to
start legal action to foreclose upon your mortgaged property
IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage
debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings
against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if
legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even
if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other
reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's
fees.
OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due
under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30)
DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time
up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other
charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with
the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing
your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never
defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the
mortgage property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual
dateof the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the
longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: Countrywide Home Loans, Inc.
Address; P. O. Sox 660694 Dallas, TX 75266-0694
Phone Number: 1-800-669-0102
Fax Number: 1-805-577-3432
Contact Person: MS PTX-36
Attention; Loan Counselor
EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and
your right to occupy it. If you continue to live in the property after the Sheriffs sale, a lawsuit to remove you and your furnishings
and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage
debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that
the other requirements of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM
ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE
THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES
IN ANY CALENDAR YEAR.)
TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT
INSTITUTED 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.
Your ban is in default. Pursuant to your loan documents, Countrywide may, enter upon and conduct an inspection of your
7113 8257 1470 7503 6634
property. The purposes of such an inspection are to (i) observe the physical condition of your property, (ii) verify that the
propery is occupied andior (iii) determine the identity of the occupant. If you do not cure the default prior to the inspection, other
actions to protect the mortgagee's interest in the property (including, but not limited to, winterization, securing the property, and
valuation services) may be taken. The costs of the above-described inspections and property preservation efforts will be
charged to your account as provided in your security instrument.
If you are unable to cure the default on or before August 31 , 2006, Countrywide wants you to be aware of various options that
may be available to you through Countrywide to prevent a foreclosure sale of your property. For example:
• Repayment Plan: It is possible that you may be eligible for some form of payment assistance through Countrywide.
Our basic plan requires that Countrywide receive, up front, at least M. of the amount necessary to bring the account
current, and that the balance of the overdue amount be paid, along with the regular monthly payment, over a
defined period of time. Other repayment plans also are available.
r Loan Modification: Or,-it is possible that the regular monthly payments can be lowered through a modification of the
loan by reducing the interest rate and then adding the delinquent payments to the current loan balance. This
foreclosure alternative, however, is limited to certain loan types.
• Sale of Your Property: Or, if you are willing to sell your home in order to avoid foreclosure, it is possible that the sale
of your home can be approved through Countrywide even if your home is worth less than what is owed on it.
• Deed-in-Lieu: Or. if your property is free from other liens or encumbrances, and if the default is due to a serious
financial hardship which is beyond your control, you may be eligible to deed your property directly to the Noteholder
and avoid the foreclosure sale.
If you are interested in discussing anyaf-these foreclosure alternatives with Countrywide, you must contact us immediately. If
you request assistance, Countrywide will need to evaluate whether that assistance will be extended to you. In the meantime,
Countrywide will pursue all of its rights and remedies under the loan documents and as permitted by law, unless it agrees
otherwise in writing. Failure to bring your loan current or to enter into a written agreement by August 31, 2006 as outlined above
will result in the acceleration of your debt.
Time is of the essence. If you have any questions c_on_ceming this notice, please contact Loan Counseling Center immediately at
1-800-669-0102.
r
APPENDIX C
PENNSYLVANIA HOUSING FINANCE AGENCY
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
CONSUMER CREDIT COUNSELING AGENCIES
ADMO COUNTY
American Red Cross - Hanover Chapter ARMSTRONG COUNTY CCCS of Western Pennyslvania, Inc.
529 Carlisle Street CCCS of Western Pennyslvania Inc. 217 E. Plank Road
Hanover PA 17331 217 E. Plank Road Altoona, PA 16602
Ph: 717-637-3768 Aifoona, PA 16502 Ph. 814-944-8100
Fax 717.637-3294 Ph: 814444-8100 Fax 814-944-5747
Ph: 814.944-5747
Fltartclal COU CouinsNing Services of Franklin
Credit Counselors of PA Tableland Services, Inc.
535 East Main Street
3i West reet
Waynesboro
PA 17268 401 Wood Street Somerset, PA 15501
,
Ph: 717-762-a285 Suite 906
Pittsburgh, PA 15222 Ph: 814-445-9628
Ph: BW-452-0148
CCCS of Western PA Ph: 412-338-9954 Fax 814443-3690
2000 Li glestown Road Ph: 800-737.2933
Fax 412-338-9963
RRKS COUNTY
Harrisburg, PA 17102
Ph: 717-541-1757 Budget Counseling Center
Ph: 717-541-4670 Indiana Co. Community Action Program 247 North Fifth Street
827 Water Street Reading, PA 19601
Adams County Housing Authority Boot 187
Irxliana, PA 15701 Ph: 610.375.7866
Fax 610.375-7830
139-143 Carlisle St Par 724-465-2657
Gettysburg, PA 17325
Ph: 7173341518 Fax 724-465-5118 Economic Opportunity Cabinet of Schuylkill
Fax 717-334-8326 BEAVER COUNTY 22Cft*
5 N. Centre Street
ALLEGHENY COUNTY Action Housing, Inc.
425 a Avenue Potts%ft PA 17901
Ph: 717-622-1995
Pennsylvania Housing Finance Agency
(Maraca Hess) Suite 950 Fax: 717-622.0429
2275 Swallow Hill Road Pittsburgh, PA 15219
Ph: 412.391-1956
CCCS of Lehigh Valley
Building 200
Pittsburgh, PA 15220 Fax 41Z391A512 3871 Crescent Court East
Ph: 412-429-2842
Fac 412-429-2835
Housing Opportunities of Beaver Co., Inc. Whileha8, PA 18052
Ph: 61040-4011
650 Corporation Street Ph: WO-220-2733 (814 only)
Action Housing, Inc.
' Suite 207
Beaver
PA 15009 Fax 610821-8932
4256
Avenue
Suite 950 ,
Ph: 7247 28-75 1 1 Community Housing Counselor, Inc.
Pittsburgh, PA 15219
Ph: 412391-1956
Credit Counselors of PA Post Office Box 244
Kay" Square, PA 19348
Fir 412-281-2102 401 Wood Street Ph: 610444-3682
Ph: MD-792-2801 suits 906
Pittsburgh
PA 15222 Fax 610444-8243
Fax 412-391.4512 ,
Ph: 412-338.9954 BLAIR COUNTY
CC
CCCS of Western Pennsylvania Inc Par 800.737-2933
Fax 412-338-9963 Bedford-Futton Housing Services
R.D
1
Box 384
309 Smithfield Street
Pittsburgh
PA 15222 .
,
Everett
15537
,
Ptr b12-471-7584 Man-Valley
llneritPloyed Committee
120 E
0 A Ph:
: 814-623-9129
Urban League of Pittsburgh
BL&ft for Equal Opportunity .
venue
Homestead, PA 15120
Ph: 412.462-9962 Fax: 814-623-7187
CCCS of Western Pennsylvania, Inc.
One Smithfield Street Ph: 412-462-9964 217 E. Plank Road
PJbsbtagh, PA 15222-2222
Ph: 412-227-4802
Hou*v Opportunities Inc_ Altoona, PA 16602
Ph: 8149448100
Fac 412-2615207 133 Seventh Street
Post Office Box 9 Ph: 814-9445747
Mon-Valey Urlemployed Committee McKeesport, PA 15134 Keystone Economic Development Corp.
12D 9" Avenue
Av
enue Ph: 412-664-1906 1954 Mary Grace Lane
Homestead,
PA
15120 Fax: 412-664-0873 Johnstown, PA 15901
412462.9982
BED FORD COUNTY Ph:
814-535-6556
Fax: 814539-168
Fax 814-539-1688
88
Credd Cotnselors of PA Bedford-Fulton Housing Services
401 Wood Street 10241 Lincoln Highway Weathedzatlon Office
Suite Everett, PA 15537 917 M ifilin Street
Pittsburgh, PA 15222 Ph: 814.623-9129 Huntingdon, PA 16652
Ph, 412 338-9964 Fax 814-623-7187 Ph: 814-643-2343
Ph: 800.737-2933
Fax 412338-99W Keystone Economic Development BRADFORD COUNTY
Corporation ACS of Northeastern Pennsylvania
Community Acton Southwest 1954 Mary Grace Lane 1400 Abington Executive Park
22 West High Street
Street
Waynesburg
sburg A 16370 Johnstown, PA 15901
Ph: 814.535-6556 Suite 1
Clarks Summitt, PA 18411
,
Ph: 72 Fax 814539-1688 Pit 570-587-9i63
Ph: 800-822-9537
Housing
Opportunities
H
ou Weatheriz bon Office Fax 570.587-9134
133
Seventh Street 917 Mifflin Street Fax 570587.9135
Past Office Box 9 Huntingdon, PA 16652
McKeesport, PA 15132 Ph: 814643.2343 31 W. Market Street
Ph: 412-884-1908 Wilkes-Barre, PA 18702
Fax 412-884.0873 Ph: 570-821-0637
Ph: 800-MM-9537
Fax: 570821-1785
9 South 7 h Street CCCS of Delaware Valley CCCS of Western PA
Stroudsburg, PA 18360 Trevose Corporate Center 219-A College Park Plaza
ft 570-420.8980 4606 Street Road Johnstown, PA 15904
Ph: 800-922-9537 Trevose, PA 19047 Ph: 814-539-6335
Fax: 570-420-8981 Ph- 215-563-5665
CCCS of Western PA
1631 S. Atherton Street CCCS of Lehigh Valley 217 E. Plank Road
suite 100 3671 Crescent Court East Altoona, PA 16602
State College, PA 16801 Whitehall, PA 18052 Ph: 814.944$100
Ph: 814-238-3668 Ph: 610-821-4011 Fax: 814-944-5747
_ _Fax 814-238-3660 Ph: 800-220.2733
Fax: 610.821-8932 Keystone Econ Development Corp.
The Trehab Center of Northeastern PA 1954 Mary Grace Lane
10 Public Avenue American Crertit Counseling InstRute Johnstown, PA 15901
Monlross, PA 18801 845 Coates Street Ph: 814-535.6556
Pic 570.278-3338 Coatesville, PA 19320 Fax 814-539-1688
Ph: 800-982-4045 Ph: 886-212-0741
Fax 570.278-1889 Tableland Services, Inc.
144 E. Dekalb Pike 535 East Main Street
German Street KIM of Prussia, PA 19406 Somerset, PA 15501
Post Office Box 389 Ph: 610.971-2210 Ph: 814-445-9628
Dushwre, PA 18614 Fax: 610-265-4814 Ph: 800452-0148
Pit 570-928.9668 Fax: 814-443-3690
i Fax: 570-928-8144 755 York Road
Suite 103 CAMERON COUNTY
33 Walnut Street Warminster, PA 18974 Northern Tier Community Action Corp.
Wdsboro, PA 16901 Ph: 215.4449429 Post Office Box 389
Ph: 570-724-5252 Fax 215-956.8344 135 West 0 Street
Fax 570-724.5783 Emporium, PA 15834
BUTLER COUNTY Ph: 814466-1161
185 Elmira Street Action Housing, Inc. Fax 814486-0825
Post Oltice Box 218 425 a Avenue
Troy, PA 16947 Suite 950 CCCS of Northeastern PA
Ph: 570-297-2101 Pittsburgh, PA 15219 1631 S. Atherton Street
Ph: 412-391-1956 Suite 100
103 Warren Street Ph: 412-281-2102 State College, PA 16801
Past Office Box 709 Ph: 814-238-3688
TurtM a wmk, PA 18657 Housing Opportunities, Inc. Fax 814-238-3669
Ph: 570-836-6840 650 Corporate St.
F= 570'836-8332 Sulle207 CCCS of Western PA
McKeesport PA 15132 217 E. Plank Road
931 Main Street Ph: 412-6641590 Altoona, PA 16602
Honesdale, PA 18431 Fax: 412-664-W3 Ph: 814944.8100
Pie 570-253-8941 Fax 814944-5747
Fax 570.253-4817 Housing Opportunities, Inc.
133 Seventh Street CARBON COUNTY
BUCKS COUNTY Post Office Box 9 EOC of Schuylkill County
Acorn Housing Corporation McKeesport, PA 16134 225 N. Centre Street
846 North Broad Street Ph: 412-6641906 Pottsvft PA 17901
Philadelphia, PA 19130 Fax 412-664.0873 Ph: 570.622-1995
Ph: 215.765.1221 Fac 570.622-0429
Fax 215.765-1427 CCCS Of Western PA
YMCA Building
Bucks County FlotASing Group, Inc. 339 N Washington Street 36711 Cresent Court East
140 East Richardson Avenue Butler, PA 16001 Whitehall, PA 18052
LangharrA PA 19047 Ph. 724-M-7812 Ph: 610.821-4011
Pit 215.750-4310 Ph: 8OD-220-2733 (717 and 814 only)
Fax 215-750.4318 Mon-Valley Unemployed Committee Fax 61D•821-0137
120 E- 9" Avenue
RACE Homestead, PA 15120 CCCS of Northeastern
PA
167 Allegheny Avenue, a Floor Ph: 412-462-9962 1400 Abington Executive Park
Philadelphia, PA 19140 Fax 412-462-9964 Suite 1
Ph: 215-426.SM Clarks Summht, PA 18411
Famc 215.426-9122 Credit Counselors of PA Ph: 570.587-9163
401 Wood Street, Suite 906 Ph: 80D•922-9537
Community Development Corp. of Pittsburgh, PA 15222 Fax: 576.5874134
Frankford Ph: 412-038-9954 Fax: 570-587.9135
4620 Griscom Street Ph: 800-737-2933
Philadelphia, PA 19124 Fax 412-338-9963 9 South 16 Street
Ph: 215-7442990 Stroudsburg, PA 18360
Fax 215-7442012 CAMBRIA COUNTY Ph: 570-420.8980
Bedford-Fulton Hawing Services Ph: 800.922-9537
Northwest Counseling Service R.D. 1, Box 384 Fax 570-420.8981
6141 North Broad Street Everett, PA 15537
Philadelphia, PA 19141 Ph: 814.623-9129 CornMssian an Economic Opportunity of
PIt: 215.3247500 Fax 814.623-7187 Luzeme County
Fax 215.3248753
Indiana Cry Community Action Pro
ram 163 Amber Lane
Wil
Barra
PA 1
CCCS of Delaware valley g
827 Water Street, Box 187 ,
kes-
8702
Ph: 570.826-0510
1515 Market Street - Suite 1325
i Indiana, PA 15701 Ph: 8OD-822-0359
Ph
ladelphia, PA 19107 Ph: 412-465.2657 Fax 5704829-1665 - Cal before faxing
Ph: 215-563-5665 Fac 412.465-5118 Ph: 570.455.4994 - Hazelton
Fax 2154864-2666 Fax 570.455-5631 - Cal before faxing
Ph: 570.836-4090 -Tunkhannock
31 W. Market Street CCCS of Delaware Valley CCCS of Western PA
Wilkes-Barre, PA 18702 1515 Market Street 219-A College Park Plaza
Ph: 570.821-0837 Suite 1325 Johnstown, PA 15904
Ph: 800-922-9537 Philadelphia, PA 19107 Ph: 814-539-6335
Fax 570.821-1785 Ph: 215-563-5665
Fax: 215-563-7020 CLINTON COUNTY
1631 S. Atherton Street Lycoming-Clinton Counties
Suite 100 Comrtxnity Housing Counseling Inc. Commission for Community Action (STEP)
State College, PA 16801 Post Office Box 244 2138 Lincoln Street
Ph: 814-238-3668 Kennett Square, PA 19348 Post Office Burr 1328
Fax 814-238-3669 Ph: 610.444-3682 Williamsport, PA 17703 -
Fax: 610-444-8243 Ph: 570.326.0587
CENTRE COL TY Fax 570.322-2197
CCCS of Western Pennsylvania, Inc. Phila. Council for Community Adv.
217 E. Plank Road 100 North 17' Street CCCS of Northeastern PA
Altoona, PA 16602 Suite 600 201 Basin Street
Ph: 814.944.8100 Philadelphia, PA 19103 Williamsport, PA 17703
Fax: 814-944-5747 Ph: 215-567-7803 Ph: 570-323-6627
Fax 215-963-9941 Fax: 570-323.6626
Lytoming-Clinton Co. Comm. For
Community Action Community Development Corp of CCGS of Northeastern PA
(STEP) Fran kford 1631 S. Atherton Street
2138 Lincoln Street Group Miinistry Suite 100
Post Office Box 1328 4620 Griscom Street State College, PA 16801
Wiiansport, PA 17703 Philadelphia, PA 19124 Ph: 814-238-3668
Ph: 570.326-0587 Ph: 215.744-2990 Fax: 814-238-3669
Fa: 570.322-2197 Fax: 215.744-2012
COLUMBIA COUNTY
CCCS of Northeastern PA CCCS of Delaware Valley CCCS of Northeastern Pennsylvania
1631 S. Atherton Street Marshal Building 31 W. Market Street
suits 100 790 E. Market Street Post Oftke Box 1127
State College, PA 16801 Suite 215 W ilkes43w% PA 18702
Ph: 814-2383668 West Chester, PA 19382 Ph: 570-821-0837
Fax 814-238-3669 Ph: 215.563-5665 Ph: 800.922-9537
Fax: 570-821-1785
CCCS of Northeastern PA American Credd Conselno Institute
201 Basis Street 845 Coates Street Commission an Economic Opportunity d
Alianspo
rt, PA
7703 Coatesville, PA 19= Luzeme Canty
?
27
t
Ph: 888-212-6741
163 Amber Lane
Fax: 570,323-6626 Wilkes-Barre, PA 18702
144 E. Dekolb Pike Ph: 570.828-0510
CHEST?NTY King of Prussia. PA 19406 Ph: 800.822-0359
Acorn Horsing Corporation Ph: 610.971-2210 Fax: 5704129.1665 - Cal before faxing
846 North Broad Street Fax: 610-265.4814 Ph: 570-4554994 - Hazaaan
PNWoW% PA 19130 Fax: 57040-501 - Cal before faxing
Ph: 215.765.1221 755 York Road Ph: 57043&4090 - Tunkhannock
Fmc 215.765-1427 Suite 103
Warminster, PA 18974 1400 Abington Executive Park
Budget Counseling Center Ph: 215444-9429 Suite 1
247 Norht Fdth Street Fax: 215-956-6344 Clarks Summitt, PA 18411
Reading, PA 19601 Ph: 570-587-9163
Ptx 810-375-7886 CLARION COUNTY Ph: 800.922-8$37
Fax 215.375.7830 CCCS of Western Pennsylvania, Inc. Fax 570-587-9134
YMCA Building Fax: 570-587-9135
RACE 339 North Washington Street
167 W. Allegheny Avenue
2nd Boor Butler, PA 18001 CRAVPFORD COUNTY
Ph: 412.282-7812 Booker T. Washington Center
Philadelphia. PA 19140 1720 Holartd Sued
Pit 215-428.8025 CLEARFlELD COUNTY Erie. PA 16503
Fax: 215.426-9122 Keystone Economic Development Pit 814.453-6744
corporation
Fax 814-45"749
Media Fellowship House 1964 Mary Gram Lane
302 S, Jackson Street Johnstown, PA 15901 John F. Kennedy Center, inc.
Mekfia, PA 19063 Ph: 814.535.6556 2021 East 20° Street
Ph: 610-585-0846 Fax: 814-539-1688 Ede, PA 16510
Fax: 810.565-8567 Ph: 814-898.0400
CCCS d Wester Pennsylvania, Inc. Fax 814.898-1243
Tabor Community Services, Inc. 217 E. Plank Road
439 E, King Street Altoona, PA 16602 Greater Ede Community Action Committee
Lancaster, PA 17602 Ph: 814944-8100 18 West a street
Ph: 717-397-5182 Fa: 814.944-5747 Erle, PA 16501
Ph: 800.788-5062 (H.O. only) Ph: 814-459-4581
Fax 717399.4127 Indiana Co. Community Action Fax: 814-45&0161
Program -
American Red Cross of Chester 827 Watr Street Shenango Valley Urban League, Inc.
1729 Edgemo rrl Avenue Box 187 601 Indiana Avenue
Chester, PA 19013 Indiana, PA 15701 Farrell, PA 16121
Pit 610-874-1484 Ph: 724465.2657 Ph: 412-981-5310
Fax 724
465 5118
Northwest Counseling Services CUMBERLAND
f
6001 N. Broad Street
CCCS t# lVortheastem PA n Penns
COGS CCS of
of Wester Pennsylvania, Inc.
Philadelphia, PA 19141 1631 S. Atherton Street 2000 Unglestown Road
Pic 215324.7600 Suite 100 Harrisburg, PA 17102
Fax: 215-324-8753 State College, PA 16801 Ph: 717-541-1757
Ph: 814-238-3668
Fax 814-238-3669
Url wn Street League d Metropolitan Harrisburg ACCI CCCS of Western Pennsylvania, Inc.
Harrisburg, PA 17101 175 Strafford Avenue
Suite 1 1 North Gate Square
Ph: 717-234-5925
Wayne, PA 19067 2 Garden Center Drive
Greensburg
PA 15601
Fax 717-234.9459 Ph: 610.971-2210 ,
Ph: 724.83&1290
Fax: 610.687-7860
Community Action Comm. of the Capital Tableland Services
Inc
Region
1514 Derry Street
Northwest Counseling Service
5001 North Broad Street .
,
131 North Center Avenue
Harrisburg, PA 17104
Philadelphia, PA 19141 Somerset, PA 15501
Ph: 814-445-9628
Pfr 717-232-9757
Fax 717-234-2227 Ph: 215-324-7500
Fax 215.324-8753 Fax 814-443-3690
Flnarr:i21 Counseling Services of Franklin
rd RACE Mon Valley Unemployed Committee
120 E
9° Avenu
31 West 3
Street
Waynesboro
PA 17268 167 W.
Allegheny Ave., 2"d Floor .
e
Homestead, 15120
,
.__Ph: 717-762-3285 Philadelphia, PA 19140
Ph: 215-426-8025 Ph: 412-482-9 -9962
YWCA of Carlisle Fax: 215-426-9122 Community Action Southwest
3010 Street
Carl^ PA 17013
Cor rnunity Housing Counselor, Inc. 22 W West Hg Street
Waynesburg, 15370
Ph: 717-243-0818 Past Office Box 244
Kennett Square, PA 19348 Ph: 724-852-2893
Fax 717-731-9589 Ph: 610.4443682 Fayette Co Community Action Agency
he.
Adams County Housing Authority Fax 610-444-8243 ,
137 North Beeson Avenue
139-143 Carlisle Street
Community Dowel Corp of Frankford Uniontown, PA 15401
Ph: 724-437-6050
Gettysburg, PA 17325
Ph: 717-334-1518 Group hNnistry Ph: 800-427-INFO
Fax 717-334-8328 4620 Griscom Street
Philadelphia, PA 19124 Fax 724-437-4418
DAUPHIN COUNTY Ph: 215-7442990
Fax 215-7442012 CCCS of Western PA
CCCSof Westem Pennsylvania
)no. 199 Edson Street
,
2000 Linglestown Road
CCCS of Delaware Valley UniontowrY PA 16401
Pry- 724-439-1939
Harrisburg, PA 17102 280 North Providence Road
Ph: 717-541-1757
Fax 717-541.4670 Medial, PA 19063 FOREST COUNTY
Ph: 215-563-5665 Warren-Forrest Counties Economic
Cornownily Action Commission of the ACCI
Opportunity
CCouncil
Capital Region 144 E. Dekalb Pike 204
Post Office Box 547
1514 Derry Street
Harrisburg, PA 17104 King of Prussia. PA 19408
Ph: 610-971-2210 warren, PA 16365
Ph: 717-232-9757
Pager: 610-973-6219 Ph: 814726-2400
Fax 814723.0510
Fax 717.234-2227
Urban League of Metropolitan Harrisburg
"
ELK COU
NTY
John F. Kennedy Center, Inc.
FRANKLIN COUNTY
Financial Services Unlimited
2107 K 6
Street
Harrisburg, PA 17101 East 20" Street
Erie
PA 16510 31 West 3'd Street
Ph: 717-234-5925 ,
Ph: 814898-0400 Waynesboro. PA 17268
Ph: 717-762.3285
Fax 717-2349459 Fax 814-898-1243
DELAWARE COUNTY
Northern Tier Community Action Corp CCCS o (Western Pennsylvania, Inc.
912 South George Street
_ ? n Housing s
d Sy
848 North Broad 2021
Post Office Box 389 York, PA 17403
,
19130
135 West 4 Street Ph: 717-846.4176
Ph 215.765-1221
Fax 215.765-1427 Emporium, PA 15834
Ph: 814466-1161 Community Action Commission of Capital
Region
CCCS d Delaware Valley Fax 814488.0625 1514 Derry Street
1515 Market Street
ERIE COUNTY Harrisburg, PA 17104
Ph: 717-252-9757
Suds 1325 •
Philadephia
PA 19107 Booker T. Washington Center
Fax 717-234-2227
, 1720 Holland Street
Ph 215-563-5665
Fauc 215.864.2666 Ede, PA 16503 CCCS of Western PA
Ph: 814.453-5744 2000 Linglestown Road
Media Fellowship House Fax 814453-5749 Harrisburg, PA 17102
302 a Jackson Street
Jahn F. Kennedy Carder, Inc. Ph: 717-641-1757
Fax: 717-541-4670
Madre, PA 19063 2021 East 2& Street
Ptr 610.565.0846 _
Fax 610.565.8567 Erie, PA 16510
Ph. 814898-0400 YWCA of Carlisle
Philadelphia Council for Community
Fax 814898-1243 301 G Street
Cadbsle, PA 17013
Advancement
100 North 17 St
t
Greater Erie Community Action Ph: 717-243-3818
Fax 717-2433948
ree
Sulte 800
Plrledelplnia, PA 19103 committee
18 West 9^ Street
Erie
PA 16501
American Red Cross-Hanauer Chapter
Ph 215-567-7803 ,
Pfe 814459-4581 529 Carlisle Street
Hanover
PA 17331
Fax 215-963-9941 Fax 814-456-0161 ,
Ph: 717-637-3768
American Red Cross of Chester E8XW COUNTY Fax. 717-6373294
1729 Edgmott Avenue
Giesler, PA 19013 Action Housing, Inc.
425 a Avenue Urban Le
of Metropolitan H
bg.
?
Ph: 610.874.1484 Suite 950 2107 N.6
Street
Harrisburg, PA 17101
Pittsburgh, PA 15219 Ph: 717-234-5925
Ph: 412-391-1956 Fax 717-234.9459
Ph: 412-281-2102
Fax 412-391-4512
Adams County Housing Authority Imam Co Community Action Program LAWRENCE COUNTY
139 -143 Carlisle Street 827 Water Street, Box 187 CCCS Of Western Pennsylvania
Gettysburg, PA 17325 Indiana, PA 15701 1° Federal Plaza
Ph: 717-3341518 Ph: 724-465.2657 Suite 406
Fax 717-3348326 Fax 724465-5118 North MN Street
FULTON COUNTY
CCCS O (Western PA New Casfi% PA 16101
Ph: 724-652-8074
Bedford-Fullon Housing Services 219-A College Park Plaza
R.D. 1, Box 384 Johnstown, PA 15904 312 Chestnut Street
Everett PA 15537 Ph: 8145396335 Suite 227
Ph: 814.623-9129 MeadvNe. PA 16335
Fax 814.623-7187 JEFFERSON COUNTY Ph: 814-393-8570
John F. Kennedy Center, Inc.
CCCS of Western Pennsylvania, Inc. 2021 East 20° Street Shen8rW Valley Urban League
Inc
912 South George Street
Erie, PA 16510 ,
,
501 Indiana Avenue
York, PA 17403 Ph: 814.898-0400 Farrell, PA 16121
Ph: 717-846.4176 Fax: 814-898-1243 Ph: 72498153i0
Frtencibl Counseling Services of Franklin
31 West and Street Indiana County Community Action
OPPot i d Beaver County
Frogman 650 Corporation
650 St.
.
Waynesboro, PA 17268 827 Water Street, Box 187 Suite 207
Ph: 717-762-3285 Indiana, PA 15701 Beaver, PA 15009
Ph: 724465-2657 Ph: 724728-7202
WraYnerization Office Fax 724-465-5118 Fax 724728-7202
917 Lift Street
Huntingdon, PA 16652 CCCS of Western Pennsylvania, inc. LEBANON COUNTY
Ph: 814843-2343 YMCA Build'
Cabinet of Schuylkill
k Opportunity
North Washington Street County
GREENE COUNTY Butler, PA 16001 225 North Centre Street
Action Housing, Inc.
425 &Avenue Ph: 724-282.7812 Pottsville, PA 17901
Suite 950
JUNIATA COUNTY Ph: 570-6221995
Fax: 574622.0429
Pittsburgh, PA 15219 CCCS of Western Pennsylvania, Inc.
Ph: 412-391-1956 217 F- Plank Road Tabor Community Services
Inc.
Ph: 412-281-2102 Altoona, PA 16602 ,
439 E. King Street
Fax 412-391-4512 Ph: 814.944.8100 Lancaster, PA 17602
fax 814944-5747 Ph: 717 97-5182
Community Action Southwest Ph: 800-788-5062
22 West High Street Weathertzation Office Fax 717,199-4127
Waynesburg. PA 15370 917 Affi t Street
Ph: 724.852-2893 Huntingdon, PA 16652 LEHIGH COUNTY
Fax: 724-627-7713 Ph: 814843-2343 CCCS of Lehigh Valley
Mon-valley Unemployed Committee
LACKAWANNA COUNTY 3671 Crescont Court East
Whitehall
PA 18052
120 E. e Avenue Q= of Northestem Penn svhr a ,
Ph: 610-821-4011
5120
HcOlestsed, PA 31 W. Market Street Ph: 800-220-2733 (717 and 814 only)
Ph: 412-482-9962 Post 0111M Box 1127 Fax: 610-821-8932
Fax: 412-462-9964 Wiles-Barre, PA 18702
GCCS of Western Pennsylvania
Inc. Ph: 570-8210837
Ph: 800-922-9537 Economic Opportunity Cabinet of Schuylkill
,
1 North Gate Square
Fax 570.821-1785 County
225 North Centre Street
2 Garden Center Drive Pottsville, PA 17901
Greensburg, PA 15601 1400 Abington Executive Park Ph: 570.622-1995
Ph: 724838-1290 Suite 1 Fax 570.622.0429
Clarks Summit, PA 18411
HUNTNGDON COUNTY Ph: 570-587-9163 LU2ERNE COUNTY
Befad-Fullor1 Housing Services Ph: 8OD-955-9537 CCCS Of WRIbeastem PenaVlvanis
R.D. 1, BcK 384 Fax: 570.587-9134 31 W. Market Street
Everett PA 16537 Fax 570.587-9135 Post Office Burt 1127
Ph: 814623-9129 Wilkes-Barre, PA 18702
Fax 814-623.7187 LANCASTER COUNTY Ph: 570.821-0837
Community Housing Counselors, Ph: 800.922.9537
WeatredzaUon Office
lherh Incorporated Faoc 570.821-1785
917
Street
Street
ffin P09 Office Box 244
n,
Fknti
, PA 1 16652 KwW Square, PA 19348 1400 Ablagton Executive Park
Ph 814-64 Ph: 215-444-3682 Suite 1
CC(Sd Western Pennsylvania Inc Fax 215-444-3178 Clarks Srmmit, PA 18411
.
217 E. Plank Road
CCCS of Western Pennsylvania, inc. Ph- 570-587-9163
Ph: 800.955.9537
ABoons, PA 16602 912 South George Street Fax 570-587-9134
Ph: 814944-8100 York, PA 17403 Fax: 570-567.9135
Fax: 6149445747 Ph: 717-846-4176
INDUkKA COUNTY
CCCS of Lehigh Valley Commission on Economic Opportunity of
Luzern County
CCCS of Western
Pennsylvania, Inc. 3671 Crescent Cant East 163 Amber Lane
1 North Gate Square Whitehall, PA 18052 Wikes-Barre
PA 18702
2 Garden Center Drive Ph: 215-821-4011 ,
Ph: 570.826.0510
Greensburg, PA 15601 Ph: 8OD-220.2733 (717 and 814 only) Ph: 8004M-0359
Phi 724838-1290 Fax 215-821-8932 Fax 5704129.1665 - Coll before faxing
Ke
yslow Economic Development
i
Tabor Community Services, Inc. Ph: 570456.4994 - Hazelton
Fax 570.455-5631 - Call before faxing
Corporat
on
1964 race Lane
Mary 439 E.
Kin pAtreet
L
Ph: 570-838.4090- Tunkhannock
Johnstown, PA 15901 ancas
17602
Ph: 717-397-5182 EOC of Schuylkill County
Ph 814535.6556 Ph: 800-788-5062 225 North Centre Street
Fmc 814-539-1688 Fax 717~999-4127 Pottsville. PA 17901
Ph: 570.622-1995
Fax 570-622-0429
LYCOMING COUNTY
CCCS of Northeastern Permsvlvenia
31 W. Market Street
Poet Office Box 1127
Wakes-Barre, PA 18702
Ph: 570-821-0837
Ph: 800.922-9537
Fax 570-821-1785
1400 Abington Executive Park
Suite 1
Clarks Summitl, PA 18411
Ph: 570;587-9163
Ph: 800-922-9537
Fax: 570-587-9134
Fax 570-587-9135
201 Basin Street
Williamsport, PA 17703
Pit: 570323-6627
Fax 570-323-6626
Lycarong-Canton Counties Commission
for
Ca mxWty Action (STEP)
2138 Lincoln Street
Post Offce Box 1328
Williamsport, PA 17703
Ph: 570326-0587
Fax 570-322-2197
WK AN COUNTY
Jahn F. Kennedy Center, Inc.
2021 East 20w Street
Etfe, PA 16510
Ph: 814-896-0400
Fax: 814.898.1243
Northem Tier Community Action Group
Rost Office Box 389
135 W. 4w Street
Empodum, PA 15834
Ph: 814-486-1161
Fax 814.486-0825
MERCER CO}1?
Shonargo Valley Urban League, Inc.
601 Indiana Avenue
Farrel, PA 16121
Ph: 724-981-5310
CCCS of Western Pennsylvania, Inc.
YMCA Building
339 North Washington Street
Batter, PA 16001
Ph 724-282-7812
CO!!
CCCS d Western Pennsylvania, Inc.
217 E. Plank Road
Altoona, PA 16602
Ph: 814-944-8100
Fax 814-9445747
CCCSd Northeastern Pennsylvania
1631 S. Atherton Street
Sidle 100
State College, PA 16801
Pit 814-238-3668
Fax 814238-3669
WeadWzadon office
917 MIM Street
Huntingdon, PA 16652
Ph: 814.643-2343
MONROE COUNTY
CCCS d Northeastern Pennsylvanla
31 W. Markel Street
Post Office Box 1127
Wakes-Barre, PA 18702
Ph: 570821-0837
Ph: 800922-9537
Fax 570821-1785
9 South 7 h Street
Stroudsburg, PA 18360
Ph: 570-420-8980
Ph: 800-922-9537
Fax: 570.420-8981
1400 Abington Executlve Park
Suite 1
Clarks Summitt, PA 18411
Ph: 570-587-9163
Ph: 800-922-9537
Fax 570-587-9134
Fax 570.587-9135
Comm on Economic Opportunity of
Luzeme County
..163 Amher.Lane
Wakes-Barre, PA 18702
Ph: 570-826-0510
Ph: 800-822-0359
Fax 570-829-1665 - Call before faxing
Ph: 570-455-4994 - Hazelton
Fax 570.455-5631 -Call before faxing
Ph: 570-836-40W - Tunkhannock
MONTGOMERY COUNTY
Acorn Housing Corporation
846 North Broad Street
Philadelphia, PA 19130
Ph: 215.766.1221
Fax 215-765-1427
CCCS of Delaware Valley
Norristown Business Center
190 W. Germantown Pike, Suite 140
Norristown, PA 19401
Ph. 215.663-5665
CCCS of Delaware Valley
1515 Market Street, Suite 1325
Philadelphia, PA 19107
Ph: 215.563-5665
Fax 215-864-2666
Northwest Counseling Service
5001 N. Broad Street
Philadelphia, PA 19141
Ph: 215-324-7500
Fax 215-324-8753
Community Action Development Comm
113 E. Main Street
Norristown, PA 19401
Ph: 610277-6363
Fax 610277.2123
Community Housing Counselors Inc.
Post Office Box 244
Kennett Square, PA 19348
Ph 215-444-3682
Fax 215-444-8243
Media Fellowship House
302 S. Jackson Street
Media, PA 19063
Ph: 610.6850846
Fax 610-565-8567
Phila Council for Community Advnrrt
100 North 17w Street, Suite 600
Philadelphia, PA 19103
Ph. 215.587-7803
Fax 215-963.9941
American Credit CounsOhm Institute
845 Coates St
Coatesville, PA 19320
Ph: 888-212-6741
144 E. Dekalb Pike
King of Prussia, PA 19406
Ph: 610971.2210
Fax: 610265-4814
755 York Road
Suite 103
Warminster, PA 18974
Ph: 216-444-9429
Fax 215-956-6344
MONTOUR COUNTY
C_CCS of Northeastern Pennsylvania
31 W. Market Street
Past Office Box 1127
Wilkes-Barre, PA 18702 .
Ph. 570.821-0837
Ph: 800-922-9537
Fax 570-821-1785
1400 Abington Executive Park
,Suite 1 - .
Clarks Surnmitt, PA 18411
Ph: 670-687-9163
Ptr 800-922-9537
Fax: 570.587-9134
Fax 570-587-9135
NORTiiHAMPTON COUNTY
CCCS of Lehigh Valley
3671 Crescent Court East
Whkdw A, PA 18052
Ph: 610321-4011
Ph: 800-220-2733 (717 and 814 only)
Fax 610821-8932
NORTHUMBERLAND COUNTY
CCCS d Northeastem Penn Nanla
31 W. f arket Street
Post Office Box 1127
Wakes-Barre, PA 18702
Ph: 570821-0837
Ph: 800-922-9537
Fax 570821-1785
1400 Abington Executive Park
Suite 1
Clarks Summitt, PA 18411
Ph: 670-587-9163
Ph: fD0-922-9537
Fax: 570-587-9134
Fax 570-587-9135
201 Basin Street
Williamsport, PA 17703
Ph: 570.323.6627
Fax 570.323-6628
Economic Opportunity Cabinet of Schuylkill
County
225 North Centre Street
Polls ft PA 17901
Pit 570622.1995
Fax 570-622-0429
PERRY COUNTY
CCCS of Westem Pennsylvania, Inc.
2000 Unglestown Road
Harrisburg, PA 17102
Ph: 717-641-1757
Fax 717-541-4670
Urban League of Metropolitan Harrisburg
2107 N. r Street
HafldsbUrg, PA 17101
Ph: 717-2345925
Fax 717-2349459
YWCA of Carlisle
301 G Stt?eet
CarAste, PA 17013
Ph: 717-243.3818
Fax 717-243-3948
Financial Counseling Services of Franklin
31 West V Street
Waynesboro, PA 17268
Ph: 717-762-3285
Weethetization oftice
917 Miffkt Street
Huntingdon. PA 16652
Ph: 814.643-2343
i
Community Action Commission of The
Capital Region
1514 Derry Street
Harrisburg, PA 17104
Ph: 717-232-9757
Fax: 717-234.2227
PHILADELPHIA COUNTY
Acorn Housing Corporation
846 North Broad Street
Philadelphia, PA 19130
Ph: 215.765-1221
Fax: 215-765-1427
Nordwiest Counseling Service
5001 N. Broad Street
Phbdelphia, PA 19141
Ph: 215-324-7500
Fax: 215.324-8753
CCCS of Delaware Valley
1515 Market Street
Suite 1325
Philadelphia, PA 19107
Pitt 215.563-5665
Fax 215.864-2666
RACE
167 W. Allegheny
2" Floor
PttAedetpftia, PA 19140
Ph: 216-426.8025
Fax 215426-9122
Media Fellowship House
302 S. Jackson Street
Media PA 19063
PM. 610565-0846
Fax 610-565-8567
PCCA
100 North 17° Street
Suits 600
Miladelphia, PA 19103
Ph: 215.567-7803
Fax 215.963-9941
CCCS of Delaware Valley
One Cherry Hill
Strke215
Cherry Hill, NJ 08002
Ph: 216-563-5685
Housing Association of Delaware Valley
1500 Walnut Street
Style 601
PK%Kk4A* PA 19102
Ph: 215-545-6010
Fax: 215790-9132
Housing Association of Delaware Valley
658 North Welts Street
Philadelphia, PA 19123
Pty 215-978-0224
Fax 215-765-7614
Community Devel. Corp. of Frankford
Group Ministry
4620 Gdscorn Street
Philadelphia, PA 19124
Ph: 215.744-2990
Fax 215-744-2012
American Credit Counseling Institute
845 Coates Street
Coatesville, PA 19320
Ph: 888.212-6741
144 E. Dekalb Pike
King Of Prussia, PA 19406
Ph: 810971-2210
Fax 610-265-4814
765 York Road
Suite 103
Warminster, PA 18974
Ph: 215.444-9429
Fax: 215-956.6344
PIKE COUNTY
CCCS of Northeastern Pennsylvania
31 W. Market Street
Post Office Box 1127
Wilkes-Barre, PA 18702
Ph: 570.821.0837
Ph: 800.922-9537
Fax: 570821-1785
9 South 7w Street
Stroudsburg, PA 18360
Ph: 5704204980
Ph: 800-922-9537
Fax: 570-420.8981
1400 Abington Executive Park
Suite i
Clarks Summih, PA 18411
Ph: 570587-9163
Ph: 800922-9537
Fax: 570587-9134
Fax: 570.587-9135
POTTER COUNTY
Northern Tier Community Action Group
135 West 4r' Street
Emporium, PA 15834
Ph: 814.486-1161
Fax 814-486.0825
SCHUYLIGLL COUNTY
Budget Counseling Center
247 North Fifth Street
Reading, PA 19601
Ph: 610375.7866
Fax 610375-7830
Commission on Economic Opportunity
of Luzern Co.
163 Amber Lane
Wilkes-Barre, PA 18702
Ph: 570826-0510
Ph: 800-872-0359
Fax 570.829-1665 - Cal before faxing
Ph: 570.455-4994 - Hazelton
Fax: 570.465-5631 - Cal before feo6ng
Ph: 570836-4090-Tunkhannock
Economic Opport Cabinet of Schuylkill
Co.
225 N. Centre Street
Pottsville, PA 17901
Ph: 570622-1995
Fax 570-622-0429
CCCS of Lehigh Valley
Post Office Box A
Whitehall, PA 18052
Pit 810821-4011
Fax 810-821-8932
SNYDER COUNTY
CCCS of Western Pennsylvania, Inc..
2000 Linglestown Road
Harrisburg, PA 17102
Ph: 717-541-1757
,Fax 717-541.4670
Community Action Commission of the
Capital Region
1514 Derry Street
Harrisburg, PA 17104
Ph: 717-232-9767
Fax 717-234-2227
Urban League of Metropoitan
arrisbur
107 % N. 6 Street
Harrisburg, PA 17101
Ph: 717-234-5925
Fax: 717-234.9459
SOMERSET COUNTY
Bedford-Fulton Housing Services
R.D. 1, Box 384
Everett, PA 15537
Ph 814-623-9129
Fax 814-623-7187
CCCS of Western Pennsylvania, Inc.
1 North Gate Square
2 Garden Center Drive
Greensburg, PA 15601
Pit 724$38-1290
Tableland Services Inc.
535 East Main Street
Somerset, PA 15501
Ph: 814-445-9628
Ph 800-452-0148
Fax: 814-443-3690
Keystone Economic Development Corp.
1954 Mary Grace Lane
Johnstown, PA 15901
Ph: 814-535-8556
Fax 814-539-1688
CCCSof Western PA
219-A College Park Plaza
Johnstown, PA 15904
Ph: 814-539.8335
SI&UVAN COUNrr
CCGS of Norttteasiem Pennsvivante
1400 Abington Executive Park
Suie i
Clarks Summkt, PA 18411
Ph: 570-587-9163
Ph: 800-922 9537
Fax: 570587.9134
Fax 570.567-9135
31 W. Market Street
Wilkes-Barre. PA 18702
Ph: 570-821-0837
Ph: 800.922-9537
Fax 570.821-1785
The Trehab or of Northeastern PA
185 Ehnfra Street
Post Office Box 218
Troy, PA 16947
Ph: 570-297-2101
Fax 570.297-2799
17 Crafton Street
Wtllsboro, PA 16901
Pit: 570.724-5252
Fax 570-724-5783
103 Warren Street
Post Offk;e Box 709
Tunkhahnock,PA 18657
Ph: 570-836.6840
Fax 5704366332
German Street
Post Office Box 389
Dushore, PA 18614
Pitt 570928-9668
Fax 670-928-8144
931 Main Street
Honesdale, PA 18431
Ph: 570-253-8941
Fax: 570253-4817
7 Lake Avenue
Boor 339
Momms% PA 18801
Ph: 570278-3338
Ph: 800982-4045
Fax: 570-278.1889
SMUEHANN A COUNTY 103 Warren Street Warren-Forrest Counlies Economic
M o Norttern Pennsylvania Post Office Box 709 Opportuncly Council
S? j timgton Executive Park Tunkhannock, PA 18657 1209 Pennsyvenia Avenue
West
Ph: 570-836.6840 ,
Post Office Box 547
Clarks Summitt, PA 18411 Fax: 570-836-6332 Warren
PA 16365
Ph: 570.587-9163 ,
Ph: 814-726-2400
Pit: 800.922-9537 931 Main Street Fax: 814-723-0510
Fax 570-587-9134 Honesdale, PA 18431
Fax 570-587-9135 Ph: 570-253-8941 WASHINGTON COUNTY
- Fax: 570-253-4817 Action Housing, Inc.
31
W. Market Sired 425 6n Avenue
Wilkes-Barre, PA 18702 The Trehab Center of NE PA suite 950
Pit: 570$21.0837 7 Lake Avenue Pntsburgh
PA 15219
Ph: 800-922-9537 Box 339 ,
Mr. 412-391-1956
Fax 570.821-1785 Montrose, PA 18801 Ph: 412-281-2102
b C
t
Am Ph: 570-278.3338 Fax 412-3914512
enter 0 Northeastern PA
0-i
- Ph: 800-9824045
185 Elmira Street Fax: 570.278-1889 CCCS of Western Pennsylvania
Inc
Past Office Box 218 ,
.
1 North Gate Square
Troy, PA 16947 UNION CiOUNTY 2 Garden Center Drive
Ph: 570-297-2101 Lycorning-Clinton Co Comm for Comm Greensburg, PA 15601
Fax: 570.297.2799 Action (STEP) Ph: 724-838-1290
2138 Lincoln Street
German Street Post Office Box 1328 Housing Opportunities
Inc
PostOtlice Box 389
Williamsport, PA 17703 .
,
133 Seventh Street
Oushore,PA 18614 Ph: 570.326-0587 McKeesport
PA 15132
Pie 570-928.9668 Floc: 570-322-2197 ,
Ph: 412-664.1690
Fax-570-928.8144 Fart 412-664-0873
CCCS ot Western Pennsylvania. Inc.
17 Cralton Street 217 E. Plank Rood CrecR Counselors of PA
Wdilsboro, PA 16901 Altoona, PA 16602 401 Wood Street
Ph: 570.724-5252 Ph: 814-944-8100 Suite 906
Fax: 570-724-5783 Fax: 814-944-5747 Pittsburgh, PA 15222
103 Warren Street
CCC9 o Norttteestem Pennsylvania Pie 412-338-9954
Ph.. WO-737-2933
Past Office Box 709 31 W. Market Street Fax 412-338-9963
Tutkhannock, PA 18657 posy Office Box 1127
Pte 570-836-6840 Wilkes-Barre, PA 18702 Community Action Southwest
Fax 570-836-6332
I Ph: 570.821-0837 22 West "gh Street
931 Main Ptx-
ac ?? ?85 WWnesburg, PA 15370
ft 724 724-M 852-2893
,
Haiesdafe, PA 18431
Ph: 570-253-8941 1400 Abington Executive Park 53 N. College Street
i Fax 570-253.4817 Suite 1 Wastringtor% PA 15301
7Lake Avenue Clanks Summitt, PA 18411 Ph: 724.222-8292
Pfc 570-587-9163
Box 339
MOrkhose
PA 18801 Ph: 800-822-9537
2
ley Unemployed Committee
w
, Fax: 570587-9134 1
0 E.
120 E. 9
Avenue
Pie 570-278-3338 Fax 570587-9135 Homestead
PA 15120
Ph: 800.982-4045 ,
Ph: 412-462-9962
Fax 570-278-1889 201 Basin Street Fax 412-462-9964
i Williernsport, PA 17703
TIOGA COUNTY Ph: 570323.6027 WAYHE COUNTY
rte. S of Narlheastem PennsvNaila Fax 570323.6626 CA= of Northeaster P Nk+arrla
1400 Abutgton Executive Park 1400 Abington Executive Park
suite 1 VENANQO CO Suite 1
Clerks Sunmitl, PA 18411 Greater Erie Community Action (larks Summitt
PA 18411
Ph: 570-587-9163 Committee ,
Ph: 570-587-9163
Pit 800.922-9537 18 West a Street Ph: 8004122.9537
Fac 570.587-9134 E4 PA 16501 Fax 570-587-9134
Fax 570.587-9135 Ph: 814-459-4581 Fax 570-597-9135
Fax 814.456-0161
31 W. Market Street 9 South 7 Street
W*es-Barre, PA 18702 CCCS of Western Pennsylvania, Inc. Stroudsburg
PA 18360
Ph: 570-82140837 YMCA Building ,
Ph: 570.420-89130
Ph: 800.922-9537 339 North Washington Street Pit 800.922.9537
Fax 570-821-1785 Butler, PA 16001 Fax 570-420.13981
Ph: 412-282-7812
ILTrahab Center of Northeastern PA
185 Elmira Street 31 W. Market Street
Past Otlice Box 218 John F. Kennedy Center, Inc.
2021 East 2e Street Wilkes-Barre, PA 18702
Troy, PA 18947
Erie, PA 16510 Ph: 570-821-37
Ph 800.922-9537
Ph: 570.297-2101 Ph: 814-898.0400 Fax 570-821-1785
Fax 570-297-2799 Fax 814-898-1243
German Street
WARREN COUN The Trehab Canter of NE PA
185 Elmira Street
Post Office Box 389
r Booker T Washington Caner Post Office Box 218
Dttahore, PA 18614 1720 Holland Street Tray
PA 16947
PIK 570-928.9668 Erie, PA 16503 ,
Pte 570-297-2101
Fax 570.928.8144 Ph: 814-453-5744 Fax 570-297-2799
Fax: 814-453.5749
17 Craftart Street 17 Craton Street
Wdsboro, PA 16901 Greater Erie Community Action Weilsboro
PA 16901
Ph: 570.724.5252 Committee ,
Ph: 570-724-5252
Fax 570-724-6783 18 West a Street Fax 570-724-5783
Erie, PA 16501
Ph: 814-459-4581
Fax 814-456-0161
103 Warren Street
Post Office Box 709
Tunkhannock,PA 18657
Ph: 570436-6840
Fax 570-836-6332
German Street
Post Office Box 369
Dushm, PA 18614
Ph: 570.928-9668
Fax 570-928-8144
931 Main Street
Honesdale, PA 18431
Ph: 570-253-8941
Fax 570-253-4817
7 Labe Avenue
Box 339
Monlros% PA 18801
Ph: 570.278.3338
Ph: 800-982-4045
Fax 570.278-1889
WESTMORELAND COUNTY
Action Housing, Inc.
425 6r' Avenue
suite 950
Pittsburgh, PA 15219
Ph: 412-391-1956
Ph: 412-281-2102
Community Action Southwest
22 West High Street
Waynesburg, PA 15370
Ph: 724-852-2893
CCCS of Western Pennsylvania, inc.
1 North Gate Square
2 Garden Center Drive
Greensburg, PA 15601
Ph: 724-838-1290
Housing Opportunities, Inc.
133 Seventh Street
McKeesport, PA 15132
Ph: 412-864-1590
Fax 412.664-0873
Keystone Economic Development
Corporation
1954 Mary Grace Larne
Johnstown, PA 15901
Ph: 814-535.6556
Fax 814-539-1688
Tableland Services Inc.
535 East Main Street
Somerset, PA 15501
Ph, 814445-9628
Ph: 800452-0148
Fax 814-0433690
199 Edison Street
UnIordown, PA 15401
Ph: 724439.8939
Indiana Co Community Action Program
827 Water Street
Box 187
Irtdfarta, PA 15701
Ph: 724.485.2657
Fax 724-465-5118
Man-Valley Unemployed Committee
120 E. 9d Avenue
Homestead. PA 15120
Ph: 412-462-9962
Fax 412-462-9964
Credit Oxwzelors of PA
401 Wood Street
Suite 906
Pittsburgh, PA 15222
Ph: 412-338-9954
Ph: 800-737.2933
Fax 412-338-9963
WYOMING COUNTY
Common Economics Opportunity of
Luzeme County
163 Amber Lane
Wilkes-Barre, PA 18701
Ph: 570-828.0510
Ph: 800-822-0359
Fax: 570829-1665 - Call before taxing
Ph: 570-455-4994 - Hazelton
Fax 570455-5631- Call before taxing
ft 570-836-4090 - Tunkhannock
CCCS of Northeastern PA
1400 Abington Executive park
suite 1
Clerks Summitt, PA 18411
Ph: 570-587-9163
Ph: 800-922-9537
Fax: 570-587-9134
Fax: 570.687-9135
31 W. Market Street
Wllkes-Barre, PA 18702
Ph: 570-821-0837
Ph: 800-922-9537
Fax: 570.821-1785
The Trehab Center of NE PA
7 Lake Avenue
Box 339
Montrose, PA 18801
Phe 570-278-3338
Pfx 800-982-4045
Fax 570-278-1889
185 ENrka Street
Post OSk:a Box 218
Troy, PA 16947
Ph: 570.297-2101
Fax 570.297-2799
17 Craftan Street
Wellsboro, PA 16901
Ph: 570-724-5252
Fax 570-724.5783
103 Warm Street
Post Office Box 709
Tunkhanrock, PA 18657
PK' 570836.6840
Fax 570836-6332
German Street
Post Office Box 389
Dushor% PA 18614
Ph: 570928-OWB
Fax 570.928.8144
931 Main Street
Honesdale, PA 18431
Ph: 570253-8941
Fax 570253-4817
YORK COUNTY
American Red Cross-Hanover Chapter
529 Carlisle Street
Hanover, PA 17331
Ph: 717537-3768
Fax: 717-637-3294
Housing Council of York
116 North George Street
York, PA 17401
Ph: 717-854-1541
Fax 717-845-7934
CCCS of Western Pennsylvania Inc.
2000 Lfnglestown Road
Harrisburg, PA 17102
Ph: 717.541-1757
For.. 717-541-4670
Adams County Housing Authority
139-143 Carlisle Street
Gettysburg, PA 17325
Ph: 717-334-1518
Fax 717-334-8326
CCCS of Western Pennsylvania, Inc.
912 South George Street
York, PA 17403
Ph: 717.846-4176
lv?`
?. 1
CASE NO: 2006-06670 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
TROUT TERESA ET AL
SHANNON SHERTZER
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
TROUT TERESA the
DEFENDANT , at 1810:00 HOURS, on the 1st day of December , 2006
at 508 HERMAN AVENUE
LEMOYNE, PA 17043 by handing to
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
14.08
.00
10.00
.00
q,
Sworn and Subscibed to
before me this
of
42.08-,)
day
So Answers:
R. Thomas Kline
12/04/2006
GOLDBECK MCCAFFERTY MCKEEV R
By:
;,
Z?
'Deputy Sh iff
A. D.
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-06670 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
TROUT TERESA ET AL
SHANNON SHERTZER
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
TROUT BART A the
DEFENDANT
at 1810:00 HOURS, on the 1st day of December , 2006
at 508 HERMAN AVENUE
LEMOYNE, PA 17043
TERESA TROUT, WIFE
by handing to
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs: So Answers:
Docketing 6.00
Service .00
Affidavit
.00
Surcharge 10.00 R. Thomas Kline
.00
??
16.00 12/04/2006
J a,?i??/U4 GOLDBECK MCCAFFERTY MCK?EVER
Sworn and. Subscibed to
By:
k I'
I1!
)
before me this
day
Deputy -
rerifif
of A. D.
In the Court of Common Pleas of Cumberland County
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS
OF MORGAN STANLEY ABS CAPITAL I INC. TRUST 2004-
HE9, MORTGAGE PASS THROUGH CERTIFICATES,
SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
No. 06-6670
vs.
TERESA TROUT
BART A. TROUT
(Mortgagor(s) and Record Owner(s))
508 Herman Avenue
Lemoyne, PA 17043
Defendant(s)
PRAECIPE FOR JUDGMENT
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE
OF COLLECTING THE DEBT.
Enter the Judgment in favor of Plaintiff and against TERESA TROUT and BART A. TROUT by default for want of
an Answer.
Assess damages as follows:
Debt $107,483.09
Interest from 01/05/07 to Date of Sale
Total
(Assessment of Damages attached)
I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECrROM ED AMOUNTS ALLEGED TO
BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN THE COMPLAINT.
I certify that written notice of the intention to file this praecipe was mailed or delivere to the party against whom judgment
a is to be entered and to his attorney of record, if any, after the default occurred and at le t ten d no to the date of the
filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1
Joseph A. Goldbe k, Jr.
Attorney for Plain 'ff
I.D. #16132 J
AND NOW ID Judgment ered in favor of
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUST E ON BEHALF OF THE CERTIFICATE HOLDERS
OF MORGAN STANLEY ABS CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH CERTIFICATES,
SERIES 2004 HE9 and against TERESA TROUT and BART A. TROUT by default for want of an Answer and damages
assessed in the sum of $107,483.09 as per the above certification.
Prothonotary
Rule of Civil Procedure No. 236 - Revised
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS
OF MORGAN STANLEY ABS CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH CERTIFICATES,
SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
VS.
No. 06-6670
TERESA TROUT
BART A. TROUT
(Mortgagors and Record Owner(s))
508 Herman Avenue
Lemoyne, PA 17043
Defendant(s)
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE
PURPOSE OF COLLECTING THE DEBT.
NOTICE
Notice is given that a judgment in the above-captioned matter has been entered against you.
Curt Long
Prothonot
By:
If you have any questions concerning the above, please contact:
Joseph A. Goldbeck, Jr.
Goldbeck McCafferty & McKeever
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
CWD-6627
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED
FOR THE PURPOSE OF COLLECTING THE DEBT.
DATE OF THIS NOTICE: December 22, 2006
TO:
BART A. TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE ON
BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN STANLEY ABS
CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
vs.
TERESA TROUT
BART A. TROUT
(Mortgagor(s) and Record Owner(s))
508 Herman Avenue
Lemoyne, PA 17043
Defendant(s)
TO: BART A. TROUT
508 Herman Avenue
Lemoyne, PA 1 7043-1 822
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Action of
Mortgage Foreclosure
Term
No. 06-6670
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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO
ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
20 xvh
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 5000 - 701 Market Street.
Philadelphia, PA 19106 215-825-6318
CWD-6627
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED
FOR THE PURPOSE OF COLLECTING THE DEBT.
DATE OF THIS NOTICE: December 22, 2006
TO:
TERESA TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE ON
BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN STANLEY ABS
CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
vs.
TERESA TROUT
BART A. TROUT
(Mortgagor(s) and Record Owner(s))
508 Herman Avenue
Lemoyne, PA 17043
Defendant(s)
TO: TERESA TROUT
508 Herman Avenue
Lemoyne, PA 1 7043-1 822
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Action of
Mortgage Foreclosure
Term
No. 06-6670
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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO
ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
?Il?CO??- rA Gafifbeck 7r
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 5000 - 701 Market Street.
Philadelphia, PA 19106 215-825-6318
VERIFICATION OF NON-MILITARY SERVICE
The undersigned, as the representative for the Plaintiff
corporation within named do hereby verify that I am authorized
to make this verification on behalf of the Plaintiff corporation
and that the facts set forth in the foregoing verification of
Non-Military Service are true and correct to the best of my
knowledge, information and belief. I understand that false
statements therein are made subject to penalties of 18 Pa. C.S.
4904 relating to unsworn falsification to authorities.
1. That the above named Defendant, TERESA TROUT, is about
unknown years of age, that Defendant's last known residence is
508 Herman Avenue, Lemoyne, PA 17043-1822, and is engaged in
the unknown business located at unknown address.
2. That Defendant is not in the Military or Naval Service
of the United States or its Allies, or otherwise within the
provisions of the Soldier of
Congress of 1940 and its Amendments-
Date:
VERIFICATION OF NON-MILITARY SERVICE
The undersigned, as the representative for the Plaintiff
corporation within named do hereby verify that I am authorized
to make this verification on behalf of the Plaintiff corporation
and that the facts set forth in the foregoing verification of
Non-Military Service are true and correct to the best of my
knowledge, information and belief. I understand that false
statements therein are made subject to penalties of 18 Pa. C.S.
4904 relating to unsworn falsification to authorities.
1. That the above named Defendant, BART A. TROUT, is
about unknown years of age, that Defendant's last known
residence is 508 Herman Avenue, Lemoyne, PA 17043-1822, and is
engaged in the unknown business located at unknown address.
2. That Defendant is not in the Military or Naval Service
of the United States or its Allies, or otherwise within the
provisions of the Soldiers' and Sailors' Civil f Action of
Congress of 1940 and its Amendments-
Date:
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
ULU i ?c.;HE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE ON BEHALF OF THE CERTIFICATE
HOLDERS OF MORGAN STANLEY ABS CAPITAL I
INC. TRUST 2004-HE9, MORTGAGE PASS
THROUGH CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
VS.
TERESA TROUT
BART A. TROUT
(Mortgagor(s) and Record owner(s))
508 Herman Avenue
Lemoyne, PA 17043
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION LAW
ACTION OF MORTGAGE FORECLOSURE
No. 06-6670
ORDER FOR JUDGMENT
Please enter Judgment in favor of DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN STANL Y ABS CAPITAL I
INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH CERTIFICATES, SE S 20 HE9, and against
TERESA TROUT and BART A. TROUT for failure to file an Answer in the ab e action within (20) days (or
sixty (60) days if defendant is the United States of America) from the date of s ice of the Complaint, in the sum
of $107,483.09.
Joseph A. Goldbeck,
Attorney for Plaintiff
I hereby certify that the above names are correct and that the precise reside?oe ess of the judgment
creditor is DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE ON EHALF OF THE
CERTIFICATE HOLDERS OF MORGAN STANLEY ABS CAPITAL I INC. TRU "C
2Q4-HE9, MORTGAGE
PASS THROUGH CERTIFICATES, SERIES 2004 HE9 7105 Corporate Drive PTX C-35 Plano, TX 75024 and
that the name(s) and last known address(es) of the Defendant(s) is/are TERESA TROUT, 508 Herman Avenue
Lemoyne, PA 17043-1822 and BART A. TROUT, 508 Herman Avenue Lemoyne, PA 17043-1822;
Z// (7 1
GOL )BECK McCAFFERTY
& McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney for Plaintiff
ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly assess the damages in this case to be as follows:
Principal Balance $95,535.17
Interest from 05/01/2006 through $5,415.69
01/04/2007
Reasonable Attorney's Fee $4,776.76
Late Charges
$341.27
Costs of Suit and Title Search $900.00
Escrow
$514.20
$107,483.09
GOLDBECK McCAF
BY: Joseph A. Goldb "k, Jr.
Attorney for Plaintiff
AND NOW, this / 04 day of J Q tit . , 2007 damages are assessed as above.
Pro Prothy
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Lq
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s;
PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE ON BEHALF OF THE CERTIFICATE
HOLDERS OF MORGAN STANLEY ABS CAPITAL I
INC. TRUST 2004-HE9, MORTGAGE PASS
THROUGH CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
TERESA TROUT
BART A. TROUT
Mortgagor(s) and Record Owner(s)
508 Herman Avenue
Lemoyne, PA 17043
Defendant(s)
No. 06-6670
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
Interest from 01/05/07
to Date of Sale at
7.9900%
$107,483.09
(Costs to be added)
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All that certain tract or parcel of land and premises, situate, lying and being in the Borough of Lemoyne,
in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as
follows, being Lot No. 64 and the western one-half of Lot No. 65, section "D", on the Plan of Riverton,
said plan being recorded in the Cumberland County Recorder's Office in Deed Book "C", Volume 11,
page 589, more particularly bounded and described as follows:
Beginning at a point on the southern line of Herman Avenue, said point located 57.5 feet measured
westwardly along the southern line of Herman Avenue from the southwest corner of Herman Avenue
and Fifth Street; thence in a southerly direction through the center of the partition wall of a double two
and one-half story frame dwelling house, a distance of 150 feet to Plum Alley; thence along the northern
side of Plum Alley, a distance of 52.5 feet to a point on the dividing line between Lot Nos. 63 and 64 on
said plan; thence along said dividing line in a northerly direction, a distance of 150 feet to a point on the
southern side of Herman Avenue; thence in an easterly direction along the southern side of Herman
Avenue, a distance of 52.5 feet to a point, the place of beginning.
Having thereon erected the western one-half of a double two and one-half story frame dwelling house
known as 508 Herman Avenue, Lemoyne, Pennsylvania.
TAX PARCEL NO: 12-22-0822
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-6670 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN STANLEY ABS
CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH CERTIFICATES, SERIES
2004 HE9, Plaintiff (s)
From TERESA TROUT AND BART A. TROUT
(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 $107,483.09
L.L. $.50
Interest FROM 1/5/07 TO DATE OF SALE AT 7.9900%
Atty's Comm % Due Prothy $1.00
Atty Paid $140.08
Plaintiff Paid
Date: JANUARY 10, 2007
(Seal)
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK, JR., ESQUIRE
Address: GOLDBECK MCCAFFERTY & MCKEEVER
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Other Costs
-F-y
Supreme Court ID No. 16132
Goldbeck McCafferty & McKeever
BY: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF THE
CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-HE9,
MORTGAGE PASS THROUGH CERTIFICATES,
SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
vs.
TERESA TROUT
BART A. TROUT
(Mortgagor(s) and Record Owner(s))
508 Herman Avenue
Lemoyne, PA 17043
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
No. 06-6670
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE ON BEHALF OF THE CERTIFICATE
HOLDERS OF MORGAN STANLEY ABS CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets
forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property
located at:
508 Herman Avenue
Lemoyne, PA 17043
1.Name and address of Owner(s) or Reputed Owner(s):
TERESA TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
BART A. TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
2. Name and address of Defendant(s) in the judgment:
TERESA TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
BART A. TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
-r,
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS
8201 GREENSBORO DRIVE
SUITE 350
MCLEAN, VA 22102
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
4. Name and address of the last recorded holder of every mortgage of record:
PENNSYLVANIA HOUSING FINANCE AGENCY
211 North Front Street
PO BOX 15057
Harrisburg, PA 17101
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
508 Herman Avenue
Lemoyne, PA 17043
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the b t of my Personal knowledge or
information and belief. I understand that false statements herein are made subject to a penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
DATED: January 4, 2007
GOLDBECK McCAFF & KEEVER
BY: Joseph A. Goldb J ., Esq.
Attorney for Plaintif
t?
Y
C
_
06-6670
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6318
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF THE
CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-
HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
vs.
TERESA TROUT
BART A. TROUT
Mortgagor(s) and Record Owner(s)
508 Herman Avenue
Lemoyne, PA 17043
Defendant(s;
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Term
No. 06-6670
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: TROUT, BART A.
BART A. TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
Your house at 508 Herman Avenue, Lemoyne, PA 17043 is scheduled to be sold at Sheriffs Sale
on Wednesday, June 13, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce
the court judgment of $107,483.09 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN STANLEY ABS
CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2004
HE9 against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
06-6670
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN STANLEY ABS
CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2004
HE9, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you
must pay call our office at 215-825-6329 or 1-866-413-2311 and
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
i
06-6670
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: 717-243-9400 or.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud. ov for Help for Homeowners Facing the
Loss of Their Homes.
4). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
5). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at homeretention&goldbecklaw com.
Call Judy at 215-825-6329 or fax 215-825-6429. The figure and/or package you
requested will be mailed to the address that you request or faxed if you leave a message
with that information. The attorney in charge of our firm's Homeowner Retention
Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418.
Please reference our Attorney File Number of CWD-6627.
Para informacion en espanol puede communicarse con Loretta a1215-825-6344.
-. ". 1Cii
co
?J
06-6670
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6318
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF THE
CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-
HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
vs.
TERESA TROUT
BART A. TROUT
Mortgagor(s) and Record Owner(s)
508 Herman Avenue
Lemoyne, PA 17043
Defendant(s,
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Term
No. 06-6670
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: TROUT, TERESA
TERESA TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
Your house at 508 Herman Avenue, Lemoyne, PA 17043 is scheduled to be sold at Sheriffs Sale
on Wednesday, June 13, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce
the court judgment of $107,483.09 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN STANLEY ABS
CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2004
HE9 against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
06-6670
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN STANLEY ABS
CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2004
HE9, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you
must pay call our office at 215-825-6329 or 1-866-413-2311 and
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings
You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
06-6670
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: 717-243-9400 or.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
5). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at homeretention(a,goldbecklaw.com.
Call Judy at 215-825-6329 or fax 215-825-6429. The figure and/or package you
requested will be mailed to the address that you request or faxed if you leave a message
with that information. The attorney in charge of our firm's Homeowner Retention
Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418.
Please reference our Attorney File Number of CWD-6627.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
?
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GOLDBECK McCAFFERTY & McKEEVER
BN': Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE ON BEHALF OF THE CERTIFICATE
HOLDERS OF MORGAN STANLEY ABS CAPITAL I
INC. TRUST 2004-HE9, MORTGAGE PASS
THROUGH CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
vs.
TERESA TROUT
BART A. TROUT
Mortgagor(s) and
Record Owner(s)
508 Herman Avenue
Lemoyne, PA 17043
Defendant(s)
CWT-6627
CF: 11/20/2006
SD: 06/13/2007
$107,483.09
IN THE COURT OF COMMON PLEAS
of Cumberland
CIVIL ACTION - LAW
ACTION OF MORTGAG FORECLOSURE
No.
Term
CERTIFICATE OF SERVICE
PURSUANT TO Pa.R.C.P. 3129.2 (c) (2)
Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that s
Defendants of the Notice of Sheriff Sale was made by:
X) Personal Service by the Sheriffs Office/cam t-1 aadals (copy of return al
( ) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return rec
( ) Certified mail by Sheriffs Office.
( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defend
(proof of mailing attached).
( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of
attached).
( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record.
IF SERVICE WAS ACCOMPLISHED BY COURT ORDER.
( ) Premises was posted by Sheriffs Office/competent adult (copy of return a
( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attacheC
( } Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original recei?
Mail attached).
ce on the
ied).
attached).
s) of record
nowledgment
) for Certified
Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders ( f any) has been
made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of maili attached).
The undersigned understands that the statements herein are subjen the penalties pr vided by 18 P.S.
Section 4904.
Deutsche Bank National Trust Company, as
Trustee on behalf of the Certifacate Holders of
Morgan Stanley ABS Capital 1 Inc. Trust 2004-
HE9 Mortgage Pass Through Certificates, Series
2004 HE9
VS
Teresa Trout and Bart A. Trout
In The Court of Common P eas of
Cumberland County, Penns lvania
Writ No. 2006-6670 Civil erm
Mark Conklin, Deputy Sheriff, who being duly sworn according to law,
February 9, 2007 at 1250 hours, he served a true copy of the within Real Estate
Description, in the above entitled action, upon the within named defendants to i
Bart A. Trout, by making known unto Teresa Trout personally and as wife of B
Herman Ave, Lemoyne, Cumberland County, Pennsylvania its contents and at t
handing to her personally the said true and correct copy of the same.
Jason Vioral, Deputy Sheriff, who being duly sworn according to Iaw, s
12, 2007 at 0925 hours, he posted a true copy of the within Real Estate Writ, N
Description, in the above entitled action, upon the property of Teresa Trout an
508 Herman Avenue, Lemoyne, Cumberland County, Pennsylvania according l
R. Thomas Kline, Sheriff, who being duly sworn according to law, state
above Real Estate Writ, Notice, Poster and Description in the following manne
mailed a notice of the pendency of the action to the within named defendants, t
and Bart A. Trout, by regular mail to their last known address of 508 Herman
PA 17043. These letters were mailed under the date of April 3, 2007 and never
Sheriffs Office.
So his er
R. Thomas Kline, Sheriff
tes that on
rit, Notice and
Teresa Trout and
A. Trout, at 508
same time
tes that on April
tice, Poster and
Bart A. Trout, at
law.
he served the
The Sheriff
wit: Teresa Trout
venue, Lemoyne,
returned to the
B*:.A a
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attomey I.D.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6320
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF THE
CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-
HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
vs.
TERESA TROUT
BART A. TROUT
Mortgagor(s) and Record Owner(s)
508 Herman Avenue
Lemoyne, PA 17043
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
No.
Term
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE ON BEHALF OF'
HOLDERS OF MORGAN STANLEY ABS CAPITAL I INC. TRUST 2004-HE9, MORTGAGE P,
CERTIFICATES, SERIES 2004 HE9, Plaintiff in the above action, by its attorney, Joseph A. Goldb
forth as of the date the praecipe for the writ of execution was filed the following information concern
located at:
508 Herman Avenue
Lemoyne, PA 17043
1.Name and address of Owner(s) or Reputed Owner(s):
TERESA TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
BART A. TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
IN THE COURT OF CO MON PLEAS
of Cumberland ounty
CIVIL ACTIO - LAW
ACTION OF MOR
FORECLOSURE
[E CERTIFICATE
S THROUGH
V, Jr., Esquire, sets
g the real property
2. Name and address of Defendant(s) in the judgment:
TERESA TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
BART A. TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
3. Name and last known address of every judgment creditor whose judgment is a record lien on the pr, perty to be sold:
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS
8201 GREENSBORO DRIVE
SUITE 350
MCLEAN, VA 22102
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support nforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
4. Name and address of the last recorded holder of every mortgage of record:
PENNSYLVANIA HOUSING FINANCE AGENCY
211 North Front Street
PO BOX 15057
Harrisburg, PA 17101
5. Name and address of every other person who has any record interest in or record lien on the props -ty and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record! interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any
may be affected by the sale.
TENANTS/OCCUPANTS
508 Herman Avenue
Lemoyne, PA 17043
(attach separate sheet if more space is needed)
in the property which
I verify that the statements made in this affidavit are true and correct to the best of my pers nal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties ol? 18 Pa. C. S. Section 4904
relating to unworn falsification to authorities.
DATED: May 16, 2007
ABECK cCC ,FFERTY & r
oseph A. Goldbeck, Jr., Esq.
iev for Plaintiff
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Deutsche Bank National Trust Company, as In The Court of Common Pleas of
Trustee on behalf of the Certifacate Holders of Cumberland County, Pennsylvania
Morgan Stanley ABS Capital 1 Inc. Trust 2004- Writ No. 2006-6670 Civil Term
HE9 Mortgage Pass Through Certificates, Series
2004 HE9
VS
Teresa Trout and Bart A. Trout
Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on
February 9, 2007 at 1250 hours, he served a true copy of the within Real Estate Writ, Notice and
Description, in the above entitled action, upon the within named defendants to wit: Teresa Trout and
Bart A. Trout, by making known unto Teresa Trout personally and as wife of Bart A. Trout, at 508
Herman Ave, Lemoyne, Cumberland County, Pennsylvania its contents and at the same time
handing to her personally the said true and correct copy of the same.
Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on April
12, 2007 at 0925 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 Teresa Trout and Bart A. Trout, at
508 Herman Avenue, Lemoyne, 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: Teresa Trout
and Bart A. Trout, by regular mail to their last known address of 508 Herman Avenue, Lemoyne,
PA 17043. These letters were mailed under the date of April 3, 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 Joseph Goldbeck.
Sheriffs Costs:
Docketing 30.00
Poundage 17.77
Advertising 15.00
Posting Handbills 15.00
Mileage 30.72
Law Library .50
Prothonotary 1.00
Levy 15.00
Surcharge 30.00
Law Journal 355.00
Patriot News 339.92
Share of Bills 16.17
Postpone Sale 40.00
$906.08 ? ?., R ??g?o7
So Answ rs:
R. Thomas Kline, Sheriff
BY -j6dM&nqd1,-,, i) 5?D Real Estate ergeant 4 a5 r, L
Goldbeck McCafferty & McKeever
BY: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF THE
CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-HE9,
MORTGAGE PASS THROUGH CERTIFICATES,
SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
VS.
TERESA TROUT
BART A. TROUT
(Mortgagor(s) and Record Owner(s))
508 Herman Avenue
Lemoyne, PA 17043
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
No. 06-6670
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE ON BEHALF OF THE CERTIFICATE
HOLDERS OF MORGAN STANLEY ABS CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets
forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property
located at:
508 Herman Avenue
Lemoyne, PA 17043
1.Name and address of Owner(s) or Reputed Owner(s):
TERESA TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
BART A. TROUT
508 Heenan Avenue
Lemoyne, PA 17043-1822
2. Name and address of Defendant(s) in the judgment:
TERESA TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
BART A. TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
t?
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS
8201 GREENSBORO DRIVE
SUITE 350
MCLEAN, VA 22102
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
4. Name and address of the last recorded holder of every mortgage of record:
PENNSYLVANIA HOUSING FINANCE AGENCY
211 North Front Street
PO BOX 15057
Harrisburg, PA 17101
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
508 Herman Avenue
Lemoyne, PA 17043
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the b t of my ?ersonal knowledge or
information and belief. I understand that false statements herein are made subject to e penalti s of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities. I
i
DATED: January 4, 2007
GOLDBECK MCCAFF & KEEVER
BY: Joseph A. Goldb , J ., Esq.
Attorney for Plainti
f
06-6670
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6318
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF THE
CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-
HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
VS.
TERESA TROUT
BART A. TROUT
Mortgagor(s) and Record Owner(s)
508 Herman Avenue
Lemoyne, PA 17043
Defendant(
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Term
No. 06-6670
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: TROUT, BART A.
BART A. TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
Your house at 508 Herman Avenue, Lemoyne, PA 17043 is scheduled to be sold at Sheriffs Sale
on Wednesday, June 13, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce
the court judgment of $107,483.09 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN STANLEY ABS
CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2004
HE9 against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
f
06-6670
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN STANLEY ABS
CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2004
HE9, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you
must pay call our office at 215-825-6329 or 1-866-413-2311 and
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
06-6670
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: 717-243-9400 or.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
5). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at homeretention(a,g?oldbecklaw.com.
Call Judy at 215-825-6329 or fax 215-825-6429. The figure and/or package you
requested will be mailed to the address that you request or faxed if you leave a message
with that information. The attorney in charge of our firm's Homeowner Retention
Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418.
Please reference our Attorney File Number of CWD-6627.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
06-6670
S
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6318
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF THE
CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-
HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
VS.
TERESA TROUT
BART A. TROUT
Mortgagor(s) and Record Owner(s)
508 Herman Avenue
Lemoyne, PA 17043
Defendants
Term
No. 06-6670
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: TROUT, TERESA
TERESA TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
Your house at 508 Herman Avenue, Lemoyne, PA 17043 is scheduled to be sold at Sheriffs Sale
on Wednesday, June 13, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce
the court judgment of $107,483.09 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN STANLEY ABS
CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2004
HE9 against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
r
z <
06-6670
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN STANLEY ABS
CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2004
HE9, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you
must pay call our office at 215-825-6329 or 1-866-413-2311 and
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
r
06-6670
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: 717-243-9400 or.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
5). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at homeretention@jzoldbecklaw.com.
Call Judy at 215-825-6329 or fax 215-825-6429. The figure and/or package you
requested will be mailed to the address that you request or faxed if you leave a message
with that information. The attorney in charge of our firm's Homeowner Retention
Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418.
Please reference our Attorney File Number of CWD-6627.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
All that certain tract or parcel of land and premises, situate, lying and being in the Borough of Lemoyne,
in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as
follows, being Lot No. 64 and the western one-half of Lot No. 65, section "D", on the Plan of Riverton,
said plan being recorded in the Cumberland County Recorder's Office in Deed Book "C", Volume 11,
page 589, more particularly bounded and described as follows:
Beginning at a point on the southern line of Herman Avenue, said point located 57.5 feet measured
westwardly along the southern line of Herman Avenue from the southwest corner of Herman Avenue
and Fifth Street; thence in a southerly direction through the center of the partition wall of a double two
and one-half story frame dwelling house, a distance of 150 feet to Plum Alley; thence along the northern
side of Plum Alley, a distance of 52.5 feet to a point on the dividing line between Lot Nos. 63 and 64 on
said plan; thence along said dividing line in a northerly direction, a distance of 150 feet to a point on the
southern side of Herman Avenue; thence in an easterly direction along the southern side of Herman
Avenue, a distance of 52.5 feet to a point, the place of beginning.
Having thereon erected the western one-half of a double two and one-half story frame dwelling house
known as 508 Herman Avenue, Lemoyne, Pennsylvania.
TAX PARCEL NO: 12-22-0822
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 06-6670 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN STANLEY ABS
CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH CERTIFICATES, SERIES
2004 HE9, Plaintiff (s)
From TERESA TROUT AND BART A. TROUT
(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 $107,483.09 L.L. $.50
Interest FROM 1/5/07 TO DATE OF SALE AT 7.9900%
Atty's Comm % Due Prothy $1.00
Atty Paid $140.08 Other Costs
Plaintiff Paid
Date: JANUARY 10, 2007
(Seal)
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK, JR., ESQUIRE
Address: GOLDBECK MCCAFFERTY & MCKEEVER
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ID No. 16132
vc+?
O
Real Estate Sale # 19
On February 6, 2007 the Sheriff levied upon the
defendant's interest in the real property situated in
Lemoyne Borough, Cumberland County, PA
Known and numbered as 508 Herman Avenue,
Lemoyne, more fully described on Exhibit "A"
filed with this writ and by this reference
incorporated herein.
Date: February 6, 2007 By: _
JG d?
Real Esta Sergeant
0S i? s !' l?jl
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#19
.. ........... ........................... a? .....
Sworn to and
iq ota i; ;I Scai
Terry L. tiussd!, Nucary +?ubk.
City Cif Harrisi7urg, Ua.uphin County
?IMyCommissiontxpifc-June 6,2010 j
lembg Penns v . f : q--( r ar on or Notaries
Y PUBLIC
A.D.
CUMBERLAND COUNTY SHERIFF'S OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
Ail that oa'ttia tract or of bmd and
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TAX PARM-N0:12-22r=
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.
f
Coyne,
SWORN TO AND SUBSCRIBED before me this
4 day of May, 2007
."-SEAL I/
LOS F " IDE e, kktary Public
REAL ESTATE SALE NO. 19
Writ No. 2006-6670 Civil
Deutsche Bank National Trust
Company, as Trustee on Behalf of
the Certificate Holders of Morgan
Stanley ABS Capital I Inc.
Trust 2004-HE9 Mortgage Pass
Through Certificates,
Series 2004 HE9
vs.
Teresa Trout and Bart A. Trout
Atty.: Joseph A. Goldbeck, Jr.
All that certain tract or parcel of
land and premises, situate, lying and
being in the Borough of Lemoyne,
in the County of Cumberland and
Commonwealth of Pennsylvania,
more particularly described as fol-
lows, being Lot No. 64 and the west-
ern one-half of Lot No. 65, section
"D", on the Plan of Riverton, said
plan being recorded in the Cumber-
land County Recorder's Office in
Deed Book "C", Volume 11, page
589, more particularly bounded and
described as follows:
Beginning at a point on the south-
ern line of Herman Avenue, said
point located 57.5 feet measured
westwardly along the southern line
of Herman Avenue from the south-
west comer of Herman Avenue and
Fifth Street; thence in a southerly
direction through the center of the
partition wall of a double two and
one-half story frame dwelling house.
a distance of 150 feet to Plum Al-
ley; thence along the northern side
of Plum Alley, a distance of 52.5
feet to a point on the dividing line
between Lot Nos. 63 and 64 on said
plan; thence along said dividing line
in a northerly direction, a distance
of 150 feet to a point on the south-
ern side of Herman Avenue; thence
in an easterly direction along the
southern side of Herman Avenue, a
distance of 52.5 feet to a point, the
place of beginning.
Having thereon erected the west-
ern one-half of a double two and
one-half story frame dwelling house
known as 508 Herman Avenue.
Lemoyne, Pennsylvania.
TAX PARCEL NO: 12-22-0822.
GOLDBECK McCAFFERTY &
McKEEVER
BY: MICHAEL T. MCKEEVER
ATTORNEY I.D. #56129
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106-1532
(215) 627-1322
ATTORNEY FOR PLAINTIFF
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Term
No. 06-6670
By:
GOLDBECK McCAFFERTY & McKEEVER
MICHAEL T. MCKEEVER, ESQUIRE
ATTORNEY FOR PLAINTIFF
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF THE
CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-HE9,
MORTGAGE PASS THROUGH CERTIFICATES,
SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
VS.
TERESA TROUT
BART A. TROUT
508 Herman Avenue
Lemoyne, PA 17043
Defendant(s)
PRAECIPE TO REINSTATE COMPLAINT
Kindly reinstate the Complaint in the above captioned matter.
-T L
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Cn
t'i'ff
.r .,.
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney I.D. #56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE ON BEHALF OF THE CERTIFICATE
HOLDERS OF MORGAN STANLEY ABS CAPITAL I
INC. TRUST 2004-HE9, MORTGAGE PASS
THROUGH CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
VS.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
No. 06-6670
TERESA TROUT
BART A. TROUT
508 Herman Avenue
Lemoyne, PA 17043
Defendants
PRAECIPE TO VACATE JUDGMENT
TO THE PROTHONOTARY:
Kindly vacate the judgment upon payment of your costs only.
A5*ev?t?
MICHA T. MCKEEVER, ESQUIRE
0
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a
4 _ ?x
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I"?
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-06670 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
TROUT TERESA ET AL
TIMOTHY REITZ
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
TROUT TERESA
DEFENDANT
the
at 1320:00 HOURS, on the 9th day of May , 2008
at 508 HERMAN AVENUE
LEMOYNE, PA 17043
BART A TROUT
was served upon
by handing to
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 16.00
Affidavit .00
Surcharge 10.00
.00
4 4. 0 0
Sworn and Subscibed to
before me this day
of ,
So Answers:
R. Thomas Kline
05/12/2008
GOLDBECK MCCAFFERTY MCKEEVER
By : ? -9/ zt??
Denoity Sheri
A.D. /
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-06670 P Amended
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
TROUT TERESA ET AL
TIMOTHY REITZ , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
TROUT BART A the
DEFENDANT , at 1320:00 HOURS, on the 9th day of May 2008
at 508 HERMAN AVENUE
LEMOYNE, PA 17043
BART A TROUT
by handing to
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing His attention to the contents thereof.
Amended
Sheriff's Costs:
Docketing 18.00
Service 16.00
Affidavit .00
Surcharge 10.00
.00
5?l??OSr 44.00
Sworn and Subscibed to
before me this
of
So Answers
_f! o
R. Thomas Kline
05/16/2008
GOLDBECK MCCAFFERTY MCKEEVE
By:
day
A. D.
Duty Sheri
In the Court of Common Pleas of Cumberland County
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS
OF MORGAN STANLEY ABS CAPITAL I INC. TRUST 2004-
HE9, MORTGAGE PASS THROUGH CERTIFICATES,
SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
VS.
TERESA TROUT
BART A. TROUT
(Mortgagor(s) and Record Owner(s))
508 Herman Avenue
Lemoyne, PA 17043
Defendant(s)
PRAECIPE FOR JUDGMENT
No. 06-6670
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE
OF COLLECTING THE DEBT.
Enter the Judgment in favor of Plaintiff and against TERESA TROUT and BART A. TROUT by default for want of
an Answer.
Assess damages as follows:
Debt
Interest from 06/21/2008 to
Date of Sale per diem at $20.91
Total
(Assessment of Damages attached)
$120,429.74
I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO
BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT.
I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment
is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the
filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1
Michael T. McKeever
Attorney for Plaintiff
I.D. #56129
AND NOW I.It1]E (15rd OWOR , Judgment is entered in favor of
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS
OF MORGAN STANLEY ABS CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH CERTIFICATES,
SERIES 2004 HE9 and against TERESA TROUT and BART A. TROUT by default for want of an Answer and damages
assessed in the sum of $120,429.74 as per the above certification.
Pr onotary
VERIFICATION OF NON-MILITARY SERVICE
The undersigned, as the representative for the Plaintiff corporation within named do
hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation
and that the facts set forth in the foregoing verification of Non-Military Service are true and
correct to the best of my knowledge, information and belief. I understand that false statements
therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to
authorities.
1. That the above named Defendant, TERESA TROUT, is about unknown years of
age, that Defendant's last known residence is 508 Herman Avenue Lemoyne, PA 17043-1822, and
is engaged in the unknown business located at unknown address.
2. That Defendant is not in the Military or Naval Service of the United States or its
Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of
Congress of 1940 and its Amendments.
Date: Clxlo?
0
VERIFICATION OF NON-MILITARY SERVICE
The undersigned, as the representative for the Plaintiff corporation within named do
hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation
and that the facts set forth in the foregoing verification of Non-Military Service are true and
correct to the best of my knowledge, information and belief. I understand that false statements
therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to
authorities.
1. That the above named Defendant, BART A. TROUT, is about unknown years of
age, that Defendant's last known residence is 508 Herman Avenue Lemoyne, PA 17043-1822, and
is engaged in the unknown business located at unknown address.
2. That Defendant is not in the Military or Naval Service of the United States or its
Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of
Congress of 1940 and its Amendments.
Date: 4/691/ U 7?_
CWD-6627
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED
FOR THE PURPOSE OF COLLECTING THE DEBT.
DATE OF THIS NOTICE: May 30, 2008
TO:
TERESA TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF
MORGAN STANLEY ABS CAPITAL I INC. TRUST 2004-HE9,
MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2004
HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
vs.
TERESA TROUT
BART A. TROUT
(Mortgagor(s) and Record Owner(s))
508 Herman Avenue
Lemoyne, PA 17043
TO: TERESA TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
Plaintiff
Defendant(s)
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Action of
Mortgage Foreclosure
Term
No. 06-6670
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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
Michael T. McKeever
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever, Esq.
Attorney for Plaintiff
Suite 5000 - 701 Market Street.
Philadelphia, PA 19106 215-825-6318
CWD-6627
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED
FOR THE PURPOSE OF COLLECTING THE DEBT.
DATE OF THIS NOTICE: May 30, 2008
TO:
BART A. TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF
MORGAN STANLEY ABS CAPITAL I INC. TRUST 2004-HE9,
MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2004
HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
vs.
TERESA TROUT
BART A. TROUT
(Mortgagor(s) and Record Owner(s))
508 Herman Avenue
Lemoyne, PA 17043
Plaintiff
Defendant(s)
TO: BART A. TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
IMPORTANT NOTICE
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Action of
Mortgage Foreclosure
Term
No. 06-6670
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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
Michael T. McKeever
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever, Esq.
Attorney for Plaintiff
Suite 5000 - 701 Market Street.
Philadelphia, PA 19106 215-825-6318
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney I.D. #56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE ON BEHALF OF THE CERTIFICATE
HOLDERS OF MORGAN STANLEY ABS CAPITAL I
INC. TRUST 2004-HE9, MORTGAGE PASS
THROUGH CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
vs.
TERESA TROUT
BART A. TROUT
(Mortgagor(s) and Record owner(s))
508 Herman Avenue
Lemoyne, PA 17043
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION LAW
ACTION OF MORTGAGE FORECLOSURE
No. 06-6670
ORDER FOR JUDGMENT
Please enter Judgment in favor of DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN STANLEY ABS CAPITAL I
INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2004 HE9, and against
TERESA TROUT and BART A. TROUT for failure to file an Answer in the above action within (20) days (or
sixty (60) days if defendant is the United States of America) from the date of service of the Complaint, in the sum
of $120,429.74.
Michael T. McKeever
Attorney for Plaintiff
I hereby certify that the above names are correct and that the precise residence address of the judgment
creditor is DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE ON BEHALF OF THE
CERTIFICATE HOLDERS OF MORGAN STANLEY ABS CAPITAL I INC. TRUST 2004-HE9, MORTGAGE
PASS THROUGH CERTIFICATES, SERIES 2004 HE9 7105 Corporate Drive PTX C-35 Plano, TX 75024 and
that the name(s) and last known address(es) of the Defendant(s) is/are TERESA TROUT, 508 Herman Avenue
Lemoyne, PA 17043-1822 and BART A. TROUT, 508 Herman Avenue Lemoyne, PA 17043-1822;
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney for Plaintiff
ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly assess the damages in this case to be as follows:
Principal Balance $95,535.17
Interest from 05/01/2006 through $16,351.62
06/20/2008
Reasonable Attorney's Fee $4,776.76
Late Charges $1,066.49
Costs of Suit and Title Search $900.00
Escrow Payments Due 5 X $257.10 $1,285.50
Escrow $514.20
$120,429.74
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney for Plaintiff
AND NOW, this 0Zrd day of ?Vnp , 2008 damages are assessed as above.
Pro rothy
00
cr,
Rule of Civil Procedure No. 236 - Revised
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS
OF MORGAN STANLEY ABS CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH CERTIFICATES,
SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
No. 06-6670
vs.
TERESA TROUT
BART A. TROUT
(Mortgagors and Record Owner(s))
508 Herman Avenue
Lemoyne, PA 17043
Defendant(s)
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE
PURPOSE OF COLLECTING THE DEBT.
NOTICE
Notice is given that a judgment in the above-captione ter h e ed against you.
urt Long
Protho ry
By:
Deputy
If you have any questions concerning the above, please contact:
Michael T. McKeever
Goldbeck McCafferty & McKeever
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-6670 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY,
as Trustee on behalf of THE CERTIFICATE HOLDERS OF MORGAN STANLEY ABS CAPITAL
I INC., TRUST 2004-HE9, MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2004 HE9
Plaintiff (s)
From TERESA TROUT and BART A. TROUT
(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 gamishee(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 $120,429.74
L.L.
Interest from 6/21/08 to Date of Sale per diem at $20.91
Atty's Comm % Due Prothy $2.00
Atty Paid $1,187. to(* Other Costs
Plaintiff Paid
Date: 6/23/08
Prothonotary
(Seal) By:
REQUESTING PARTY:
Name: MICHAEL T. MCKEEVER, ESQUIRE
Address: GOLDBECK MCCAFFERTY & MCKEEVER
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Deputy
Supreme Court ID No. 56129
PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
Michael T. McKeever
Attorney I.D.#56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE ON BEHALF OF THE CERTIFICATE
HOLDERS OF MORGAN STANLEY ABS CAPITAL I
INC. TRUST 2004-HE9, MORTGAGE PASS
THROUGH CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
vs.
TERESA TROUT
BART A. TROUT
Mortgagor(s) and Record Owner(s)
508 Herman Avenue
Lemoyne, PA 17043
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 06-6670
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
Interest from
06/21/2008 to Date of
Sale per diem at
$20.91
$120,429.74
(Costs to be added)
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney for Plaintiff
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Goldbeck McCafferty & McKeever
BY: Michael T. McKeever
Attorney I.D. #56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF THE
CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-HE9,
MORTGAGE PASS THROUGH CERTIFICATES,
SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
vs.
TERESA TROUT
BART A. TROUT
(Mortgagor(s) and Record Owner(s))
508 Herman Avenue
Lemoyne, PA 17043
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
No. 06-6670
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE ON BEHALF OF THE CERTIFICATE
HOLDERS OF MORGAN STANLEY ABS CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9, Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth
as of the date the praecipe for the writ of execution was filed the following information concerning the real property located
at:
508 Herman Avenue
Lemoyne, PA 17043
1.Name and address of Owner(s) or Reputed Owner(s):
TERESA TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
BART A. TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
2. Name and address of Defendant(s) in the judgment:
TERESA TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
BART A. TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS
8201 GREENSBORO DRIVE
SUITE 350
MCLEAN, VA 22102
4. Name and address of the last recorded holder of every mortgage of record:
PENNSYLVANIA HOUSING FINANCE AGENCY
211 North Front Street
PO BOX 15057
Harrisburg, PA 17101
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
508 Herman Avenue
Lemoyne, PA 17043
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
DATED: June 20. 2008
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever, Esq.
Attorney for Plaintiff
.J
44
06-6670
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney I.D.#56129
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6318
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF THE
CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-
HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
VS.
TERESA TROUT
BART A. TROUT
Mortgagor(s) and Record Owner(s)
508 Herman Avenue
Lemoyne, PA 17043
Defendants;
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Term
No. 06-6670
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: TROUT, TERESA
TERESA TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
Your house at 508 Herman Avenue, Lemoyne, PA 17043 is scheduled to be sold at Sheriffs Sale
on Wednesday, December 10, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to
enforce the court judgment of $120,429.74 obtained by DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9 against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
4
W
YI
06-6670
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN STANLEY ABS
CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2004
HE9, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you
must pay call our office at 215-825-6329 or 1-866413-2311.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
06-6670
2 Liberty Avenue
Carlisle, PA 17013
r
06-6670
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: 717-243-9400 or.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website
http://www.phfa.org/consumers/homeowners/real.aspx.
5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at homeretention@yoldbecklaw.com.
Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you
requested will be mailed to the address that you request or faxed if you leave a message
with that information. The attorney in charge of our firm's Homeowner Retention
Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418.
Please reference our Attorney File Number of CWD-6627.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
01
06-6670
GOLDBECK McCAFFERTY & MCKEEVER
BY: Michael T. McKeever
Attorney I.D.#56129
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6318
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF THE
CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-
HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
VS.
TERESA TROUT
BART A. TROUT
Mortgagor(s) and Record Owner(s)
508 Herman Avenue
Lemoyne, PA 17043
Defendant(s'
Term
No. 06-6670
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: TROUT, BART A.
BART A. TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
Your house at 508 Herman Avenue, Lemoyne, PA 17043 is scheduled to be sold at Sheriffs Sale
on Wednesday, December 10, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to
enforce the court judgment of $120,429.74 obtained by DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9 against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
06-6670
To prevent this Sheriffs Sale you must take immediate action:
I . The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN STANLEY ABS
CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2004
HE9, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you
must pay call our office at 215-825-6329 or 1-866-413-2311.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
06-6670
2 Liberty Avenue
Carlisle, PA 17013
06-6670
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: 717-243-9400 or.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website
hqp://www.phfa.orp-/consumers/homeowners/real.aspx.
5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at homeretention&goldbecklaw.com.
Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you
requested will be mailed to the address that you request or faxed if you leave a message
with that information. The attorney in charge of our firm's Homeowner Retention
Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418.
Please reference our Attorney File Number of CWD-6627.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
Michael T. McKeever
Attorney I.D. #56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS
OF MORGAN STANLEY ABS CAPITAL I INC. TRUST
2004-HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
vs.
TERESA TROUT
BART A. TROUT
Mortgagor(s) and Record Owner(s)
508 Herman Avenue
Lemoyne, PA 17043
Defendant(s)
CERTIFICATION AS TO THE SALE OF REAL PROPERTY
NO. 06-6670
I, Michael T. McKeever, Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and
I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the
Act.
Michael T. McKeever
Attorney for plaintiff
IN THE COURT OF
COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF
MORTGAGE FORECLOSURE
Deutsche Bank National Trust Company
VS
Teresa Trout and Bart A. Trout
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2006-6670 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED per letter of request from Attorney Michael McKeever.
Sheriff s Costs:
Docketing
Poundage
Advertising
Posting Handbills
Prothonotary
Levy
Mileage
Surcharge
Share of Bills
So Answers:
R. Thomas Kline, Sheriff
t
BY
Real Estate S geant
30.00
3.08
15.00
15.00
2.00
15.00
32.00
30.00
14.92 nn
$157.00
a = w
Ck
?, dlc.4 94
t ,*4 '
Goldbeck McCafferty & McKeever
BY: Michael T. McKeever
Attorney I.D. #56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF THE
CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-HE9,
MORTGAGE PASS THROUGH CERTIFICATES,
SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
VS.
TERESA TROUT
BART A. TROUT
(Mortgagor(s) and Record Owner(s))
508 Herman Avenue
Lemoyne, PA 17043
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 06-6670
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE ON BEHALF OF THE CERTIFICATE
HOLDERS OF MORGAN STANLEY ABS CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9, Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth
as of the date the praecipe for the writ of execution was filed the following information concerning the real property located
at:
508 Herman Avenue
Lemoyne, PA 17043
1.Name and address of Owner(s) or Reputed Owner(s):
TERESA TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
BART A. TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
2. Name and address of Defendant(s) in the judgment:
TERESA TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
BART A. TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS
8201 GREENSBORO DRIVE
SUITE 350
MCLEAN, VA 22102
4. Name and address of the last recorded holder of every mortgage of record:
PENNSYLVANIA HOUSING FINANCE AGENCY
211 North Front Street
PO BOX 15057
Harrisburg, PA 17101
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
508 Herman Avenue
Lemoyne, PA 17043
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unworn falsification to authorities.
DATED: June 20.2008
UOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever, Esq.
Attorney for Plaintiff
06-6670
GOLDBECK McCAFFERTY & MCKEEVER
BY: Michael T. McKeever
Attorney I.D.#56129
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6318
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF THE
CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-
HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
vs.
TERESA TROUT
BART A. TROUT
Mortgagor(s) and Record Owner(s)
508 Herman Avenue
Lemoyne, PA 17043
Defendant(s
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Term
No. 06-6670
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: TROUT, BART A.
BART A. TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
Your house at 508 Herman Avenue, Lemoyne, PA 17043 is scheduled to be sold at Sheriffs Sale
on Wednesday, December 10, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to
enforce the court judgment of $120,429.74 obtained by DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9 against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
06-6670
To prevent this Sheriffs Sale you must take immediate_action:
1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN STANLEY ABS
CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2004
HE9, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you
must pay call our office at 215-825-6329 or 1-866413-2311.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings
4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
06-6670
2 Liberty Avenue
Carlisle, PA 17013
06-6670
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: 717-243-9400 or.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website
httn://www nhfa org/consumers/homeowners/real asnx.
5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at homeretention(cr?aoldbecklaw com.
Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you
requested will be mailed to the address that you request or faxed if you leave a message
with that information. The attorney in charge of our firm's Homeowner Retention
Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418.
Please reference our Attorney File Number of CWD-6627.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
06-6670
GOLDBECK McCAFFERTy & McKEEVER
BY: Michael T. McKeever
Attorney I.D.#56129
Suite 5000- Mellon Independence Center
701 Market. Street
Philadelphia, PA 19106
215-825-6318
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF THE
CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-
HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
VS.
TERESA TROUT
BART A. TROUT
Mortgagor(s) and Record Owner(s)
Term
No. 06-6670
508 Herman Avenue
Lemoyne, PA 17043
Defendants
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
------------
TO: TROUT, TERESA
TERESA TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
Your house at 508 Herman Avenue, Lemoyne, PA 17043 is scheduled to be sold at Sheriffs Sale
on Wednesday, December 10, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to
enforce the court judgment of $120,429.74 obtained by DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9 against you.
NOTICE OF OWNS m RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
06-6670
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN STANLEY ABS
CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2004
HE9, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you
must pay call our office at 215-825-6329 or 1-866413-2311.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
EVEN IF THE SHERIFFS SALE DOES NOT TAKE PLACEll YUU HAVE OTHER RIGHTS
1 • If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
06-6670
2 Liberty Avenue
Carlisle, PA 17013
06-6670
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: 717-243-9400 or.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website wwa go-v for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website
httn //www.nhfa or /consumers/homeowners/rPat
5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at homeretention(c>)eoldbecklaw
Call Seth at 215-825-6329 or fax 215-825-6429. The figure will be mailed to the address that you request axand/or package
ed if you leaveya messa e
with that information. The attorney in charge of our firm's Homeowner Retention g
Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418.
Please reference our Attorney File Number of CWD-6627.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
All that certain tract or parcel of land and premises, situate, lying and being in the Borough of Lemoyne,
in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as
follows, being Lot No. 64 and the western one-half of Lot No. 65, section "D", on the Plan of Riverton,
said plan being recorded in the Cumberland County Recorder's Office in Deed Book "C", Volume 11,
page 589, more particularly bounded and described as follows:
Beginning at a point on the southern line of Herman Avenue, said point located 57.5 feet measured
westwardly along the southern line of Herman Avenue from the southwest corner of Herman Avenue
and Fifth Street; thence in a southerly direction through the center of the partition wall of a double two
and one-half story frame dwelling house, a distance of 150 feet to Plum Alley; thence along the northern
side of Plum Alley, a distance of 52.5 feet to a point on the dividing line between Lot Nos. 63 and 64 on
said plan; thence along said dividing line in a northerly direction, a distance of 150 feet to a point on the
southern side of Herman Avenue; thence in an easterly direction along the southern side of Herman
Avenue, a distance of 52.5 feet to a point, the place of beginning.
Having thereon erected the western one-half of a double two and one-half story frame dwelling house
known as 508 Herman Avenue, Lemoyne, Pennsylvania.
TAX PARCEL NO: 12-22-0822
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 06-6670 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY,
as Trustee on behalf of THE CERTIFICATE HOLDERS OF MORGAN STANLEY ABS CAPITAL
I INC., TRUST 2004-HE9, MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2004 HE9
Plaintiff (s)
From TERESA TROUT and BART A. TROUT
(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 gamishee(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 $120,429.74 L.L.
Interest from 6/21/08 to Date of Sale per diem at $20.91
Atty's Comm % Due Prothy $2.00
Atty Paid $1,187. lolp Other Costs
Plaintiff Paid
Date: 6/23/08 D
Prothonota
(Seal) By:
REQUESTING PARTY:
Name: MICHAEL T. MCKEEVER, ESQUIRE
Address: GOLDBECK MCCAFFERTY & MCKEEVER
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Deputy
c
Supreme Court ID No. 56129
Real Estate Sale #5 2-
On August 28, 2008 the Sheri=ff levied, upon the
defendant, s interest in the real property situated in
Borough of Lemoyne, Cumberland County, PA
Known and numbered as 508 Herman Ave., Lemoyne
more fully described on Exhibit "A"
filed with this writ and by this reference
incorporated herein.
Date: August 28, 2008 By:
-j
Real Esta Sergeant
_L.
'J
N y CT1
OS :8 V L Z OF 8001
JJI1 3 HS I.._ _ ;
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
IN RE:
BART A. TROUT
TERESA A. TROUT
j??-(ola70
Chapter 13
Case No.: 1-07-bk-01792 MDF
Debtor(s)
ORDER DISMISSING CASE
Upon consideration of Trustee's Certificate of Default on the Stipulation settli
motion to dismiss case for material default, and it having been determined that this
should be dismissed, it is
ORDERED that the case of the above-named debtor(s) be and it hereby i
dismissed and it is further
ORDERED that the trustee hereby is discharged from further responsibility in thi
case, and it is further
ORDERED that all pending adversary proceedings in this case be and they herE
are dismissed, and it is further
ORDERED that any outstanding fees are immediately due and payable to the U
Bankruptcy Court.
By the C'otul,
7??)o
Ban Judge (Ds)
This document is electronically signed and f=led on the same date.
Date: February 28, 2008
Case 1:07-bk-01792-MDF Doc 45 Filed 02/28/08 Entered 02/28/0808:
Main Document Page 1 of 1
=rn rW.
co
:7 "T.
MIN f
REV 6/05
5211
UNITED STATES BANKRUPTCY COURT
MIDDLE DISTRICT OF PENNSYLVANIA
Case No.1:08-bk-03751-RNO
Chapter 13
In re: Debtor(s) (name(s) used by the debtor(s) in the last 8 years, including married, maiden, and trade):
Bart A Trout Teresa M Trout Dlp _ tp&,70
dba All American Gutter
ORDER DISMISSING CASE UNDER 11 U.S.C. §521(i)(1)
It appearing the above-named debtor(s) has/have failed to file documents required pursuant to the
of 2005, it is hereby,
ORDERED that the case of the above-named debtor(s) be and is hereby dismissed. The trustee hereby is
discharged from further responsibility in this case, and it is further
ORDERED that all pending actions in this case are hereby dismissed.
-`.j ."a
rj
cD
C-`,
C_°
Dated: 12/1/08 BY THE COURT -{
6ZA v
United States Bankruptcy Judge
This document is electronically signed and filed on the same date,
N
.r;
? J
Cb
Ar
Act
CD
?T.
J°
f'>
Case 1:08-bk-03751-RNO Doc 8 Filed 12/01 /08 Entered 12/01/0808:48:29
Order Dismiss per 521 i Page 1 of 1
UNITED STATES BANKRUPTCY COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
In re: Bart A. Trout dba All American
Gutter
and Teresa M. Trout
Debtors
Deutsche Bank National Trust Company as
Trustee for Morgan Stanley ABS Capital 1
Inc. Trust 2004-HE9, Mortgage
Pass-Through Certificates, Series 2004-HE9,
or its Successor or Assignee
Movant
vs.
Bart A. Trout dba All American Gutter and
Teresa M. Trout
Lawrence G. Frank, Trustee
Respondents
ORDER
0&- (x(070
? A
C=
G'?
r CD
Xap
Upon consideration of the Motion for Relief from Stay, it is hereby ORDERED that the
automatic stay of Bankruptcy Code §362(a) be, and the same hereby is, MODIFIED to permit
Deutsche Bank National Trust Company as Trustee for Morgan Stanley ABS Capital 1 Inc. Tru
2004-HE9, Mortgage Pass-Through Certificates, Series 2004-HE9, or its Successor or Assignee
to foreclose its mortgage, and, without limitation, to exercise any other rights it has under the
mortgage or with respect to the property located at: 508 Herman Avenue, Lemoyne,
Pennsylvania 17043.
Rule 4001(a)(3) is not applicable and Deutsche Bank National Trust Company as Truste
for Morgan Stanley ABS Capital 1 Inc. Trust 2004-HE9, Mortgage Pass-Through Certificates,
Series 2004-HE9, or its Successor or Assignee may immediately enforce and implement this
order granting relief from the automatic stay.
By the Coint
Judge
This document is electronically signed and filed on the same date.
Dated: May 19, 2009
Chapter 7
Bankruptcy No. 1-09-bk-02645 MDF
ti
r,
Case 1:09-bk-02645-MDF Doc 23 Filed 05/19/09 Entered 05/19/09 14:33:11
Main Document Page 1 of 1
fnldeend (10/09)
UNITED STATES BANKRUPTCY COURT
MIDDLE DISTRICT OF PENNSYLVANIA
In re: Debtor(s) (name(s) used by the debtor(s) in the last 8 years, including married, maiden, and trade):
Bart A Trout
dba All American Gutter
508 Herman Avenue
Lemoyne, PA 17043
Teresa M Trout
508 Herman Avenue
Lemoyne, PA 17043
Chapter 7
Case No. 1:09-bk-02645-MDF
Last four digits of Social-Security, Individual
Taxpayer-Identification, Employer Tax-Identification No(s)(if
any):
xxx-xx-1912
xxx-xx-2161
FINAL DECREE
The estate of the above named debtor(s) has been fully administered.
Z
C
G'7
t `w'_s
IT IS ORDERED, Lawrence G. Frank (Trustee) is discharged as trustee of the estate of the above named
debtor(s); the case is closed without a discharge having been issued for Bart A Trout and Teresa M Trout in
accordance with F.R.B.P. 4004(c)(1)(H).
BY THE COURT
Dated: July 28. 2010 Mary D. France
United States Bankruptcy Judge
This document is electronically signed and filed on the same date.
0'_ (? '70
Case 1:09-bk-02645-MDF Doc 32 Filed 07/28/10 Entered 07/28/10 13:07:47
Final Decree - No Discharge Page 1 of 1
PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P 3180-31.83
KML Law Group, P.C.
Suite 5000 - BNY Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE ON BEHALF OF THE CERTIFICATE
HOLDERS OF MORGAN STANLEY ABS CAPITAL I
INC. TRUST 2004-HE9, MORTGAGE PASS
THROUGH CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
vs.
TERESA TROUT
BART A. TROUT
Mortgagor(s) and Record Owner(s)
508 Herman Avenue
Lemoyne, PA 17043
Defendant(s)
TO THE PROTHONOTARY:
IN THE COURT OF COMMON
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
No. 06-6670
I-q
r*? Mw
C=
?i
,* CD
>
`
na
PRAECIPE FOR WRIT OF EXECUTION
Issue Writ of Execution in the above matter:
O
6?8.5o PD ATr%/
49.08 c?-
lfi.00
%&. 0 S "
'1?f.00 'r
yy, 00
V5 so '.
9.00
I-500
10.00
,r
8.00
l'f • DO 'r
/, d/6.16, - PO A7TY
$a.a5,ve0o
C* 7 `188{
0 d 79037
Amount Due
Interest from
6/21/2008 to Date of
Sale per diem at
$20.91
(Costs to be added)
$120,429.74
By:
KML LA GROUP, P.C.
Michael McKeever Pa. ID 56129
Jay E. Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
istina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. 205047
Jill P. Jenkins Pa. ID 306588
Attorneys for Plaintiff
RE Ori :z ?_
ALL that certain or parcel of land and premises, situate, lying and being in the Borough
of Lemoyne, in the County of Cumberland and Commonwealth of Pennsylvania, more
particularly described as follows, being Lot No. 64 and the western one-half of Lot No.
65, Section "D", on the Plan of Riverton, said Plan being recorded in the Cumberland
County Recorder's Office in Deed Book "C", Volume 11, Page 589, more particularly
bounded and described as follows:
BEGINNING at a point on the southern line of Herman Avenue, said point located 57.5
feet measured westwardly along the southern line of Herman Avenue from the southwest
corner of Herman Avenue and Fifth Street; thence in a southerly direction through the
center of the partition wall of a double two and one-half story frame dwelling house, a
distance of 150 feet to Plum Alley; thence along the northern side of Plum Alley, a
distance of 52.5 feet to a point on the dividing line between Lot Nos. 63 and 64 on said
Plan; thence along said dividing line in a northerly direction, a distance of 150 feet to a
point on the southern side of Herman Avenue; thence in an easterly direction along the
southern side of Herman Avenue a distance of 52.5 feet to a point, the place of
BEGINNING.
HAVING thereon erected the western one-half of a double two one-half story frame
dwelling house as 508 Herman Avenue, Lemoyne Pennsylvania.
TAX PARCEL #: 12-22-0822-158
KML Law Group, P.C.
Suite 5000 - BNY Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS
OF MORGAN STANLEY ABS CAPITAL I INC. TRUST
2004-HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
vs.
TERESA TROUT
BART A. TROUT
Mortgagor(s) and Record Owner(s)
508 Herman Avenue
Lemoyne, PA 17043
Defendant(s)
CERTIFICATION AS TO THE SALE OF REAL PROPERTY
NO. 06-6670
Plaintiff, by counsel, hereby certifies that it has complied with the provisions of Act 91 of 1983 and/or
property in question is not subject to the Act.
By: 'Ie ._
- 64?? KML LAW GROUP, P.C.
Michael McKeever Pa. ID 56129
Jay E. Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
.David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. 205047
Jill P. Jenkins Pa. ID 306588
Attorneys for Plaintiff
oaf ?
IN THE COURT OF
COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF
MORTGAGE FOREC
real
IN THE COURT OF COMMON PLEAS OF CU
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS
OF MORGAN STANLEY ABS CAPITAL I INC. TRUST
2004-HE9, MORTGAGE PASS THROUGH CERTIFICATES,
SERIES 2004 HE9
Plaintiff
vs.
TERESA TROUT
BART A. TROUT
Defendant(s)
"BERLAND COUNTY, PENNS VA A
1
C)
NO. 06-6670
C- a
c
a
w.1,y
RELIEF ACT AS AMENDED
1. The undersigned attorney with KML Law Group, P.C., as the representative for the
intiff in
the above entitled matter, does hereby state to the best of his/her information and belief, as follows:
2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC")
operated by the United States Department of Defense (https://www.dmdc.osd.mil/appj/scra/scraHom(
for the following individual(s): TERESA TROUT, has a last known residence of 508 Herman Ave
Lemoyne, PA 17043-1822. The following information was used to search the DMDC (check all
apply):
X Last Name
X First Name
X Social Security Number
3. The DMDC search results, a copy of which is attached, states that based on the
provided, the DMDC does not possess any information indicating that the individual is on active
has been on active duty within the last 367 days.
The undersigned understands that the statements herein are made subject to penalties of 18
C.S.A. 4904 relating to unsworn falsification to authorities.
Date By: .ter
KML LAW GROUP, P.C.
Michael McKeever Pa. ID 56129
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Jay Kivitz Pa. ID 26769
Andrew Gornall Pa. ID 92382
Joshua I. Goldman Pa. 205047
Jill P. Jenkins Pa. ID 306588
Attorneys for Plaintiff
or
fr2 p12 08:47:59
Department of Defense Manpower Data Center Results as of: Aug-0
SCRA 2.2.2
Status Report
Pursuant to S+erv cememb ers Civil Relief Act
Last Name: TROUT First Name: TERESA
Active Duty Status As Of: Aug-06-2012
Active Duty Start Date Active Duty End Date Status Service component
On Active Duty On Active Duty Status Dale
NA NA No NA
This response reflects the individuals' active duty status based on the Active Duty Status Date
Left Active Duty within 367 Days of Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA NA No NA
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Dale
The fdember or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date
Order Notification Start Date - Order Notification End. Date -- Status -.Service Component
NA NA No NA
This response reflects whether the individual or his/her unit has received early notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is th status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Hea h, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
W LAJ.11- W
y6t oral my 4? A?M-
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility
Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as
the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family
member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitle to the
protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL: http://www.defenselink.mil/faglpis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status
date and you fail to obtain this additional Service verification, punitive provisions of the SCRA maybe invoked against you. See 50 USC App. § 52 (c).
This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual lelft Active
Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for ctive
duty on the Active Duty Status Date.
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active servi e
authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard eserve
Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the S.
Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps).
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1).
Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this websit
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of ervice.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who h ve not
actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of t e SCRA
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under they SCRA
are protected
WARNING: This certificate was provided based on a last name, SSN, and active duty status date provided by the requester. Providing erroneous
information will cause an erroneous certificate to be provided.
Report ID: LJCE29N548
IN THE COURT OF COMMON PLEAS OF CU
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS
OF MORGAN STANLEY ABS CAPITAL I INC. TRUST
2004-HE9, MORTGAGE PASS THROUGH CERTIFICATES,
SERIES 2004 HE9
Plaintiff
vs.
TERESA TROUT
BART A. TROUT
Defendant(s)
"BERLAND COUNTY, PENNSYLVANIA
NO. 06-6670 s C?
r- C- ;
RELIEF ACT AS AMENDED
1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in
the above entitled matter, does hereby state to the best of his/her information and belief, as follows:
2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC")
operated by the United States Department of Defense (https://www.dmdc.osd.mil/appi/scra/scraHom(
for the following individual(s): BART A. TROUT, has a last known residence of 508 Herman Ave
Lemoyne, PA 17043-1822. The following information was used to search the DMDC (check all
apply):
X Last Name
X First Name
X Social Security Number
3. The DMDC search results, a copy of which is attached, states that based on the
provided, the DMDC does not possess any information indicating that the individual is on active
has been on active duty within the last 367 days.
The undersigned understands that the statements herein are made subject to penalties of 18
C.S.A. 4904 relating to unsworn falsification to authorities.
Date 0 By: '
KML LAW GROUP, P.C.
Michael McKeever Pa. ID 56129
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
l----David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Jay Kivitz Pa. ID 26769
Andrew Gornall Pa. ID 92382
Joshua I. Goldman Pa. 205047
Jill P. Jenkins Pa. ID 306588
Attorneys for Plaintiff
or
Department of Defense Manpower Data Center
status Report
Pursuant to Servicemembets Civil Relief Act
Last Name: TROUT First Name: BART
Active Duty Status As Of: Aug-06-2012
Results as of : Aug-06-2b12 06:21:49
..'SCRA 2.2.2
Active. Duty Start Date Active Duty End Date Status Service Component
On Active Duty On Active Duty Status Date
NA NA No NA
This response reflects the individuals' active duty status based on the Active Duty Status Date
Left Active Duty W" 367 Days of Active Duty Status Date
Active Duty Start Date Active Duty End Date status Service Component
NA NA No NA
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or HisMer Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date
Order Notification Start Date Order Notification End Date Status Service Component
NA NA No NA
This response reflects whether the individual or his/her unit has received early notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is th status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAH, Public Hea h, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
iA_
fig %74?j
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility
Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as
the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any mily
member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitle to the
protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL: hftp://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty tatus
date and you fail to obtain this additional Service verification, punitive provisions of the SCRA maybe invoked against you. See 50 USC App. § 52 (c).
This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual I ft Active
Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active
duty on the Active Duty Status Date.
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty perio s less
than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active servi e
authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by th
President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization positi n in the
unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve
Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the J.S.
Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps).
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who woul not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services eriods.
Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1).
Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this websit
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of ervice.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not
actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under th? SCRA
are protected
WARNING: This certificate was provided based on a last name, SSN, and active duty status date provided by the requester. Providing erroneous
information will cause an erroneous certificate to be provided.
Report ID: K7MCI0F703
T
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KML Law Group, P.C.
Suite 5000 - BNY Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF THE
CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-HE9,
MORTGAGE PASS THROUGH CERTIFICATES,
SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
vs.
TERESA TROUT
BART A. TROUT
(Mortgagor(s) and Record Owner(s))
508 Herman Avenue
Lemoyne, PA 17043
Plaintiff
Defendant(s)
IN THE COURT OF COMMON
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
AFFIDAVIT PURSUANT TO RULE 3129
No. 06-6670 -
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DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE ON BEHALF OF THE CERTIFICA
HOLDERS OF MORGAN STANLEY ABS CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9, Plaintiff in the above action, by counsel, KML Law Group, P.C., sets forth as c
date the praecipe for the writ of execution was filed the following information concerning the real property located at:
508 Herman Avenue
Lemoyne, PA 17043
1.Name and address of Owner(s) or Reputed Owner(s):
TERESA TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
BART A. TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
2. Name and address of Defendant(s) in the judgment:
TERESA TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
BART A. TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
the
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS
8201 GREENSBORO DRIVE
SUITE 350
MCLEAN, VA 22102
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC
3300 SW 34TH AVENUE
SUITE 101
OCALA, FL 34474
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS
C/O PHELAN HALLINAN & SCHMIEG, LLP
1617 JFK Boulevard STE 1400
Philadelphia, PA 19103
4. Name and address of the last recorded holder of every mortgage of record:
PENNSYLVANIA HOUSING FINANCE AGENCY
211 North Front Street
PO BOX 15057
Harrisburg, PA 17101
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be
by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which }nay be
affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may
affected by the sale.
TENANTS/OCCUPANTS
508 Herman Avenue
Lemoyne, PA 17043
TRACY BURDULIS-TROUT
38 GOLFVIEW ROAD
CAMP HILL, PA 17011
I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understanthat
false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities.
DATED: U I?
By: D '
KML LAW GROUP, P.C. z
-Michael McKeever Pa. ID 56129
Jay E. Kivitz Pa. ID 26769
-Lisa Lee Pa. ID 78020
-Kristina Murtha Pa. ID 61858
-David Fein Pa. ID 82628
-Thomas Puleo Pa. ID 27615
-Joshua 1. Goldman Pa. 205047
-Jill P. Jenkins Pa. ID 306588
Attorneys for Plaintiff
06-66701
KML Law Group, P.C.
Suite 5000- BNY Independence Center
701 Market Street
Philadelphia, PA 19106
(215) 627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF THE
CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-
HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
vs.
TERESA TROUT
BART A. TROUT
Mortgagor(s) and Record Owner(s)
508 Herman Avenue
Lemoyne, PA 17043
Defendant(s,
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
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Docket No. 06-6670 -0 a ?
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THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: TROUT, TERESA
TERESA TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
Your house at 508 Herman Avenue, Lemoyne, PA 17043 is scheduled to be sold at Sheriffs Sale
on Wednesday, December 05, 2012, at 10:00 AM, in Commissioners Hearing Rm. 2nd FL Courthouse to
enforce the court judgment of $120,429.74 obtained by DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9 against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
IN THE COURT OF COMMON PLEAS
C;;;J,) r:.
;- -
To prevent this Sheriffs Sale you must take immediate action:
06-66701
1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN STANLEY ABS
CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2004
HE9, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you
must pay call our office at 215-825-6329 or 1-866-413-2311.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings
4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
8. You may contact the Foreclosure Resource Center: httn://www.philadelphiafed.org/foreclosure/
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
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
06-6670'
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: or 717-243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.g_ov for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website
http://www.phfa.org/consumers/homeowners/real.aspx.
5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at
homeretention@kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825-
6429. The figure and/or package you requested will be mailed to the address that you
request or faxed if you leave a message with that information. The attorney in charge of
our firm's Homeowner Retention Department is David Fein who can be reached at 215-
825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of CWD-
6627.
Para informacion en espanol puede communicarse con Loretta a1215-825-6344.
Plaintiff
Defendant(s)
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Docket No. 06-6670--tai ti
r"M
co
r-- 6_
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
06-6670
K AM Law Group, P.C.
Suite 5000- BNY Independence Center
701 Market Street
Philadelphia, PA 19106
(215) 627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF THE
CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-
HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
vs.
TERESA TROUT
BART A. TROUT
Mortgagor(s) and Record Owner(s)
508 Herman Avenue
Lemoyne, PA 17043
TO: TROUT, BART A.
BART A. TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
Your house at 508 Herman Avenue, Lemoyne, PA 17043 is scheduled to be sold at Sheriffs Sale
on Wednesday, December 05, 2012, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to
enforce the court judgment of $120,429.74 obtained by DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9 against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
IN THE COURT OF COMMON PLEAS
=T- ,
c
`--
To prevent this Sheriffs Sale you must take immediate action:
06-6670,
I The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN STANLEY ABS
CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2004
HE9, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you
must pay call our office at 215-825-6329 or 1-866-413-2311.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
8. You may contact the Foreclosure Resource Center: hqp://www.pliiiadelphiafed.org/foreclosure/
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
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
I
06-6670
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: or 717-243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website
http://www.phfa.or2/consumers/homeowners/real.aspx.
5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at
homeretention@kmllawgroup.coni.com. Call Seth at 215-825-6329 or fax 215-825-
6429. The figure and/or package you requested will be mailed to the address that you
request or faxed if you leave a message with that information. The attorney in charge of
our firm's Homeowner Retention Department is David Fein who can be reached at 215-
825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of CWD-
6627.
Para information en espanol puede communicarse con Loretta al 215-825-6344.
ALL that certain or parcel of land and premises, situate, lying and being in the Borough
of Lemoyne, in the County of Cumberland and Commonwealth of Pennsylvania, more
particularly described as follows, being Lot No. 64 and the western one-half of Lot No.
65, Section "D", on the Plan of Riverton, said Plan being recorded in the Cumberland
County Recorder's Office in Deed Book "C", Volume 11, Page 589, more particularly
bounded and described as follows:
BEGINNING at a point on the southern line of Herman Avenue, said point located 57.5
feet measured westwardly along the southern line of Herman Avenue from the southwest
corner of Herman Avenue and Fifth Street; thence in a southerly direction through the
center of the partition wall of a double two and one-half story frame dwelling house, a
distance of 150 feet to Plum Alley; thence along the northern side of Plum Alley, a
distance of 52.5 feet to a point on the dividing line between Lot Nos. 63 and 64 on said
Plan; thence along said dividing line in a northerly direction, a distance of 150 feet to a
point on the southern side of Herman Avenue; thence in an easterly direction along the
southern side of Herman Avenue a distance of 52.5 feet to a point, the place of
BEGINNING.
HAVING thereon erected the western one-half of a double two one-half story frame
dwelling house as 508 Herman Avenue, Lemoyne Pennsylvania.
TAX PARCEL #: 12-22-0822-158
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 06-6670 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY,
as Trustee on behalf of THE CERTIFICATE HOLDERS OF MORGAN STANLEY ABS CAPITAL
I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2004 HE9,
Plaintiff (s)
From TERESA TROUT & BART A TROUT
(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: $120,429.74 L.L.:
Interest from 6/21/08 to Date of Sale per diem @ $20.91
Atty's Comm: % Due Prothy: $2.25
Atty Paid: $1,216.16 Other Costs:
Plaintiff Paid:
Date: 8/8/12 '
David D. Buell, Prothonotary
??--
(Seal) o ??•
Deputy
REQUESTING PARTY:
Name: DAVID FEIN, ESQUIRE
Address: KML LAW GROUP, PC
SUITE 5000 - BNY INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106-1532
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ID No. 82628
HIVII~ LAW GROUP, P.C.
Suite 5000
BNY Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF THE
CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-
HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
vs.
TERESA TROUT
BART A. TROUT
Mortgagor(s) and
Record Owner(s)
508 Herman Avenue
Lemoyne, PA 17043
Defendant(s)
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CWD-6627
CF: 11/20/2006
SD: 12/05/2012
$120,429.74
OF COMMON PLEAS
of Cumberland County
CNIL ACTION -LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 06-6670
CERTIFICATE OF SERVICE
PURSUANT TO Pa.R.C.P. 3129.2 (c) (2)
Keith C. Halili, an employee of KML Law Group, P.C., counsel of Plaintiff, hereby certifies that service
on the Defendants of the Notice of Sheriff Sale was made by:
(~Q Personal Service by the Sheriffs Office/eernpetent-et~rlt (copy of return attached).
( ) Certified mail by KML Law Group, P.C. (original green Postal return receipt attached).
( ) Certified mail by Sheriffs Office.
( ) Ordinary mail by KML Law Group, P.C. to Attorney for Defendant(s) of record (proof of mailing
attached).
( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached).
( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record.
IF SERVICE WAS ACCOMPLISHED BY COURT ORDER.
( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached).
( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached).
( ) Certified Mail & ordinary mail by KML Law Group, P.C. (original receipt(s) for Certified Mail
attached).
( ) Published in accordance with court order (copy of publication attached).
Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by
ordinary mail KML Law Group, P.C. (copies of proofs of mailing attached).
The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section
4904.
Respectfully sub fitted,
BY: Keith .Halili
Legal Assistant
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Duetsche Bank National Trust Company
vs. Case Number
Bart Trout (et al.) 2006-6670
SHERIFF'S RETURN OF SERVICE
10/04/2012 11:40 AM -Deputy William Cline, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the
above titled action, upon the property located at 508 Herman Avenue, Lemoyne Borough, Lemoyne, PA
17109, Cumberland County.
10/05/2012 07:14 PM -Deputy Ryan Burgett, being duly sworn according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, by making known its contents and at the same
time personally handing a true copy to a person representing themselves to be TERESA TROUT-WIFE,
who accepted as "Adult Person in Charge" for Bart Trout at 508 Herman Avenue, Lemoyne Borough,
Lemoyne, PA 17109, Cumberland County.
10/05/2012 07:14 PM -Deputy Ryan Burgett, being duly sworn according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, by making known its contents and at the same
time personally handing a true copy to a person representing themselves to be the Defendant, to wit:
Teresa Trout at 508 Herman Avenue, Lemoyne Borough, Lemoyne, PA 17109, Cumberland County.
SHERIFF COST: $941.20
October 25, 2012
SO ANSWERS,
..,
RON R ANDERSON, SHERIFF
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KML Law Group, P.C.
Suite 5000 - BNY Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF THE
CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-
HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
vs.
TERESA TROUT
BART A. TROUT
Mortgagor(s) and Record Owner(s)
508 Herman Avenue
Lemoyne, PA 17043
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION -LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 06-6670
SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE ON BEHALF OF THE CERTIFICATE
HOLDERS OF MORGAN STANLEY ABS CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9, Keith C. Halili, an employee of KML Law Group, P.C., counsel of Plaintiff, sets forth
as of the date the praecipe for the writ of execution was filed the following information concerning the real property located
at:
508 Herman Avenue
Lemoyne, PA 17043
1.Name and address of Owner(s) or Reputed Owner(s):
TERESA TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
BART A. TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
2. Name and address of Defendant(s) in the judgment:
TERESA TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
BART A. TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
PA DEPARTMENT OF PUBLIC WELFARE -Bureau of Child Support Enforcement
Health and Welfare Bldg. -Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS
8201 GREENSBORO DRIVE
SUITE 350
MCLEAN, VA 22102
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC
3300 SW 34TH AVENUE
SUITE 101
OCALA, FL 34474
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS
C/O PHELAN HALLINAN & SCHMIEG, LLP
1617 JFK Boulevard STE 1400
Philadelphia, PA 19103
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC
P.O. Box 2026
Flint, MI 48501
BOROUGH OF LEMOYNE
665 Market Street
Lemoyne, PA 17043
YELLOW BOOK SALES AND DISTRIBUTION COMPANY INC.
c/o Amato and Lessa, P.C.
107 North Commerce Way
Bethlehem, PA 18017
4. Name and address of the last recorded holder of every mortgage of record:
PENNSYLVANIA HOUSING FINANCE AGENCY
211 North Front Street
PO BOX 15057
Harrisburg, PA 17101.
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
508 Herman Avenue
Lemoyne, PA 17043
TRACY BURDULIS-TROUT
38 GOLFVIEW ROAD
CAMP HILL, PA 1701 I
I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
DATED: November 21, 2012
KML Law Group, P.C.
BY: Keith C. Halili
Legal Assistant
PRAECIPE FOR WRIT OF EXECUTION- (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
KML Law Group,P.C.
Suite 5000-BNY Independence Center (j j '(�lt� �' „�
701 Market Street
Philadelphia,PA 19106-1532 L 0 C 0 U T
215-627-1322 P E NS Y,-vA tj'
Attoniey-for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE ON BEHALF OF THE CERTIFICATE
HOLDERS OF MORGAN STANLEY ABS CAPITAL I IN THE COURT OF COMMON PLEAS
INC.TRUST 2004-HE9,MORTGAGE PASS
THROUGH CERTIFICATES, SERIES 2004 HE9 of Cumberland County
7105 Corporate Drive
PTX C-35 CIVIL ACTION—LAW
Plano,TX 75024
Plaintiff ACTION OF MORTGAGE FORECLOSURE
vs.
TERESA TROUT No. 06-6670
BART A.TROUT
Mortgagor(s)and Record Owner(s)
508 Herman Avenue
Lemoyne,PA 17043
Defendant(s)
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
$120,429.74
Interest from
6/21/2008 to Date of
Sale per diem at
$20.91
(Costs to be added)
T {
J i
a By:
KML Mcever O
Michael Pa.ID 56129
I_
it it g' 00 Lk Lk Jay E.Kivitz Pa. ID 26769
L� •a Lisa Lee Pa.ID 78020
u� 0 0 Kristina Murtha Pa.ID 61858
qq aQ ti t ` p� .S� David Fein Pa.ID 82628
LIL4 00 cc `3a.� '� Q Thomas Puleo Pa. ID 27615
DQ tc << < O Joshua I.Goldman Pa.205047
J ^ ill P.Jenkins Pa.ID 306588
�� w Oi
3�• 31 Attorneys for Plaintiff
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ALL that certain or parcel of land and premises, situate, lying and being in the Borough
of Lemoyne, in the County of Cumberland and Commonwealth of Pennsylvania, more
particularly described as follows, being Lot No. 64 and the western one-half of Lot No.
65, Section"D", on the Plan of Riverton, said Plan being recorded in the Cumberland
County Recorder's Office in Deed Book"C", Volume 11, Page 589, more particularly
bounded and described as follows:
BEGINNING at a point on the southern line of Herman Avenue, said point located 57.5
feet measured westwardly along the southern line of Herman Avenue from the southwest
corner of Herman Avenue and Fifth Street; thence in a southerly direction through the
center of the partition wall of a double two and one-half story frame dwelling house, a
distance of 150 feet to Plum Alley; thence along the northern side of Plum Alley, a
distance of 52.5 feet to a point on the dividing line between Lot Nos. 63 and 64 on said
Plan; thence along said dividing line in a northerly direction, a distance of 150 feet to a
point on the southern side of Herman Avenue; thence in an easterly direction along the
southern side of Herman Avenue a distance of 52.5 feet to a point,the place of
BEGINNING.
HAVING thereon erected the western one-half of a double two one-half story frame
dwelling house as 508 Herman Avenue, Lemoyne Pennsylvania.
IMPROVEMENTS consist of a residential dwelling.
MUNICIPALITY BOROUGH OF LEMOYNE
BEING PREMISES: as 508 Herman Avenue, Lemoyne PA 17043
SOLD as the property of BART A. TROUT AND TERESA TROUT
TAX PARCEL#12-22-0822-158
BEING the same premises which Timothy Jeffrey A. Niblett and Julie A. Niblett,
husband and wife and Kenneth W. Niblett, single man by deed dated 7/13/2004 and recorded
7/27/2004 in Cumberland County in Deed Book Volume 264 at Page 1786 granted and
conveyed unto Bart A. Trout and Teresa Trout.
KML Law Group,P.C.
Suite 5000—BNY Independence Center y , U
x;41 E -J.I
701 Market Street " " I . ,
Philadelphia,PA 19106-1532
"
215-627-1322 '
Attorney for Plaintiff ,_ n
DEUTSCHE BANK NATIONAL TRUST COMPANY,AS LVANIA
TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS
OF MORGAN STANLEY ABS CAPITAL I INC. TRUST IN THE COURT OF
2004-1-IE9,MORTGAGE PASS THROUGH COMMON PLEAS
CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive of Cumberland County
PTX C-35
Plano,TX 75024 CIVIL ACTION-LAW
Plaintiff
VS. ACTION OF
MORTGAGE FORECLOSURE
TERESA TROUT
BART A.TROUT
Mortgagor(s)and Record Owner(s)
508 Herman Avenue NO. 06-6670
Lemoyne,.PA 17043
Defendant(s)
CERTIFICATION AS TO THE SALE OF REAL PROPERTY
Plaintiff,by counsel,hereby certifies that it has complied with the provisions of Act 91 of 1983 and/or the real
property in question is not subject to the Act.
By. A.
KML LAVAOUAY.C.
Michael McKeever Pa.ID 56129
Jay E.Kivitz Pa.ID 26769
Lisa Lee Pa.ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa.ID 82628
Thomas Puleo Pa.ID 27615
Joshua I.Goldman Pa.205047
Jill P.Jenkins Pa. ID 306588
Attorneys for Plaintiff
KML Law Group,P.C.
Suite 5000—BNY Independence Center
701 Market Street
Philadelphia,PA 19106-1532 "" 4 E fi:1 ( j :215-627-1322
i zt�Q 1 F
Attorney for Plaintiff
, ,<
DEUTSCHE BANK NATIONAL TRUST ; r KLA
COMPANY,AS TRUSTEE ON BEHALF OF THE 1 `I� C( >�JF COMMON PLEAS
CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-HE9, of Cumberland County
MORTGAGE PASS THROUGH CERTIFICATES,
SERIES 2004 HE9
7105 Corporate Drive CIVIL ACTION-LAW
PTX C-35
Plano,TX 75024
Plaintiff ACTION OF MORTGAGE FORECLOSURE
vs.
TERESA TROUT
BART A.TROUT No. 06-6670
(Mortgagor(s) and Record Owner(s)
508 Herman Avenue
Lemoyne,PA 17043
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
DEUTSCHE BANK NATIONAL TRUST COMPANY,AS TRUSTEE ON BEHALF OF THE CERTIFICATE
HOLDERS OF MORGAN STANLEY ABS CAPITAL I INC. TRUST 2004-HE9,MORTGAGE PASS THROUGH
CERTIFICATES,SERIES 2004 HE9,Plaintiff in the above action,by counsel,KML Law Group,P.C.,sets forth as of the
date the praecipe for the writ of execution was filed the following information concerning the real property located at:
508 Herman Avenue
Lemoyne,PA 17043
1.Name and address of Owner(s)or Reputed Owner(s):
TERESA TROUT
508 Herman Avenue
Lemoyne,PA 17043-1822
BART A.TROUT
508 Herman Avenue
Lemoyne,PA 17043-1822
2.Name and address of Defendant(s)in the judgment:
TERESA TROUT
508 Herman Avenue
Lemoyne,PA 17043-1822
BART A.TROUT
508 Herman Avenue
Lemoyne,PA 17043-1822
1
3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
PA DEPARTMENT OF PUBLIC WELFARE-Bureau of Child Support Enforcement
Health and Welfare Bldg. -Room 432
P.O.Box 2675
Harrisburg,PA 171.05-2675
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle,PA 17013
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS
8201 GREENSBORO DRIVE
SUITE 350
MCLEAN,VA 22102
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,INC
3300 SW 34TH AVENUE
SUITE 101
OCALA,FL 34474
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS
C/O PHELAN HALLINAN&SCHMIEG,LLP
1617 3FK Boulevard STE 1400
Philadelphia,PA 19103
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,INC
P.O.Box 2026
Flint,MI 48501
BOROUGH OF LEMOYNE
665 Market Street
Lemoyne,PA 17043
YELLOW BOOK SALES AND DISTRIBUTION COMPANY INC.
c/o Amato and Lessa,P.C.
107 North Commerce Way
Bethlehem,PA 18017
4.Name and address of the last recorded holder of every mortgage of record:
PENNSYLVANIA HOUSING FINANCE AGENCY
211 North Front Street
PO BOX 15057
Harrisburg,PA 17101
5.Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6.Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7.Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
508 Herman Avenue
Lemoyne,PA 17043
TRACY BURDULIS-TROUT
38 GOLFVIEW ROAD
CAMP HILL,PA 17011
I verify that the statements made in this affidavit are true and correct to the best of my information and belief.I
understand that falsei statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn
falsification to autho ,ties.
DATED: �
By: ?r l
KML LA GROUP,At.
Michael McKeever Pa.ID 56129
Jay E.Kivitz Pa. ID 26769
Lisa Lee Pa.ID 78020
Kristina Murtha Pa.ID 61858
David Fein Pa.ID 82628
Thomas Puleo Pa.ID 27615
oshua I.Goldman Pa.205047
Jill P.Jenkins Pa.ID 306588
Attorneys for Plaintiff
06-6670
KML Law Group,P.C.
Suite 5000-BNY Independence Center
701 Market Street uo 4l .�
Philadelphia,PA 19106
(215)627-1322 � '` �; .
Attorney for Plaintiff PENN l f co u r g
DEUTSCHE BANK NATIONAL TRUST COMPANY,AS
TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS IN THE COURT OF COMMON PLEAS
OF MORGAN STANLEY ABS CAPITAL I INC.TRUST 2004-
HE9,MORTGAGE PASS THROUGH CERTIFICATES, of Cumberland County
SERIES 2004 HE9
7105 Corporate Drive
PTX C-35 CIVIL ACTION-LAW
Plano,TX 75024
Plaintiff ACTION OF MORTGAGE FORECLOSURE
vs.
TERESA TROUT Docket No.06-6670
BART A.TROUT
Mortgagor(s)and Record Owner(s)
508 Herman Avenue
Lemoyne,PA 17043
Defendant(s)
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: TROUT,BART A.
BART A. TROUT
508 Herman Avenue
Lemoyne,PA 17043-1822
Your house at 508 Herman Avenue,Lemoyne,PA 17043 is scheduled to be sold at Sheriffs Sale
on Wednesday,March 12,2014,at 10:00 AM,in Commissioners Hearing Rm.2nd FL Courthouse to
enforce the court judgment of$120,429.74 obtained by DEUTSCHE BANK NATIONAL TRUST
COMPANY,AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-HE9,MORTGAGE PASS THROUGH
CERTIFICATES,SERIES 2004 HE9 against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
06-6670
1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN STANLEY ABS
CAPITAL 1 INC.TRUST 2004-HE9,MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2004
HE9,the back payments,late charges,costs and reasonable attorney's fees due.To find out how much you
must pay call our office at 215-825-6329 or 1-866-413-2311.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment,if
the judgment was improperly entered.You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
4. You may need an attorney to assert your rights.The sooner you contact one,the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder.You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale.To find
out if this has happened,you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff,you Will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer.At that time,the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house.A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty(30)days from the
date of the Sheriffs Sale.This schedule will state who will be receiving that money.The money will be
paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is
wrong)are filed with the Sheriff within ten(10)days after the schedule of distribution is filed.
7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale.
8. You may contact the Foreclosure Resource Center: http://www.philadelphiafcd.org(foreclosure/
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
2 Liberty Avenue
Carlisle,PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle,PA 17013
717-243-9400
06-6670
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client)has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: or 717-243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website
http://www.phfa.org/consumers/homeowners/real.aWx.
5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at
homeretention gkmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825-
6429. The figure and/or package you requested will be mailed to the address that you
request or faxed if you leave a message with that information. The attorney in charge of
our firm's Homeowner Retention Department is David Fein who can be reached at 215-
825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of CWD-
6627.
Para informacion en espanol puede communicarse con Loretta a1215-825-6344.
s
06-6670
KML Law Group,P.C.
Suite 5000-BNY Independence Center
701 Market Street
Philadelphia,PA 19106 n4 i. !' } ,� t ¢
(215)627-1322 j
y=�,�i fU
Attorney for Plaintiff �;(- t���(�
YLVANIA
DEUTSCHE BANK NATIONAL TRUST COMPANY,AS
TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS IN THE COURT OF COMMON PLEAS
OF MORGAN STANLEY ABS CAPITAL I INC.TRUST 2004-
HE9,MORTGAGE PASS THROUGH CERTIFICATES, of Cumberland County
SERIES 2004 HE9
7105 Corporate Drive
PTX C-35 CIVIL ACTION-LAW
Plano,TX 75024
Plaintiff ACTION OF MORTGAGE FORECLOSURE
vs.
TERESA TROUT Docket No.06-6670
BART A.TROUT
Mortgagor(s)and Record Owner(s)
508 Herman Avenue
Lemoyne,PA 17043
Defendants)
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: TROUT,TERESA
TERESA TROUT
508 Herman Avenue
Lemoyne,PA 17043-1822
Your house at 508 Herman Avenue,Lemoyne,PA 17043 is scheduled to be sold at Sheriffs Sale
on Wednesday,March 12,2014,. at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to
enforce the court judgment of$120,429.74 obtained by DEUTSCHE BANK NATIONAL TRUST
COMPANY,AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC.TRUST 2004-HE9,MORTGAGE PASS THROUGH
CERTIFICATES,SERIES 2004 HE9 against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
06-6670
1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN STANLEY ABS
CAPITAL I INC.TRUST 2004-HE9,MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2004
HE9,the back payments,late charges,costs and reasonable attorney's fees due.To find out how much you
must pay call our office at 215-825-6329 or 1-866-413-2311.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered.You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
4. You may need an attorney to assert your rights. The sooner you contact one,the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder.You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened,you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer.At that time,the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house.A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty(30)days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money.The money will be
paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is
wrong)are filed with the Sheriff within ten(10)days after the schedule of distribution is filed.
7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale.
8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/
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
2 Liberty Avenue
Carlisle,PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle,PA 17013
717-243-9400
06-6670
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender(and our client)has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: or 717-243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website
http://www.phfa.org/consumers/homeowners/real.asRx.
5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at
homeretention gkmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825-
6429. The figure and/or package you requested will be mailed to the address that you
request or faxed if you leave a message with that information. The attorney in charge of
our firm's Homeowner Retention Department is David Fein who can be reached at 215-
825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of CWD-
6627.
Para informacion en espanol puede communicarse con Loretta a1215-825-6344.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 06-6670 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION—LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN STANLEY ABS
CAPITAL I INC. TRUST 2004-HE9,MORTGAGE PASS THROUGH CERTIFICATES,SERIES
2004 HE9 Plaintiff(s)
From TERESA TROUT,BART A.TROUT
(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: $120,429.74 L.L.: $.50
Interest FROM 6/21/2008 TO DATE OF SALE PER DIEM AT$20.91
Atty's Comm: Due Prothy: $2.25
Atty Paid: $2,138.97 Other Costs:
Plaintiff Paid:
Date: 11/21/13
David D. B ell, Prothonotary
(Seal)
Deputy
REQUESTING PARTY:
Name: JILL P.JENKINS,ESQUIRE
Address: KML LAW GROUP,P.C.
SUITE 5000-BNY INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA,PA 19106-1532
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ID No.306588
•
KML Law Group,P.C.
Suite 5000-BNY Independence Center Fj ��
701 Market Street 2 7 1 J JQ: 33
Philadelphia,PA 19106-1532 C IBERLA O CQ l Tv
215-627-1322 PLN,' SYLVAN'lA
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY,AS TRUSTEE ON BEHALF OF THE IN THE COURT OF COMMON PLEAS
CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004- OF Cumberland COUNTY
HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35 No. 06-6670
Plano,TX 75024
vs.
TERESA TROUT and BART A. TROUT
508 Herman Avenue
Lemoyne,PA 17043
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
MOTION FOR SUBSTITUTED SERVICE
UNDER PA.R.C.P.430(a)
Plaintiff,by and through its attorney, in support of its Motion for Substituted Service,
represents as follows:
1. Plaintiff is the holder of a mortgage upon the premises 508 Herman Avenue, Lemoyne,
PA, 17043,hereinafter,the "mortgaged premises".
2. Defendants, TERESA TROUT and BART A. TROUT,are the mortgagors and real
owners of the mortgaged premises.
3. Pursuant to Cumberland County Local Rule 208.3(a)(2)and/or Rule 208.3(a)(9),I, Alyk
Oflazian,Esquire, hereby certify that no judge has ruled on any other matters in this case. I further certify
that I am not aware that the Defendant has obtained counsel. Moreover, due to the nature of this motion,
it was not possible to locate or contact the Defendant to request her concurrence.
4. The last known addresses of Defendant,Teresa Trout,are 508 Herman Avenue,
Lemoyne,PA 17043 and 2622 Mayfair Lane,York,PA 17408 from our investigative search.
5. The Sheriff has been unable to effect service of the Notice of Sale upon Defendant,
Teresa Trout. Service was attempted on Defendant, Teresa Trout at the mortgaged premises 508 Herman
Avenue,Lemoyne,PA 17043. The property is vacant. Service was attempted on Defendant, Teresa
Trout at 2622 Mayfair Lane,York,PA 17408. The return of service indicates per the current resident,
Gary Hess father of Defendant, Teresa Trout moved from said address over six months ago to the
Dallastown,Pa area, exact whereabouts are unknown. No further information was provided.
6. The following investigation was conducted in a good faith attempt to ascertain the
whereabouts of Defendant,Teresa Trout.
WHEREFORE,Plaintiff prays that the Court enter the attached order allowing Plaintiff
to serve the Notice of Sale upon Defendant,Teresa Trout,by posting the premises and certified and
regular mail to the Defendant's last known address.
By: Cam'-`(
KML LAW GROUP, P.C.
Michael McKeever Pa. ID 56129
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Jill P.Jenkins Pa. ID 306588
yo Alyk Oflazian Pa. ID 312912
Salvatore Filippello Pa. ID 313897
Attorneys for Plaintiff
Affidavit of Good Faith Investigation
At the request of the law firm identified below I initiated an investigation into the whereabouts of the
defendant identified as the subject below. The following is true and accurate representation of my
investigation.
Client provided information: File Number: CWD-6627
Attorney/Law Firm:KML LAW GROUP, P.0
Subject Name: TERESA TROUT
Property Address: Street:508 Herman Avenue
City: Lemoyne State: PA Zip: 17043
Skip Results: Date of Birth: ProVest File Number:3848928
Last Known Address(as of 12/26/2013)Street:508 Herman Ave
City:Lemoyne State: PA Zip: 17043
Death Record Search As of 12/26/2013,the Social Security Administration has no death
record on file for Teresa Trout.
Social Security Number [X]Verifed []Not Verified SSN#XXX-XX-
Employment Search During a search for employment of our defendant no verifiable
employment information was provided prior to the investigation or found
during the Investigation.
Business Records Search All American Gutter
Entity Number:552559
Status:Active
Entity Creation Date: 10/7/2005
State of Business.: PA
Principal Place of Business:508 Herman Ave. Lemoyne PA 17043.
Name:Trout,Teresa
Mailing Address: 508 Herman Ave. Lemoyne PA 17043.
Creditor Header Inquiry The latest address from the credit header info is:
Address:508 HERMAN AVE, LEMOYNE,PA 17043 1822
Department of Motor Unable to obtain Motor Vehicle Records in the State of Pennsylvania.
Vehicle Records Search*
Drivers License Information Search No current records found.
[]Govemmental**+
[]Non-governmental
Professional Licenses Search No record found.
Freedom Of Information Act Inquiry The following addresses were sent to the United States Postal
Made to U.S. Postal Service inspector at the zip code listed with no return information to date:
508 HERMAN AVENUE I LEMOYNE 1 P A I 17043 1 CUMBERLAND
COUNTY
Military Search Not on Active Duty; Did not leave Active Duty within the past 367 days;
Has not been notified of a future call up to Active Duty
Inquiry of Relatives, 717-761-4258: Called possible relative,Wayne Hess,number has
Neighbors,&Friends been disconnected.
717-975-8765: Called possible neighbor, Kimberly Soule,number has
been disconnected.
Comments: 717-761-8436: Called possible number of defendant,Teresa Trout,
number has been disconnected.
717-761-2604: Called possible number of defendant,Teresa Trout,
number has been disconnected.
Also current for defendant: 2622 MAYFAIR LN ,YORK PA 17408
*Data not available in AL,AR,CA,HI,NH,OR,PA,VA,WA.**Historical data in CO,DE,ID,IL,KY,LA,MD,MA,MS,MO,NH,ND,
SC,WV.
+Data available in CO,CT,DE,FL,ID,IL,KY,LA,ME,MD,MA,MI,MN,MS,MO,NH,ND,OH,SC,TN,TX,WV,WI,WY.
The foregoing statement is true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A.
§4904 relating to unswom falsification to authorities. Under penalties of perjury,I declare that I have read the foregoing affidavit and
that the facts stated in it are true. .
STATE OF FLORIDA
COUNTY OF HILLSBOROUGH DEC 3 0 2013
Justin Me /es File Numb r:3848928 Sworn to or affirmed and signed before me on this—day of
Provest Services LLC (Seal) _.
Date: DEC 3 0 2013
JOSHUA N.PIMENTEL /.
Notary Public,State of Florida
My Comm.Expires May 24,2015 Signattrrr f Notary lublic
No.EE 97050 ( r i/•- �/
Printed Name of Notary Public
( ersonally Known
( )Produced as identification
IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA •
DEUTSCHE BANK NATIONAL TRUST COMPANY,AS CASE and/or DOCKET No.:06-6670
TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS
OF MORGAN STANLEY ABS CAPITAL I INC.TRUST 2004- Sheriffs Sale Date:3/12/2014
11E9,MORTGAGE PASS THROUGH CERTIFICATES,
SERIES 2004 HE9;et seq.
Plaintiff(Petitioner)
•
V.
TERESA TROUT;et al.
Defendant(Respondent)
•
AFFIDAVIT OF NON-SERVICE
❑Complaint ❑Summons IA Other:NOTICE OF SALE
1,RYAN MARKS,certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party,and that I
attempted to serve TERESA TROUT the above process on the 4 day of December,2013,at 12:50 o'clock,PM,at 508 Herman Avenue Lemoyne,PA 17043,
County of Cumberland,Commonwealth of Pennsylvania:
Manner of Service:
Defendant was not served because: ❑Moved ❑Unknown ❑No Answer ❑Vacant
A Other:PROPERTY IS VACANT,ELECTRIC OFF,EMPTY INSIDE.
Service was attempted on the following dates/times:
1)_ 2)_ 3)
Commonwealth/State of PD yl.! i VQJAAJ.. )
/ )SS:
County of Fti-k--.c )
Before me,the undersigned notary public,this day,personally,appeared to me known,who being
duly sworn according to law,depose f+ e following: -- I
1 hereby swear or affi that /ts set forth in the foregoing Affidavit of Non-Service are true and correct.
/d Subscribed and sworn to before me
ignature of Affiant) this J'5 day of DEC, ,20 13 .
File Number:CW 1 6627
Case ID#:3827560 Notary Public
::::OstIta WEALTH OF PENNSYLVAN1A
MO ARIAL SEAL
gon Township,otary Public '
MYtommistton Expires December OS,2017
•
i •
t I
r1}�1�afri�
IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA
DEUTSCHE BANK NATIONAL TRUST COMPANY,AS CASE and/or DOCKET No.:06-6670
TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS
OF MORGAN STANLEY ABS CAPITAL I INC.TRUST 2004- Sheriff's Sale Date:3/12/2014
HE9,MORTGAGE PASS THROUGH CERTIFICATES,
SERIES 2004 HE9;et seq.
Plaintiff(Petitioner)
V.
TERESA TROUT; et al.
Defendant(Respondent)
•
AFFIDAVIT OF NON-SERVICE
(i Complaint ❑Summons IS Other:NOTICE OF SALE
I,KEVEN CHASE,certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party,and that I
attempted to serve TERESA TROUT the above process on the 8 day of February,2014,at 6:24 o'clock,PM,at 2622 Mayfair Ln york,PA 17408,County of
Cumberland,Commonwealth of Pennsylvania:
Manner of Service:
Defendant was not served because: ❑Moved ❑Unknown ❑No Answer ❑Vacant
In Other:PER RESIDENT,GARY HESS,FATHER OF TERESA TROUT,DEFENDANT MOVED OUT 6 MONTHS AGO TO THE DALLASTOWN
PA AREA,EXACT WHEREABOUTS NOT PROVIDED.
Service was attempted on the following dates/times:
1) 2) 3)
Commonwealth/State of e ti )
)SS:
County of 4..001 )
Before me,the undersigned notary public,this day,personally,appeared C h.rc to me known,who being
duly sworn according to law,deposes the following:
I hereby swear or affirm that the facts set forth in the foregoing Affidavit of Non-Service are true and correct.
Subscribed and sworn to before me
(Signature ofAffiant) this /0 day of - , t /y
File Number:CWD-6627
Case ID#:3887457 COMMONWEALTH OF PENNSYLVANIA Notary Public
NOTARIAL SEAL
Eric M.Afflerbach, Notary Public
Washington Township,Berks County
My Commission Expires November 18.2017
KMIL Law Group,P.C.
Suite 5000-BNY Independence Center
701 Market Street
Philadelphia,PA 19106-1532
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY,AS
TRUSTEE ON BEHALF OF THE CERTIFICATE
HOLDERS OF MORGAN STANLEY ABS CAPITAL I IN THE COURT OF COMMON PLEAS
INC. TRUST 2004-HE9,MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9 OF Cumberland COUNTY
7105 Corporate Drive
PTX C-35
Plano, TX 75024"
No. 06-6670
vs.
TERESA TROUT and BART A. TROUT
508 Herman Avenue
Lemoyne,PA 17043
MEMORANDUM OF LAW IN SUPPORT OF MOTION
FOR SUBSTITUTED SERVICE UNDER Pa.R.C.P.430(a)
Plaintiff has filed a Notice of Sheriff's Sale against Defendant, Teresa Trout,which the
Sheriff has been unable to personally serve upon Defendant, Teresa Trout. As noted in the attached
Motion,Plaintiff has made a good faith attempt to ascertain Defendant's whereabouts without success.
Accordingly,the Court may approve alternative means of service. See Pa.R.C.P.430(a).
•
CONCLUSION
For reasons stated above and in the attached Motion,the Court should enter an order
allowing Plaintiff to serve the Notice of Sheriffs Sale upon Defendant,Teresa Trout,by posting the
premises and certified mail and regular mail to the Defendant's last known address.
By:
KMLLA GROUP,P.C.
Michael McKeever Pa. ID 56129
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Jill P. Jenkins Pa. ID 306588
fu Alyk Oflazian Pa. ID 312912
Salvatore Filippello Pa. ID 313897
Attorneys for Plaintiff
KML Law Group,P.C.
Suite 5000-BNY Independence Center
701 Market Street
Philadelphia,PA 19106-1532
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY,AS TRUSTEE ON BEHALF OF THE
CERTIFICATE HOLDERS OF MORGAN IN THE COURT OF COMMON PLEAS
STANLEY ABS CAPITAL I INC. TRUST 2004-
HE9,MORTGAGE PASS THROUGH of Cumberland County
CERTIFICATES, SERIES 2004 11E9
7105 Corporate Drive
PTX C-35
Plano,TX 75024 No. 06-6670
vs.
TERESA TROUT
BART A. TROUT
508 Herman Avenue
Lemoyne,PA 17043
CERTIFICATE OF SERVICE
Marlene Powers, an employee of KML Law Group, P.C., counsel for plaintiff, does
hereby certify that true and correct copies of the foregoing Motion for Substituted Service have
been served upon the Defendants, Teresa Trout and Bart A. Trout this day of February 2014,
by first class mail, postage prepaid.
TERESA TROUT BART A. TROUT
2622 Mayfair Lane 2622 Mayfair Lane
York, PA 17048 York, PA 17048
TERESA TROUT BART A. TROUT
508 Herman Avenue 508 Herman Avenue
Lemoyne, PA 17043-1822 Lemoyne, PA 17043-1822
BART A. TROUT
594 Old York Rd Trlr 19
Etters, PA 17319
By: 771._
KML Law Group, P.C.
Marlene Powers, Legal Secretary
Direct Phone: 215-825-6340
r
DEUTSCHE BANK NATIONAL TRUST COMPANY, IN THE COURT OF COMMON PLEAS
AS TRUSTEE ON BEHALF OF THE CERTIFICATE
HOLDERS OF MORGAN STANLEY ABS CAPITAL I OF Cumberland COUNTY
INC. TRUST 2004-HE9, MORTGAGE PASS
THROUGH CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35 06-6670
Plano,TX 75024
`»
vs. rrlm '1 {
TERESA TROUT and BART A.TROUT r c.
508 Herman Avenue > ;
Lemoyne, PA 17043 { 7
ORDER
AND NOW,this 5 day of /Alrd 2014,upon consideration of the Plaintiffs
Motion for Substituted Service under Pa.R.C.P. 430(a)and it appearing to the Court that Plaintiffs good
faith efforts to ascertain the present whereabouts of Defendant,Teresa Trout,have been unsuccessful, it
is,
ORDERED and DECREED:
that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Notice of
Sheriff's Sale upon Defendant,Teresa Trout,by posting a copy of the Notice upon the premises 508
Herman Avenue,Lemoyne,PA, 17043, and Plaintiff is directed to serve the Notice of Sheriff Sale by
certified and regular mail to the Defendant's last known addresses at 508 Herman Avenue, Lemoyne,PA,
17043 and 2622 Mayfair Lane,York,PA 17408,and that all further service of legal papers, including but
not limited to motions, petitions and rules be made by certified and regular mail to Defendant's last
known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129
may be made upon Defendant,Teresa Trout,by sending copies of same to Defendant's last known
addresses by certified and regular mail and by posting the premises. Service is complete upon mailing.
BY THE COURT:
•
J.
D' tribution ichael T. McKeever, Esquire, Suite 5000— :NY Independence Center, 701 Market Street,
Philadelphia, PA 19106-1532
TERESA TROUT, 2622 Mayfair Lane York, PA 17048
C-Opy irtxt Lea, toPti 477,1
KML LAW GROUP, P.C.
Suite 5000 — BNY Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6320
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF
THE CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-
HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
vs.
TERESA TROUT
BART A. TROUT
Mortgagors and Record Owners
508 Herman Avenue
Lemoyne, PA 17043
Defendants
a,r;�' ^a.� -O, Fl
l
fL i i O 77{0N
20/4 HAY 13 4i 10: 51
CUMBERLAND
PENNSYLVANIA COUNTY
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 06-6670
NOTICE OF THE DATE OF CONTINUED SHERIFF'S SALE
The Sheriff's Sale scheduled for May 7, 2014 at 10:00 AM in the above captioned matter has
been continued until July 02, 2014 at 10:00 AM
Date: April 29, 2014
By:
06..„
KML LAW G' C P, P.C.
701 Market Streww- , Suite 5000
Philadelphia, PA 19106
(215) 825-6332
Michael McKeever Pa. ID 56129
Jay E. Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. ID 205047
Jill P. Jenkins Pa. ID 306588
Andrew F. Gornall Pa. ID 92382
Alyk L. Oflazian Pa. ID 312912
/ Salvatore Filippello Pa. ID 313897
V Jennifer Lynn Frechie Pa. ID 316160
Attorneys for Plaintiff
KML LAW GROUP, P.C.
Suite 5000
BNY Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
CWD-6627
CF: 11/20/2006
SD: 07/02/2014
$120,429.74
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF THE
CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-
HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
vs.
TERESA TROUT
BART A. TROUT
Mortgagor(s) and
Record Owner(s)
508 Herman Avenue
Lemoyne, PA 17043
Plaintiff
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION — LAW
ACTION OF MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICE
PURSUANT TO Pa.R.C.P. 3129.2 (c) (2)
Term
No. 06-6670
Veronica Cosme, an employee of KML Law Group, P.C., counsel of Plaintiff, hereby certifies that
service on the Defendants of the Notice of Sheriff Sale was made by:
21
Personal Service by the Sheriffs Office/competent adult (copy of return attached).
Certified mail by KML Law Group, P.C. (copy of green Postal return receipt attached).
Certified mail by Sheriffs Office.
Ordinary mail by KML Law Group, P.C. to Attorney for Defendant(s) of record (proof of mailing
attached).
Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached).
Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record.
IF SERVICE WAS ACCOMPLISHED BY COURT ORDER.
(X) Premises was posted by Sheriffs Office/competent adult (copy of return attached).
( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached).
(X) Certified Mail & ordinary mail by KML Law Group, P.C. (copy of receipt(s) for Certified Mail
attached).
( ) Published in accordance with court order (copy of publication attached).
Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by
ordinary mail KML Law Group, P.C. (copies of proofs of mailing attached).
The undersigned understands that the statements herein are subject to the penalties provided by 18 Pa. C.S.A.
Section 4904.
Respectfully submitted,
BY: Veronica Cosme
Legal Assistant
IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS
OF MORGAN STANLEY ABS CAPITAL I INC. TRUST 2004-
HE9, MORTGAGE PASS THROUGH CERTIFICATES,
SERIES 2004 HE9; et seq.
Plaintiff (Petitioner)
V.
TERESA TROUT; et al.
Defendant (Respondent)
CASE and/or DOCKET No.: 06-6670
Sheriff's Sale Date: 3/12/2014
AFFIDAVIT OF SERVICE
(] Complaint ❑ Summons L] Other: NOTICE OF SALE
I, KEVEN CHASE, certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party , and that I
served BART A. TROUT the above process on the 8 day of February, 2014, at 5:10 o'clock, PM, at 594 Old York Rd Trlr 19 Etters, PA 17319 , County of
Cumberland, Commonwealth of Pennsylvania:
Manner of Service:
U By handing a copy at the residence of the Defendant(s) to an adult member of the family with whom he/she resides or to the adult person in charge
of the residence because no adult family member was found *
El
By handing a copy at the residence of the Defendant(s) to the clerk or manager of the hotel, inn, apartment house or other place of lodging at which
he/she resides *
n By handing a copy at the office or usual place of business of the Defendant(s) to the Defendant's(s') agent or to the person for the time being in
charge thereof *
* Name: MELISSA THOMAS
Relationship/Title/Position: Co -Habitant
Remarks:
Description: Approximate Age 36-40 Height 5'8 Weight 125 Race WHITE Sex FEMALE Hair BROWN
Military Status: C�No ❑Yes Branch:
Commonwealth/State of {A
) SS:
County of d e e to i
Before me, the undersigned notary public, this day, personally, appeared
duly sworn according to law, deposes the following:
j e r c n c l•-.1 to me known, who being
I hereby swear or affirm that the facts set forth in the foregoing Affidavit of Service are true and correct.
(Signature of Affiant)
File Number:CWD-6627
Case ID #:3887457
Subscribed and sworn to before me
this 10 day of 019 .
COM---MMO NwtAALJH OF PENNSYLVANIA Notary Public
NOTARIAL SEAL
Eric M. Affrbach,Not
laryPublic
Washington Township, Berks County
My Commission Expires November 18, 2017
• 1
IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS
OF MORGAN STANLEY ABS CAPITAL I INC. TRUST 2004-
HE9, MORTGAGE PASS THROUGH CERTIFICATES,
SERIES 2004 HE9; et seq.
Plaintiff (Petitioner)
V.
TERESA TROUT; et al.
Defendant (Respondent)
CASE and/or DOCKET No.: 06-6670
Sheriff's Sale Date: 5/7/2014
AFFIDAVIT OF SERVICE
❑ Complaint 0 Summons 0 Other: NOTICE OF SALE
I, KEVEN CHASE, certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party , and that I
served TERESA TROUT the above process on the 16 day of March, 2014, at 12:23 o'clock, PM, at 508 Herman Avenue Lemoyne, PA 17043 , County of
Cumberland, Commonwealth of Pennsylvania:
Manner of Service:
Ej By posting a copy of the original process on the most public part of the property pursuant to an order of court
Service was attempted on the following dates/times:
1) 2) 3)
Commonwealth/State of /� )
) SS:
County of 3 Ad )
Before me, the undersigned notary public, this day, personally, appeared
duly sworn according to law, deposes the following:
Ktre�. tL•l�
I hereby swear or affirm that the facts set forth in the foregoing Affidavit of Service are true and correct.
Subscribed and sworn t
to me known, who being
e me
(Signature of Affiant) this 17 day of , 20 • Y .
File Number:CWD-6627
Case ID #:3921434
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL. SEAL
Eric M. Afflerbach, Notary Public
Washington Township, Berks County
My Commission Expires November 18, 2017
Notary Public
1 • •
DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE ON BEHALF OF THE CERITFICAlt,
HOLDERS OF MORGAN STANLEY ABS CAPITAL I
INC. TRUST 2004-11E9, MORTGAGE PASS
THROUGH CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
vs.
TERESA TROUT and BART A. TROUT
508 Herman Avenue
Lemoyne, PA 17043
ORDER
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
06-6670
AND NOW, this —544" day of 11.4-k2014, upon consideration of the Plaintiffs
Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiffs good
faith efforts to ascertain the present whereabouts of Defendant, Teresa Trout, have been unsuccessful, it
is,
ORDERED and DECREED:
that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Notice of
Sheriff's Sale upon Defendant, Teresa Trout, by posting a copy of the Notice upon the premises 508
Herman Avenue, Lemoyne, PA, 17043, and Plaintiff is directed to serve the Notice of Sheriff Sale by
certified and regular mail to the Defendant's last known addresses at 508 Herman Avenue, Lemoyne, PA,
17043 and 2622 Mayfair Lane, York, PA 17408, and that all further service of legal papers, including but
not limited to motions, petitions and rules be made by certified and regular mail to Defendant's last
known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129
may be made upon Defendant, Teresa Trout, by sending copies of same to Defendant's last known
addresses by certified and regular mail and by posting the premises. Service is complete upon mailing.
BY THE COURT:
a . L)
Distribution list:
Michael T. McKeever, Esquire, Suite 5000 — BNY Independence Center, 701 Market Street,
Philadelphia, PA -19106-1532
TERESA TROUT, 2622 Mayfair Lane York, PA 17048
.771
1
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USPS Manifest Mailing System
Mailers Na rte & Address
KMC Law Group
701Market Street
SL71le 5000
Philadelphia; PA 19106;.. .
Article A/.:
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Permit Number
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Sequence Number:
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Type' Postage„
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Class:of:Mail ..
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Perkasie; PA`18944'
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Name and Address of Sender
3OLDBECK•
IUITE 5000
01 MARKET STREET
'HILADELPHIA, PA
9106-1532
Check type of mail or service: , Afflx Stamp Here
(If issued as a
0 Certified 0 Recorded Delivery (International) certificate of mailing,
0 COD 0 Registered or for additional copies
0 Delivery Confirmation 0 Return Receipt for Merchandise of this bill)
0 Express Mail 0 Signature Confirmation Postmark and
0 Insured Date of Receipt
Article Number
Addressee (Name, Street, City, State, & ZIP Code)
Postage Fee
Handling
Charge
Actual Value
if Registered
Insured
Value
Due Sender
if COD
DC
Fee
SC
Fee
SH
Fee
RD
Fee
RR
Fee
1.
BOROUGH OF LEMOYNE
665 Market Street
Lemoyne, PA 17043
PENNS LVANIA HOUSING
AGENC
211 No h Front Street
PO BO 415057
7 !NANCE
Poo.
2.
YELLUVV UUOK SAES AND uis 1 t-utu I iON
COMPANY INC.
c/o Amato and Lessa, P.C.
107 North Commerce Way
107
Bethlehem, PA 18017
Hamsbu
TENAN
508 He
Lemoyne,
g, PA 171
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PA 1704c
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Total Number of Piece
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Total Number of Pieces
Received at Post Office
Postmaster, Per (Name of receiving employee)
See Privacy Act Statement on Reverse
PS Form 3877, February 2002 (Page 1 of 2)
- •
Complete by Typewriter,Ank, or Ball Point Pen
CWD-6627 Cumberland County Sale Date: 03/12/2014
TERESA TROUT & BART A. TROUT
571/7_5'
Name and Address of Sender
;OLDBECK(If
>UITE 5000
.01 MARKET STREET
'HILADELPHIA, PA
9106-1532
Check type of mail or service:
❑Certified ❑ Recorded Delivery (International)
0 COD 0 Registered
0 Delivery Confirmation 0 Return Receipt for Merchandise
0 Express Mail 0 Signature Confirmation
0 Insured
Affix Stamp Here
Issued as a
certificate of
or for additional
of this bili)
Postmark and
Date of Rece
mailing,
copies
pt
Article Number
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PA DEPARTMENT OF PUBLIC WELFARE -
Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
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06
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Harrisburg, PA 1 /1O5 -261b
DOMESTIC RELATIONS OF CUMBERLAND
PO Box 320
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3.
Carlisle, PA 17013
MORTGAGE ELECTRONIC REGISTRATION
SYSTEMS
4.
8201 CREENSDORO-DR-VE
SUITE 350
MCLEAN, VA 22102
MORTGAGE ELECTRONIC REGISTRATION
5
SYSTL VIS, INC
3300 SW 34TH AVENUE
SUITE 101
OCALA, FL 34474
6.
MORTGAGE ELECTRONIC REGISTRATION
SYSTEMS
C/0 PHELAN HALLINAN & SCHMIEG, LLP
1617 JFK Boulevard STE 1400
7
Philadelphia, PA 19103
MORTGAGE ELECTRONIC REGISTRATION
SYSTEMS, INC
P.O. Box 2026
8.
Flint, MI 48501
Total Number of Pieces
Usted by Sender �v
Total Number of Pieces
Received at Post Office'Jj_;
Postmaster, Per (Name of receiving employees`
See Privacy Act Statement on Reverse
PS Form 3877, February 2002 (Page 2 of 2)
Complete by Typewri
CWD-6627 Cumberland County Sale Date: 03/12/2014
TERESA TROUT & BART A. TROUT
4 +
~Point Pen
Name and Address of Sender
(ML LAW GROUP, P.C.
'UITE 5000
►01 MARKET STREET
!HILADELPHIA, PA
19106-1532
Check type of mail or service;
0 Certified 0 Recorded Delivery (International)
0 COD 0 Registered
❑ Delivery Confirmation 0 Return Receipt for Merchandise
❑ Express Mail 0 Signature Confirmation
0 Insured
Affix Stamp Here
(If issuedasa
certificate of mailing,
or for additional copies
of this bill)
Postmark and
Date of Receipt
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Article Number
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Postage
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1 •
MONICA HOFFMAN
344 Herman Avenue
Lemoyne, PA 17043
2.
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Total Number of Pieces
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Total Number of Pieces
Received at Post Office
Postmaster, Per (a a of ceiving employee)
See Privacy Act Statement on Reverse
PS Form 3877, February 2002 (Page 1 of 2)
CWD-6627 Cumberland County Sale Date: 0 J1 /2014
TERESA TROUT & BART A. TROUT
Complete by Typewriter, Ink, or Bali Point Pen
KML LAW GROUP, P.C.
Suite 5000 — BNY Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6320
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF THE
CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-
HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
vs.
TERESA TROUT
BART A. TROUT
Mortgagor(s) and Record Owner(s)
508 Herman Avenue
Lemoyne, PA 17043
Defendant(s)
Plaintiff
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 06-6670
SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE ON BEHALF OF THE
CERTIFICATE HOLDERS OF MORGAN STANLEY ABS CAPITAL I INC. TRUST 2004-HE9, MORTGAGE
PASS THROUGH CERTIFICATES, SERIES 2004 HE9, Plaintiff in the above action, by and through an
authorized employee of its attorneys, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of
execution was filed the following information concerning the real property located at:
508 Herman Avenue
Lemoyne, PA 17043
1.Name and address of Owner(s) or Reputed Owner(s):
TERESA TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
BART A. TROUT
594 Old York Rd Trlr 19
Etters, PA 17319
2. Name and address of Defendant(s) in the judgment:
TERESA TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
BART A. TROUT
594 Old York Rd Trlr 19
Etters, PA 17319
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be
sold:
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS
8201 GREENSBORO DRIVE
SUITE 350
MCLEAN, VA 22102
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC
3300 SW 34TH AVENUE
SUITE 101
OCALA, FL 34474
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS
CIO PHELAN HALLINAN & SCHMIEG, LLP
1617 JFK Boulevard STE 1400
Philadelphia, PA 19103
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC
P.O. Box 2026
Flint, MI 48501
BOROUGH OF LEMOYNE
665 Market Street
Lemoyne, PA 17043
YELLOW BOOK SALES AND DISTRIBUTION COMPANY INC.
c/o Amato and Lessa, P.C.
107 North Commerce Way
Bethlehem, PA 18017
MONICA HOFFMAN
344 Herman Avenue
Lemoyne, PA 17043
4. Name and address of the last recorded holder of every mortgage of record:
PENNSYLVANIA HOUSING FINANCE AGENCY
211 North Front Street
PO BOX 15057
Harrisburg, PA 17101
5. Name and address of every other person who has any record interest in or record lien on the property and
whose interest may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in
the property which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the
property which may be affected by the sale.
TENANTS/OCCUPANTS
508 Herman Avenue
Lemoyne, PA 17043
TRACY BURDULIS-TROUT
38 GOLFVIEW ROAD
CAMP HILL, PA 17011
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the penalties of
18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities.
DATED: May 21, 2014
KML Law Group, P.C.
BY: Veronica Cosme
Legal Assistant
KML LAW GROUP, P.C.
Suite 5000 - BNY Independence Center
701 Market Street
Philadelphia, PA 19106-1532
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF
THE CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-
HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
vs.
TERESA TROUT
BART A. TROUT
Mortgagor(s) and Record Owner(s)
508 Herman Avenue
Lemoyne, PA 17043
IN THE COURT OF COMMON PLEAS
of Cumberland County
No. 06-6670 y ,
Cr) n�
�7 '-
77,
C-` W
Defendant(s)
MOTION TO POSTPONE SHERIFF'S SALE
Plaintiff, DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE ON
BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN STANLEY ABS CAPITAL I INC.
TRUST 2004-HE9, MORTGAGE PASS THROUGH CERl'lloICATES, SERIES 2004 HE9, by
and through its attorneys, in support of its Motion to Postpone Sheriffs Sale represents as follows:
1. Plaintiff is the holder of a mortgage upon the premises, 508 Herman Avenue Lemoyne,
PA 17043, hereinafter the "mortgaged premises."
2. Defendant(s) are the mortgagor(s) and record owner(s) of the mortgaged premises.
3. A Sheriffs Sale of the mortgaged premises was scheduled for March 12, 2014 and was
postponed to May 7, 2014; then further postponed to July 7, 2014 in order to exhaust all non -
foreclosure alternatives.
4. Plaintiff requests an additional postponement until September 03, 2014 in order to
continue exhausting all non -foreclosure alternatives.
5. There is no prejudice to any party.
6. The instant matter was assigned to the Honorable Kevin A. Hess, P.J.
7. The defendants are unrepresented by counsel and the Plaintiff has no other means to
seek concurrence in the instant motion except by mail.
WHEREFORE, Plaintiff requests that the Court enter Plaintiffs proposed order, which will
postpone the sale until September 03, 2014.
Respectfully submitted,
By:
CKML LAW GROU .
Michael McKeever Pa. ID 56129
Jay E. Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Jill P. Jenkins Pa. ID 306588
Alyk L. Oflazian Pa. ID 312912
Salvatore Filippello Pa. ID 313897
Attorneys for Plaintiff
By:
0yadnC GueiP
Nathan Wolf, Esquire a. ID87380
Local nsel for Plaintiff
KML LAW GROUP, P.C.
Suite 5000 - BNY Independence Center
701 Market Street
Philadelphia, PA 19106-1532
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE ON BEHALF OF THE CERTIFICATE
HOLDERS OF MORGAN STANLEY ABS CAPITAL I
INC. TRUST 200441E9, MORTGAGE PASS
THROUGH CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024 Plaintiff
vs.
TERESA TROUT and BART A. TROUT
Mortgagor(s) and Record Owner(s)
508 Herman Avenue
Lemoyne, PA 17043
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
No. 06-6670
Defendant(s)
MEMORANDUM OF LAW
Pennsylvania Rule of Civil Procedure 3129.3(b) allows a judgment creditor to postpone a
sheriffs sale up to -two times within a one hundred thirty day period without new notice. The
postponement must be announced to all assembled bidders. As outlined in the attached motion, the
Sheriffs Sale has already been postponed as allowed by. Pa.R.C.P. 3129.3(b). Plaintiff seeks Court
approval under, inter alia, Pa.R.C.P. 126, to postpone the sale again. This postponement will be
announced to all assembled bidders.
CONCLUSION
For all the reasons discussed above and in the attached Motion, the Court should enter the
attached Order postponing the Sheriff's Sale.
Respectfully submitted,
By:
KML LAW GROUP, P.0
Michael McKeever Pa. ID
Jay E. Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Jill P. Jenkins Pa. ID 306588
Alyk L. Oflazian Pa. ID 312912
Salvatore Filippello Pa. ID 313897
A grneys for Plaintif
6129
By:
Nathan C. 1olf, Esquire Pa. ID8780
Local Counsel for Plaintiff
47' GUthas- C, J/o%j
KML LAW GROUP, P.C.
Suite 5000 - BNY Independence Center
701 Market Street
Philadelphia, PA 19106-1532
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF
THE CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-
HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024"
Plaintiff
vs.
TERESA TROUT and BART A. TROUT
Mortgagor(s) and Record Owner(s)
508 Herman Avenue
Lemoyne, PA 17043
IN THE COURT OF COMMON PLEAS
OF Cumberland County
No. 06-6670
Defendant(s)
CERTIFICATE OF SERVICE
Genevieve Mautz, an employee of KML LAW GROUP, P.C., counsel for Plaintiff, hereby
certifies that a copy of Plaintiffs Motion to Postpone Sheriff's Sale was mailed by first class mail,
postage prepaid, to Defendant(s) on July 1, 2014.
TERESA TROUT, 508 Herman Avenue Lemoyne, PA 17043-1822
BART A. TROUT, 594 Old York Rd Trlr 19 Etters, PA 17319
TERESA TROUT, 2622 Mayfair Ln York, PA 17048
BART A. TROUT, 508 Herman Avenue Lemoyne, PA 17043-1822
BART A. TROUT, 2622 Mayfair Ln York, PA 17408
Respectfully submitted,
KML LAW GROUP, P.C.
By:
Genevieve Mautz, mal Assistant
Tel: 215-825-6364
VERIFICATION
----- - - -
I 1 -
Salvatore Filippello, Esquire, hereby states that he/she is the attorney for Plaintiff herein,
and that all of the facts set forth within the attached Motion to Postpone Sheriffs Sale are true and
correct to the best of his/her information and belief. The undersigned understands that the foregoing
statements are made subject to the penalties of 18 Pa. C.S.A. § 4904.
Respectfully submitted,
By:
KML LAW GROUP, P
Michael McKeever Pa. I
Jay E. Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Jill P. Jenkins Pa. ID 306588
Alyk L. Oflazian Pa. ID 312912
X., Salvatore Filippello Pa. ID 313897
Attorneys for Plaintiff
129
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF THE
CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-
HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
vs.
TERESA TROUT and BART A. TROUT
Mortgagor(s) and Record Owner(s)
508 Herman Avenue
Lemoyne, PA 17043
Defendant(s)"
IN THE COURT OF COMMON
PLEAS
OF Cumberland County
No. 06-6670
ORDER
AND NOW, this S"f day of 7v, V , 2014 upon consideration of
Plaintiffs Motion to Postpone Sheriffs Sale and any response thereto, it is hereby
ORDERED and DECREED:
That the Motion is granted and the Sheriffs Sale of the subject property, located at 508
Herman Avenue Lemoyne, PA 17043 is postponed until September 03, 2014, without need for
further notice, costs, and advertising.
Coai€s /721u.
"*F-LV cab
Te 44- 7 f
Iti .d-
71/iy
BY THE COURT:
i q.rcl l ,-1 ^ s r'".2d l r
Dano CIN'-V381r,►f13
:Z Wd 1 -dill r1�1,
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
FIL
it I HE Pf 3 i t1O;`t'l r.
r•r:,
SEP 10 PM 2: 3
CUMBERLAND COUNTY
PENNSYLVANIA
Duetsche Bank National Trust Company
vs.
Bart Trout (et al.)
Case Number
2006-6670
SHERIFF'S RETURN OF SERVICE
01/09/2014 11:46 AM - Deputy Dennis Fry, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the
above titled action, upon the property located at 508 Herman Avenue, Lemoyne Borough, Lemoyne, PA
17043, Cumberland County.
03/07/2014 As directed by Michael McKeever, Attorney for the Plaintiff, Sheriffs Sale Continued to 5/7/2014
04/30/2014 As directed by Michael McKeever, Attorney for the Plaintiff, Sheriffs Sale Continued to 7/2/2014
07/01/2014 As directed by Michael McKeever, Attorney for the Plaintiff, Sheriffs Sale Continued to 9/3/2014
09/02/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed",
per letter of instruction from Attorney.
SHERIFF COST: $744.75 SO ANSWERS,
September 05, 2014 RONNY R ANDERSON, SHERIFF
rot(.
4 97fr
3/04,/
(c) CountySude Sheriff.' T'eleosoft. Enc.
On November 25, 2013 the Sheriff levied upon the
defendant's interest in the real property situated in
Lemoyne Borough, Cumberland County, PA,
Known and numbered as, 508 Herman Avenue,
Lemoyne, as Exhibit "A" filed with this writ and by
this Reference incorporated herein.
Date: November 25, 2013
By:
C
Real Estate Coordinator
LXIII 4 CUMBERLAND LAW JOURNAL 01/24/14
Writ No. 2006-6670 Civil Term
Duetsche Bank National Trust
Company
vs.
Bart Trout
Teresa Trout
Atty.: Michael McKeever
IMPROVEMENTS consist of a
residential dwelling.
BEING PREMISES: 508 Herman
Avenue, Lemoyne, PA 17043.
SOLD as the property of TERESA
TROUT and BART A. TROUT.
TAX PARCEL #12-22-0822-158.
76
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:
January 24, January 31, and February 7, 2014
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.
Lisa Marie Coyne,) Editor
SWORN TO AND SUBSCRIBED before me this
7 day of February, 2014
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH, CUMBERLAND COUNTY
My Commission Expires Apr 28, 2014
The ,Patriot -News Co.
2620 Technology Pkwy
Suite 300
Mechanicsburg, PA 17050
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
the lJatriot*Xews
Now you know
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
Marianne Miller, being duly sworn according to law, deposes and says:
That she 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 2020 Technology Pkwy, Suite 300, in the
Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday
Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, 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/ Community Weekly editions which appeared on the date(s) indicated below. That neither she 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 she 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
2006-6(70 Civil Term
Daetsche Bank National
Trust Ccmpany
Vs
Bart Trout
Teresa Trout
Atty: Michael McKeever
IMPROVEMENTS
residential dwelling.
BEING PREMISES: 508 Herman
Avenue
Lemoyne, PA 17043
SOLD as the property of TERESA
TROUT and BART A. TROUT
TAX PARCEL #12-22-0822-158
This ad ran on the date(s) shown below:
01/19/14
01126/14
02/02/14
consist of a Svforn to . nd subscribed before , e t
s 18 day of February, 2014 A.D.
COMMONWEALTH i OF PENNSYLVANIA
Notarial Seal
Holly Lynn Warfel, Notary Public
Washington Twp., Dauphin County
My Commission Expires Dec. 12, 2016
MEMBER. PENNSYLVANIA ASSOCIATION OF NOTARIES
PRAECIPE FOR WRIT OF EXECU11ON - (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
KML Law Group,
Suite 5000 - BNY Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUS l'hE ON BEHALF OF THE CERTIFICA lb
HOLDERS OF MORGAN STANLEY ABS CAPITAL I
INC. TRUST 2004-HE9, MORTGAGE PASS
THROUGH CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
vs.
FERESA TROUT
BART A. TROUT
Mortgagor(s) and Record Owner(s)
508 Heiman Avenue
Lemoyne, PA 17043
Plaintiff
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION — LAW
ACTION OF MORTGAGE FORECLOSURE
No. 06-6670
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
" "
"
00 Li. 14
‘si 0 Ll
131.1k " kt
U
/444/Sk4
00 "
0.,
Interest from
6/21/200.8 to Date of
Sale per diem at
$20.91
(Costs to be added)
(4
By:
$120,429.74
KML LAW ROUP, P.C.
Michael McKeever Pa. ID 56129
Jay E. Kivitz Pa. ID 26769
Lisa Lee P. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. 205047
Jill P. Jenkins Pa. ID 306588
Attorneys for Plaintiff
St)13 'iliN\i•W' ?OM gi()1 z
R-w2A rr3 (i):1
WRIT OF EXECUTION — (MORTGAGE FORECLOSURE)
P.R.C.P. 3180-3183 AND Rule 3257
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF THE
CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-
HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
vs.
TERESA TROUT
BART A. TROUT
508 Herman Avenue
Lemoyne, PA 17043
In the Court of Common Pleas of
Cumberland County
No. 06-6670
WRIT OF EXECUTION
(MORTGAGE FORECLOSURE)
Commonwealth of Pennsylvania:
County of Cumberland
To the Sheriff of Cumberland County, Pennsylvania
To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the
following described property:
PREMISES: 508 Herman Avenue Lemoyne, PA 17043
See Exhibit "A" attached
AMOUNT DUE $120,429.74
Interest From 6/21/2008
Through Date of Sale per diem at $20.91
(Costs to be added)
Dated: Prothonotary, Common Pleas Court -. .
of Cumberland County, Pennsylvania
Deputy
ALL that certain or parcel of land and premises, situate, lying and being in the Borough
of Lemoyne, in the County of Cumberland and Commonwealth of Pennsylvania, more
particularly described as follows, being Lot No. 64 and the western one-half of Lot No.
65, Section "D", on the Plan of Riverton, said Plan being recorded in the Cumberland
County Recorder's Office in Deed Book "C", Volume 11, Page 589, more particularly
bounded and described as follows:
BEGINNING at a point on the southern line of Herman Avenue, said point located 57.5
feet measured westwardly along the southern line of Herman Avenue from the southwest
corner of Herman Avenue and Fifth Street; thence in a southerly direction through the
center of the partition wall of a double two and one-half story frame dwelling house, a
distance of 150 feet to Plum Alley; thence along the northern side of Plum Alley, a
distance of 52.5 feet to a point on the dividing line between Lot Nos. 63 and 64 on said
Plan; thence along said dividing line in a northerly direction, a distance of 150 feet to a
point on the southern side of Herman Avenue; thence in an easterly direction along the
southern side of Herman Avenue a distance of 52.5 feet to a point, the place of
BEGINNING.
HAVING thereon erected the western one-half of a double two one-half story frame
dwelling house as 508 Herman Avenue, Lemoyne Pennsylvania.
IMPROVEMENTS consist of a residential dwelling.
MUNICIPALITY BOROUGH OF LEMOYNE
BEING PREMISES: as 508 Herman Avenue, Lemoyne PA 17043
SOLD as the property of BART A. TROUT AND TERESA TROUT
TAX PARCEL #12-22-0822-158
BEING the same premises which Jeffrey A. Niblett and Julie A. Niblett, husband and wife
and Kenneth W. Niblett, single man by deed dated 7/13/2004 and recorded 7/27/2004 in
Cumberland County in Deed Book Volume 264 at Page 1786 granted and conveyed unto
Bart A. Trout and Teresa Trout, husband and wife.
r "
KML Law Group, P.C.
Suite 5000 — BNY Independence Center
701 Market Street
Philadelplza� 1?A 19106=��32 "`""'
215-627-1322
Attorney for Plaintiff
FILED—OFFICE
OF THE PROTHONOTAI 'i'
ZO11NOV 13 riti 11:15
CM3_fEI_a: 0 COUNTY
UL Z:T)[yLVA(gYIA
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF THE
CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-HE9,
MORTGAGE PASS THROUGH CERTIFICATES,
SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
vs.
TERESA TROUT
BART A. TROUT
(Mortgagor(s) and Record Owner(s))
508 Herman Avenue
Lemoyne, PA 17043
Plaintiff
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 06-6670
AFFIDAVIT PURSUANT TO RULE 3129
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE ON BEHALF OF THE CERTIFICATE
HOLDERS OF MORGAN STANLEY ABS CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9, Plaintiff in the above action, by counsel, KML Law Group, P.C., sets forth as of the
date the praecipe for the writ of execution was filed the following information concerning the real property located at:
508 Herman Avenue
Lemoyne, PA 17043
1.Name and address of Owner(s) or Reputed Owner(s):
TERESA TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
TERESA TROUT
2622 Mayfair Lane
York, PA 17048
BART A. TROUT
594 Old York Rd Trlr 19
Etters, PA 17319
2. Name and address of Defendant(s) in the judgment:
TERESA TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
TERESA TROUT
2622 Mayfair Lane
York, PA 17048
BART A. TROUT
594 Old York Rd Trlr 19
Etters, PA 17319
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
MORTGAGE ELECTRONIC REGISTRATION SYS 1'bMS
8201 GREENSBORO DRIVE
SUI 1'h 350
MCLEAN, VA 22102
MORTGAGE ELECTRONIC REGISTRATION SYS 1'hMS, INC
3300 SW 34TH AVENUE
SUITE 101
OCALA, FL 34474
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS
C/0 PHELAN HALLINAN & SCHMIEG, LLP
1617 JFK Boulevard STE 1400
Philadelphia, PA 19103
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC
P.O. Box 2026
Flint, MI 48501
BOROUGH OF LEMOYNE
665 Market Street
Lemoyne, PA 17043
YELLOW BOOK SALES AND DISTRIBUTION COMPANY INC.
c/o Amato and Lessa, P.C.
107 North Commerce Way
Bethlehem, PA 18017
MONICA HOFFMAN
344 Herman Avenue
Lemoyne, PA 17043
4. Name and address of the last recorded holder of every mortgage of record:
PENNSYLVANIA HOUSING FINANCE AGENCY
211 North Front Street
PO 130X 15057
Harrisburg, PA 17101
5. Name and -address of every other person who has any record interest in or record lien on the property -and whose interest -
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS,.
508 Herman Avenue
Lemoyne, PA 17043
TRACY BURDULIS-TROUT
38 GOLFVIEW ROAD
CAMP HILL, PA 17011
I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
DATED:
((A2 -,(11q
By:
KML LAW QRO'CJP, P.C.
Michael McKeever Pa. ID 56129
Jay E. Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. 205047
Jill P. Jenkins Pa. ID 306588
Attorneys for Plaintiff
Tfol -49[(90
FILED -OFFICE
KMIL Law Group, P.C. OF THE FIXTIIONOTAG
suite-5000-13N-Yinde*dence-&nter
701 Market street 2014 NOV 13 Ali 11: 15
Philadelphia, PA 19106
(215) 627-1322 CIS•;BERLAI:0 COUNTY
Attorney for Plaintiff PEI1NSYL AMA.
06-6670
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE
ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN IN THE COURT OF COMMON PLEAS
STANLEY ABS CAPITAL I INC. TRUST 2004-HE9, MORTGAGE
PASS THROUGH CERTIFICATES, SERIES 2004 HE9 of Cumberland County
7105 Corporate Drive
PTX C-35
Plano, TX 75024 CIVIL ACTION - LAW
vs,
TERESA TROUT
BART A. TROUT
Mortgagor(s) and Record Owner(s)
508 Herman Avenue
Lemoyne, PA 17043
Plaintiff
Defendant(s)
ACTION OF MORTGAGE FORECLOSURE
Docket No. 06-6670
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: TROUT, TERESA
TERESA TROUT
508 Herman Avenue
Lemoyne, PA 17043-1822
Your house at 508 Herman Avenue, Lemoyne, PA 17043 is scheduled to be sold at Sheriffs Sale
on Wednesday, March 04, 2015, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to
enforce the court judgment of $120,429.74 obtained by DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH
CERTIFICA lbS, SERIES 2004 HE9 against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
06-6670
The'sale-will'be-canceled ifyourpay to -DEUTSCHE BANK NATIONAL TRUST -COMPANY ------
AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN STANLEY ABS
CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2004
HE9, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you
must pay call our office at 215-825-6329 or 1-866-413-2311.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by
calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of
your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened,
you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never
happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the
buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid
for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will
be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed
distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale.
8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/
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
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
06-6670
Resources-available-forHo eo n rs Foreclosnre
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: or 717-243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website
http://www.phfa.org/consumers/homeowners/real.aspx.
5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at
homeretention@krnllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825-
6429. The figure and/or package you requested will be mailed to the address that you
request or faxed if you leave a message with that information. The attorney in charge of
our firm's Homeowner Retention Department is David Fein who can be reached at 215-
825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of CWD-
6627.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
KML Law Group, P.C.
701 Market Street
Philadelphia, PA 19106
(215) 627-1322
Attorney for Plaintiff
I
,
NO TAR Y
2'14 NOV 13 1
COUN T/
IA A
06-6670
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE
ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-HE9, MORTGAGE
PASS THROUGH CERTIFICATES, SERIES 2004 HE9
7105 Corporate Drive
PTX C-35
Plano, TX 75024
vs.
TERESA TROUT
BART A. TROUT
Mortgagor(s) and Record Owner(s)
508 Herman Avenue
Lemoyne, PA 17043
Plaintiff
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CP/IL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Docket No. 06-6670
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: TROUT, BART A.
BART A. TROUT
508 Herman Avenue
Lemoyne, PA 17043
Your house at 508 Herman Avenue, Lemoyne, PA 17043 is scheduled to be sold at Sheriffs Sale
on Wednesday, March 04, 2015, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to
enforce the court judgment of $120,429.74 obtained by DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUS FEE ON BEHALF OF THE CERTIFICATE HOLDERS OF MORGAN
STANLEY ABS CAPITAL I INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9 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:
Resources available for Homeowners-in-Forectosure
ACT NOW!
06-6670
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: or 717-243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website
http://www.phfa.org/consumers/homeowners/real.aspx.
5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at
homeretention@kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825-
6429. The figure and/or package you requested will be mailed to the address that you
request or faxed if you leave a message with that information. The attorney in charge of
our firm's Homeowner Retention Department is David Fein who can be reached at 215-
825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of CWD-
6627.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PA
DAVID D. BUELL, PROTHONOTARY
One Courthouse Square • Suite100 • Carlisle, PA • 17013
(717) 240-6195
www.ccpa.net
DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE ON BEHALF OF THE CERTIFICATE
HOLDERS OF MORGAN STANLEY ABS CAPITAL I
INC. TRUST 2004-HE9, MORTGAGE PASS THROUGH
CERTIFICATES, SERIES 2004 HE9
Vs. NO 06-6670 Civil Term
CIVIL ACTION — LAW
TERESA TROUT
BART A. TROUT
WRIT OF EXECUTION
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell
the following described property:
(1) See legal description.
(2) (Specifically describe personal property when judgment results from a mortgage covering
both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code)
NOTE: Description of property must be attached to the writ.
Amount Due: $120,429.74 L.L.:
Interest FROM 6/21/2008 TO DATE OF SALE PER DIEM AT $20.91
Atty's Comm:
Atty Paid: $2,912.22
Plaintiff Paid:
Date: 11/13/14
(Seal)
Due Prothy: $2.25
Other Costs:
David D. Buell, Prothonotary
. W/'e.2/2.e.47
Deputy
REQUESTING PARTY:
Name: JENNIFER FRECHIE, ESQUIRE
Address: KML LAW GROUP, P.C.
SUITE 5000-BNY INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ID No. 316160