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Home My WebLink About06-6954MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel 649 South Avenue, Unit 7 PO BOX 307 SECANE, PA 19018 (610) 328-2887 Attorney ID # 52634 #20154-CS CFC Attorney for Plaintiff LaSalle Bank, N.A. as Trustee : COURT OF COMMON PLEAS for the MLMI Trust Series 2006- : Cumberland COUNTY HE2 c/o Wilshire Credit Corporation 14523 SW Millikan Way, Suite 200 . Case No: Beaverton, OR 97005 Plaintiff VS. Wanda K. Showers 134 East North Street Carlisle, PA 17013 Defendant CIVIL ACTION - MORTGAGE FORECLOSURE a-1 CA L7?? THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE ADVISO You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELEGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Le han demandado a usted en la cone. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta a sentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea a visado que si usted no se defiende, la corte toma ra medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades o otros de rechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO VAYA EN PERSONA O TELEFONA A LA OFICINA ESCRITA ABAJO. ESTA OFICINA LE PUEDE PROVEER INFORMACION SOBRE COMO CONTRATAR A UN ABOGADO. SI USTED NO TIENE EL DINERO SUFICIENTE PARA CONTRATAR A UN ABOGADO, LE PODEMOS DAR INFORMACION SOBRE AGENCIAS QUE PROVEEN SERVICIO LEGAL A PERSONAS ELEGIBLE PARA SERVICIOS A COSTO REDUCIDO O GRATUITO. %-viviur,l%l.11141J k,UUly 1 Y 15AK AJJUUTA I IUN 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 -- 800-990-9108 THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15. U.S.C. §1692, et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY(30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel 649 South Avenue, Unit 7 PO BOX 307 SECANE, PA 19018 (610) 328-2887 Attorney ID # 52634 Attorney for Plaintiff LaSalle Bank, N.A. as Trustee : COURT OF COMMON PLEAS for the MLMI Trust Series 2006- : Cumberland COUNTY HE2 c/o Wilshire Credit Corporation 14523 SW Millikan Way, Suite 200 : Case No: C)L - (oQS?f Beaverton, OR 97005 Plaintiff VS. Wanda K. Showers 134 East North Street Carlisle, PA 17013 Defendant 611,JL L"-? CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE 1. Plaintiff is LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE2, a bank organized and existing under state law, with offices for the conduct of business c/o their servicing agent, Wilshire Credit Corporation at 14523 SW Millikan Way, Suite 200, Beaverton, OR 97005. 2. Defendant, Wanda K. Showers is the mortgagor and real owner of premises 134 East North Street, Carlisle, PA 17013, hereinafter described, whose last known address is listed in the caption. 3. Plaintiff brings this action in mortgage foreclosure against defendant, mortgagor and real owner, to foreclose a ` certain indenture of mortgage made, executed and delivered by the above named defendant, mortgagor and real owner to First Horizon Home Loan Corporation on October 31, 2005, which mortgage was recorded on October 31, 2005 in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1928, Page 4900, secured on premises 134 East North Street, Carlisle, PA 17013 a true and correct description of which is attached hereto as Exhibit I. 4. The mortgage has since been assigned to the plaintiff herein. 5. Plaintiff alleges each and every term, condition and covenant in the aforesaid mortgage, and hereby incorporates them herein by reference thereto. 6. The aforesaid mortgage is in default in that monthly installments of principal and interest have not been made conformity with the terms of the mortgage, from August 2006 and each month thereafter, up to and including the present time. 7. Under the terms of the aforesaid mortgage, upon default of payments set forth in the mortgage documents, the entire principal balance and all interest due thereon are collectible forthwith. 8. The following is an itemized statement of the amount due plaintiff under the terms of the aforesaid mortgage: Principal Balance $69,600.00 Interest from 07/01/06 to 12/01/06 At $13.35 per diem $ 2,055.90 Accrued late charges to 12/01/06 $ 142.10 ' Accrued Escrow deficit to 12/01/06 $ 224.88 Corporate Advances $ 220.50 Attorney's fee (50 of unpaid Principal Balance) $ 3,480.00 Title Information Certificate $ 515.00 Photostats and Postage $ 50.00 Notarizations $ 10.00 Suspense Balance ($ 49.20) TOTAL $76,249.24 9. The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania Law and will be collected in the event of a third party purchaser at Sheriff's sale. If the mortgage is reinstated prior to the Sheriff's sale, reasonable attorney's fees will be charged based on work actually performed. 10. Plaintiff sent to defendants, mortgagors and real owners a combined Notice and Warning of Intention to Foreclose and Notices of Homeowners' Emergency Mortgage Assistance Act of 1983 advising of rights available under the statutes. To date payments have not been received and Act 91 assistance has not been granted although the applicable time periods provided by statute have expired (Exhibit II). WHEREFORE, plaintiff demands judgment for foreclosure and sale of the mortgaged premises in the amount of $76,249.24, plus per diem interest at $13.35 from December 2, 006 to the date of judgment plus costs thereon. L? Martha E. Von Rosenstiel Attorney for Plaintiff VERIFICATION MARTHA E. VON ROSENSTIEL, ESQUIRE, of full age, verifies that she is the attorney for the plaintiff in the foregoing action; that she is authorized to make this verification on behalf of plaintiff; and that the statements made in the foregoing Complaint in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. This verification is being executed by the attorney for plaintiff in accordance with Pa R.C.P. 1024(c) as a signed verification could not be obtained by plaintiff within the time allowed for filing of the pleading. I understand that false statements herein are made subject to penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. Martha E. Von Rosenstiel LEGAL DESCRIPTION rArtain erected that sit uate In r C lisleland Cum be la d the Comty, ?en nsylvania,? bounded and described as followst On the North by East North Street: on the East by property now of formerly of George Laley: on the South by Locust Alley and on the Not by pro Zty now or formerly of George N. Diehl; Containing ini depth two hundredf andtfortya (240) sfeet to ?9aid$Locust Alley on the uth. SLING improved with a two•stosy house and garage. BEING known and numbered as 134 Eau North street. ...Y EXHIBIT------ ? Wilshire- Wilshire Credit Corporation Payments P.O. Box 7195, Pasadena, CA 91109-7195 09/30/2006 L178D SHOWERS, WANDA K 134 E NORTH ST CARLISLE, PA 17013 ACT 91/6 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Phone 888.917.1052 888.917.1052 Fax 503.952.7476 Web Site www.wcc.ml.com The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save our 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 servingyour County are listed at the end of this Notice. If you have any questions you may call the Pennsylvania Housing Finance A ency toll free at 1-800-342-2397. (Persons with impaired hearing can call 717) 780-1869.) This notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRI;STAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL (Continued) Wilshire Credit Corporation is licensed to do business at 14523 S.W. Milliken Way, Beaverton, OR. YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: In Colorado, the Colorado Collection Agency Board, 1525 Sherman Street, Denver, CO 80203, licenses collection agencies. Payments should not be sent to the Board. If you inform us in writing that you refuse to pay this debt or request us to cease further communication, our final communications about our actions and intentions will be in writing. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed by the Collection Service Board, State Department of Commerce and Insurance. Wilshire's office hours are Monday - Friday 7:00 AM to 5:00 PM Pacific Standard Time L 178D EXHIBIT Correspondence P.O. Box 8517 Portland, OR 97207-8517 SHOWERS, WANDA K Page 2 DERECHO A REDIMIR SU HIPOTECA. HOMEOWNERS' NAME: PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT SERVICER: SHOWERS, WANDA K 134 E NORTH ST CARLISLE, PA 170132430 1825649 FIRST HORIZON Wilshire Credit Corporation HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT") YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face -to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. 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. (Continued) Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan Way, Beaverton, OR. YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: In Colorado, the Colorado Collection Agency Board, 1525 Sherman Street, Denver, CO 80203, licenses collection agencies. Payments should not be sent to the Board. If you inform us in writing that you refuse to pay this debt or request us to coast further communication, our final communications about our actions and intentions will be in writing. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed by the Collection Service Board, State Department of Commerce and Insurance. Wilshire's office hours are Monday - Friday 7:00 AM to 5:00 PM Pacific Standard Time L178D SHOWERS, WANDA K Page 3 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 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 they receive 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 (Briny- it up to date.) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 134 E NORTH ST CARLISLE, PA 170132430 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY PAYMENTS and the following amounts are past due: Delinquency $1,075.80 Late Charges $142.10 Other Charges $161.00 Suspense Amount -$49.20 TOTAL $1,329.70 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 $1,329.70 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (Continued) Wilshire Credit Corporation is licensed to do business at 14523 S. W. Millikan Way, Beaverton, OR. YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: In Colorado, the Colorado Collection Agency Board, 1525 Sherman Street, Denver, CO 80203, licenses collection agencies. Payments should not be sent to the Board. If you inform us in writing that you refuse to pay this debt or request us to cease furthcr communication, our final communications about uur acliuns and intentions will be in writing. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed by the Collection Service Board, State Department of Commerce and Insurance. Wilshire's office hours are Monday - Friday 7:00 AM to 5:00 PM Pacific Standard Time L178D SHOWERS, WANDA K Page 4 (30) DAY PERIOD. Payments must be made either by cashier's check certified check or mongy order made payable and sent to: Wilshire Credit Corporation, P.O. Box 7195, Pasadena, CA 91109-7195. 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 it's rights to accelerate the mortgage debt. This means that the entire outstanding balance of the 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 it's 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 it's 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 actually incurred by the lender even if they exceed $50.00. The 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 nay 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 -W to one hour before the Sheriffs Sale You may do so by paving the total amount then past due, any late or other charges then due reasonable attorney's fees any costs connected with the foreclosure sale, any other costs connected with the Sheriffs Sale as specified in writing by the lender, and by performing any other requirements under the mortgage Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment of action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Wilshire Credit Corporation Address: Pa ments: P.O. Box 7195, Pasadena, CA 91109-7195 Correspondence: P.O. Box 8517 Portland, OR 97207-8517 Phone: Toll Free: 888.917.1052 Fax Number: 503.952.7476 (Continued) Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan Way, Beaverton, OR. YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED BY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: In Colorado, the Colorado Collection Agency Board, 1525 Sherman Street, Denver, CO 80203, licenses collection agencies. Payments should not be sent to the Board. If you inform us in writing that you refuse to pay this debt or request us to oeasc further communication, our final communications about our actions and intentions will be in writing. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed by the Collection Service Board, State Department of Commerce and Insurance. Wilshire's office hours are Monday - Friday 7:00 AM to 5:00 PM Pacific Standard Time L178D 'SHOWERS, WANDA K Page 5 Contact: Loan Servicing EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may or may not 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 THE MORTGAGE 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. ATTACHED IS THE CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY If you have any questions regarding this matter, please do not hesitate to contact us at our toll free number above. Sincerely, Loan Servicing Wilshire Credit Corporation is licensed to do business at 14523 S.W. Millikan Way, Beaverton, OR. YOU SHOULD CONSIDER THIS LETTER AS COMING FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. ANY INFORMATION PROVIDED RY YOU WILL BE USED TO COLLECT THIS DEBT. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO: In Colorado, the Colorado Collection Agency Board, 1525 Sherman Street, Denver, CO 80203, licenses collection agencies. Payments should not be sent to the Board. If you inform us in writing that you refuse to pay this debt or request us to cease further communication, our final communications about our actions and intentions will be in writing. NEW YORK CITY: License 1032551. NORTH CAROLINA: Permit 3840. TENNESSEE: This collection agency is licensed by the Collection Service Board, State Department of Commerce and Insurance. Wilshire's office hours are Monday - Friday 7:00 AM to 5:00 PM Pacific Standard Time L178D r7i _ __ ,, {ern `` (010 jo -, Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 649 South Avenue, Suite 6 P.O. Box 307 Secane, PA 19018 610 328-2887 Attorney I.D.# 52634 #20154-TM CPG Attorney for Plaintiff LaSalle Bank, N.A. as Trustee for the MLMI COURT OF COMMON PLEAS Trust Series 2006-HE2 Cumberland COUNTY Plaintiff vs. Case No: 06-6954 Wanda K. Showers Defendant(s) PRAECIPE TO SUBSTITUTE VERIFCATION TO THE PROTHONOTARY: Kindly substitute the verification of Dory Goebel for the verification of Martha E. Von Rosenstiel attached to Plaintiff's Complaint in Mortgage Foreclosure t t was filed on or about December 4, 2006. Martha E. Von Rosenstiel, Esquire Attorney for Plaintiff Dated: December 14, 2006 R W* Loan #1825649 VERIFICATION _bcw? -2Lr :jf hereby states that he/she is the Authorized Agent of Wilshire Credit Corporation, attorney in fact for (LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE2), plaintiff herein; that he/she is duly authorized to make this Verification on behalf of Plaintiff and verifies that the statements made in the foregoing pleading/document are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Title: A z orIzea /?gT Wilshire Cre it Corporation, attorney-in- fact for (LaSa Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE2), Plaintiff Dated: 12/1/06 x.._») ..J rt ~t CZ) - ? Ci 1 #20154-TM CFJ (default judgment) Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 649 South Avenue, Unit 7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney I.D.# 52634 LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE2 c/o Wilshire Credit Corporation 14523 SW Millikan Way, Suite 200 Beaverton OR 97005 Plaintiff VS. Wanda K. Showers 134 East North Street Carlisle, PA 17013 Defendant Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY : No: 06-6954 PRAECIPE TO THE PROTHONOTARY: Enter judgment in the sum of $76,863.34 in favor of the above named plaintiff and against the above named defendant for failure to file an answer in the above action in Mortgage Foreclosure within twenty (20) days from date of service of the Civil Action, and assess damages. I hereby certify that the correct addresses of plaintiff and defendant are as follows: Plaintiff. c/o Wilshire Credit Corporation 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005 Defendants: 134 East North Street Carlisle, PA 17013 E. Von Rosenstiel v for Plaintiff Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 649 South Avenue, Unit 7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney I.D.# 52634 LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE2 c/o Wilshire Credit Corporation 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005 Plaintiff VS. Wanda K. Showers 134 East North Street Carlisle, PA 17013 Defendant Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 06-6954 ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess damages against the above named defendant as per Civil Action in Mortgage Foreclosure, as follows: Total per complaint Additional interest on unpaid balances from 12/2/06 to 1/16/07 at $13.35 per diem $76,249.24 $ 614.10 Total assessment AND NOW, to wit, this day of $76,863.34 M rtha E. Von Rosenstiel A orney for Plaintiff 2007, damages are assessed as above. Pro Prothy w Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 649 South Avenue, Unit 7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney I.D.# 52634 LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE2 c/o Wilshire Credit Corporation 14523 SW Millikan Way, Suite 200 Beaverton OR 97005 Plaintiff vs. Wanda K. Showers 134 East North Street Carlisle, PA 17013 Defendant Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 06-6954 CERTIFICATION OF SERVICE MARTHA E. VON ROSENSTIEL, ESQUIRE, hereby certifies that she is the attorney for the plaintiff herein, and that service of the Notice under Rule 237.5 in the above matter was made on the defendants on January 2, 2007, as evidenced by the attached postal receipts. This verification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Martha E. Von Rosenstiel, Esquire Attorney for Plaintiff DATED: January 16, 2007 #20154-TM ?-( j- Martha,E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, P.C. 649 South Avenue, Suite 7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney I.D.# 52634 Attorney for Plaintiff LaSalle Bank, N.A. as Trustee for the MLMI Trust : Series 2006-HE2 c/o Wilshire Credit Corporation 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005 Plaintiff VS. Wanda K. Showers 134 East North Street Carlisle, PA 17013 Defendant TO: Wanda K. Showers 134 East North Street carlisle, PA 17013 Date of Notice: January 2, 2007 COURT OF COMMON PLEAS Cumberland COUNTY Case No: 06-6954 IMPORTANT NOTICE BOO pal YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 F Martha E. Von Rosenstiel Attorney for Plaintiff . acm vLl,n %-r1K i Ir IUATE OF MAIL] PpS MAY BE USED FOR t>OMESTIC AND rNTE DO OT PROV 4 Ar'- Tee nere m "Lamps Or meter postage and IDE FOR rNSLTRANCE-POSTMASTE E *Post mark. Inquire of Received From Trent -14TNry MARTHA VON RO 02 1P x.00266401 BOWES $ 000.950 649 SOUTH A JAN 03 MAILED FROM ZIP CODE 1 9018' UNIT 7 SECANE, PA 19018 One piece of ordinary mail addressed to: IN N F F n O 134 East North Street a PS Form 3817, Mar. 1989 #20154-TM MARTHA E. VON ROSENSTIEL, P.C. Attorney for Plaintiff Martha E. Von Rosenstiel 649 SOUTH AVENUE UNIT 7 SECANE, PA 19018 (610) 328-2887 Attorney ID # 5 2 63 4 LaSalle Bank, N.A. as Trustee COURT OF COMMON PLEAS for the MLMI Trust Series 2006- : Cumberland COUNTY HE2 c/o Wilshire Credit Corporation: 14523 SW Millikan Way, Suite 200 Case No: 06-6954 Beaverton, OR 97005 Plaintiff vs. Wanda K. Showers 134 East North Street Carlisle,PA 17013 Defendants NON-MILITARY AFFIDAVIT STATE OF PENNSYLVANIA COUNTY OF DELAWARE SS Martha E. Von Rosenstiel, Esquire, deposes and says: 1. That I am the attorney for the plaintiff herein. 2. That the individual involved in this action is the owner of the Premises described in the mortgage or deed of trust. 3. That the procedures of the Law Office of Martha E. Von Rosenstiel, P.C. are designed to discover facts concerning the military status of the mortgagor(s) and/or real owner(s). 46 4. That said procedures were followed in connection with the instant foreclosure proceeding. Inquiry made with the Department of Defense, has confirmed that the defendant(s) is/are not in the military. 6. That, on information and belief, named mortgagor(s) and real owner(s) is/are not incompetent nor a service member in military service as defined by the Servicemembers Civil Relief Act, 50 U.S.C. Appx. Section 501 et seq. This verification is made subject to the penalties of 18 Pa.C.S. §4904 relating to nsworn falsification to authorities. Martha E. Von Rosenstiel M r- N a P V i? ?s `-n E"13 (T? j a'r't i OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS ONE COURTHOUSE SQUARE CARLISLE, PA 17013 To: Wanda K. Showers 134 East North Street Carlisle, PA 17013 LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE2 V. Wanda K. Showers Docket# 06-6954 Notice Pursuant to Rule 236 of the Supreme Court of Pennsylvania. you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonota v 7 XXX Judgment by Default f L/p7 Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings If you have any questions concerning this notice, please call: Attorney: Martha E. Von Rosenstiel, Esquire at this telephone number: 610-328-2887 t' PRAECIPE FOR WRIT OF EXECUTION COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE2 V. Wanda K. Showers NO. 06-6954 Praecipe for Writ of Execution TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: AMOUNT DUE $76,863.34 INTEREST from 01/16/07 to SALE DATE At $12.64 per diem $ 1883.36 (Costs to be added) $ Marta E. Von Rosenstiel Attorney for Plaintiff 7v -t' ? a b ^Z RJ .,a V'? !? ? q to o ? a a a p C2 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected situate in Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: On the North by East North Street; on the East by property now or formerly of George Laley; on the South by Locust Alley and on the West by property now or formerly of George W. Diehl; containing thirty (30) feet in front of said East North Street and extending in depth two hundred and forty (240) feet to said Locust Alley on the South. BEING improved with a two-story house and garage. BEING known and numbered as 134 East North Street. TAX PARCEL #02-21-0318-243 TITLE TO SAID PREMISES IS VESTED IN Wanda K. Showers by Deed from Richard H. Cook and Arla M. Cook, his wife dated 10/31/2005 and recorded 10/31/2005 in Record Book 271, Page 3433. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-6954 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LASALLE BANK, N.A. AS TRUSTEE FOR THE MLMI TRUST SERIES 2006-HE2, Plaintiff (s) From WANDA K. SHOWERS (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 $76,863.34 L.L. $.50 Interest FROM 1/16/07 TO SALE DATE AT $12.64 PER DIEM - $1883.36 Atty's Comm % Atty Paid $114.40 Plaintiff Paid Date: FEBRUARY 13, 2007 (Seal) Due Prothy $1.00 Other Costs 1!??r5jrriyr el Curti . Long, P notary By: Deputy REQUESTING PARTY: Name MARTHA E. VON ROSENSTIEL, ESQUIRE Address: 649 SOUTH AVENUE, UNIT 7 P.O.BOX 307 SECANE, PA 19018 Attorney for: PLAINTIFF Telephone: 610-328-2887 Supreme Court ID No. 52634 .r Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 649 South Avenue, Unit 7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney I.D.# 52634 LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE2 c/o Wilshire Credit Corp 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005 Plaintiff vs. Wanda K. Showers 134 East North Street Carlisle, PA 17013 Defendant Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 06-6954 AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF DELAWARE SS MARTHA E. VON ROSENSTIEL, attorney for the plaintiff in the above action, sets forth as of the date the praecipe for the Writ of Execution was filed the following information concerning the real property located at 134 East North Street, Carlisle, PA 17013. 1. Name and address of owners(s) or reputed owner(s) Wanda K. Showers 134 East North Street Carlisle, PA 17013 2. Name and address of defendant(s) in the judgment: Wanda K. Showers 134 East North Street Carlisle, PA 17013 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NONE 4. Name and address of the last recorded holder of every mortgage of record: .% Mortgage Electronic Registration Systems, Inc. P.O. Box 2026 Flint, MI 48501-2026 5. Name and address of every other person who has any record lien on the property: NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, PA 17013 Cumberland County Register of Wills County Courthouse Carlisle, PA 17013 Attorney General of the United States c/o Assistant Attorney General, Tax Division U.S. Department of Justice Post Office Box 227 Washington, DC 20044 PA Department of Revenue Inheritance Tax Bureau Strawberry Square, 11th Floor Harrisburg, PA 17128-1100 Family Court/Domestic Relations Office One Courthouse Square Carlisle, PA 17013 Bureau of Compliance Clearance Support Section/ATTN: Sheriff's Sale Dept. 281230 Harrisburg, PA 17129-1230 Dept. of Public Welfare Box 2675 Harrisburg, PA 17105 OCCUPANTS/TENANTS 134 East North Street Carlisle, PA 17013 r 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. Martha E. Von Rosenstiel Attorney for Plaintiff r.? Pn Fn C ' ?? D, C: Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 649 South Avenue, Unit 7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney I.D.# 52634 LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE2 c/o Wilshire Credit Corp 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005 Plaintiff vs. Wanda K. Showers 134 East North Street Carlisle, PA 17013 Defendant Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY : No: 06-6954 CERTIFICATION I hereby certify that I am the attorney of record for the plaintiff in this action against real property, and further certify that the property is: ( ) FHA Tenant Occupied or Vacant ( ) Commercial ( ) As a result of a Complaint in Assumpsit (X) That the plaintiff has complied in all respects with Section 403 of the Mortgage Assistance Action Including but not limited to: (a) Service of the notice on defendants (b) Expiration of 30 days since service of the Notice (c) Defendants failure to request or appear at the meeting with the mortgagee or Consumer Counseling Agency (d) Defendants failure to file application with the Homeowners Emergency Assistance Program. I further agree to indemnify and hold harmless the Sheriff for any Martha E. Von Rosenstiel Attorney for Plaintiff Dated: February 1, 2007 given herein. U °? art '[3 '. ? cam, cXs -? t ??* g^ <.r ? '- ? ?' ?? s ? '?' C - '`. .--ti Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 649 South Avenue, Unit 7 P.O. Box 307 Attorney for Plaintiff Secane, PA 19018 (610) 328-2887 Attorney I.D.# 52634 LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE2 c/o Wilshire Credit Corp 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005 Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 06-6954 vs. Wanda K. Showers 134 East North Street Carlisle, PA 17013 Defendant THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Wanda K. Showers 134 East North Street Carlisle, PA 17013 Your house and/or real estate at 134 East North Street, Carlisle, PA 17013 is scheduled to be sold at Sheriff's Sale on June 13, 2007 at 10:00 a.m. to enforce the court judgment of $76,863.34 obtained by LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE2 against you. NOTICE OF OWNERS RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take IMMEDIATE action: 1. The sale will be cancelled if you pay to LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE2 the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call (610) 328-2887. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may contact an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling (610) 328-2887. 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 the 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 (610) 328-2887. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money, which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on a date to be announced by the Sheriff. 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 posted. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (800) 990-9108 (717) 249-3166 CLAIM FOR EXEMPTION To the Sheriff: I, the above named defendant, claim exemption of property from levy or attachment: (1) From my real property in my possession which has been levied upon, (a) I desire that my $300.00 statutory exemption be set-aside in kind (specify real property to be set-aside in kind): I request a prompt court hearing to determine the exemption. Notice of the hearing should be given to me at (Address) (Telephone Number) I verify that the statements made in this Claim for Exemption are true and correct. 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. Date: Signature THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 717 240-6391 MVR# 20154 cm WRIT OF EXECUTION _ (MORTGAGE FORECLOSURE) P.R.C.P. 3180 to 3183 and Rule 3257 LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE2 vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 06-6954 Civii Term Term, 20------- E.D. No Term, 20 - ----- A.D. Wanda K. Showers I WRIT OF EXECUTION (MORTGAGE FORECLOSURE) Commonwealth of Pennsylvania: County of 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 (specifically describe property below): PREMISES: 134 East North Street Carlisle, PA 17013 Amount Due Interest from 01/16/07 to Sale Date @ $12.64 per diem Attorney's fees Costs Total as endorsed. Dated (SEAL) $ 76,863.34 $ 1,883.36 By: Prothonotary, Common Pleas Court of Cumberland County, Penna. Deputy C'1 y ,b ,. r • O > w L CL H (0 N w A z a- (?D wb? a. CD ? w C 00 ?.o I `J 00 N K ? fi o ? n ? m ? K O r Q+ rt r- M CD cr ? ? °? rY C'7 O n Q va ?rf r, CD C N ,? N -? C7 o ° o v' ? ? c N b o x ? ?z O N C4 CD i z ? r ? [TJ ?? o N 0 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected situate in Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: On the North by East North Street; on the East by property now or formerly of George Laley; on the South by Locust Alley and on the West by property now or formerly of George W. Diehl; containing thirty (30) feet in front of said East North Street and extending in depth two hundred and forty (240) feet to said Locust Alley on the South. BEING improved with a two-story house and garage. BEING known and numbered as 134 East North Street. TAX PARCEL #02-21-0318-243 TITLE TO SAID PREMISES IS VESTED IN Wanda K. Showers by Deed from Richard H. Cook and Arla M. Cook, his wife dated 10/31/2005 and recorded 10/31/2005 in Record Book 271, Page 3433. G? ? -s? ?? r ??Y? ? T, _ p... .:. ? i«..' ? '? f? ?r 02/16/2007 11:10 MARTHA E. VON ROSENSTIEL P.C. 17172406397 NO.053 D01 MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAIN 649 SOUTH AVENUE, SUITE 7 SECANE, PA 19018 Martha E. Von Rosenstiel, Esquire Phone: (610) 328-2887 Leslie J. Rase, Esquire Fax: (610) 32&-2649 Ked P. Claeys, Esquire February 16, 2007 Sheriff of Cumberland County Real Estate Sales Court House Carlisle, PA 17013 FAX: 717-240-6397 ATTN: Jody RE: SALE DATE: MORTGAGOR: PREMISES: CRT.(TRM. #: OUR FILE M. Dear Jody: 611312007 Wanda K. Showers 134 East North Street 06-6954 20154 Please STA the Sheriffs Sale scheduled on the above captioned matter. No funds received. . Kindly send refund (if applicable) as soon as possible, along with a breakdown showing amounts expended. Thank you for your assistance in this matter. Sincerely yours, rr' M oVaAZet/ Trinity McDaniel Paralegal BY: Fax 1/06/2007: Qr" n.01 writ returned to the Prothonotary's ice. 3/06/2007: Cy of writ and $1,504.00 returned to v„ Attorney Von Posenstiel. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-6954 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LASALLE BANK, N.A. AS TRUSTEE FOR THE MLMI TRUST SERIES 2006-HE2, Plaintiff (s) From WANDA K. SHOWERS (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 $76,863.34 L.L. $.50 Interest FROM 1/16/07 TO SALE DATE AT $12.64 PER DIEM - $1883.36 Atty's Comm % Atty Paid $114.40 Plaintiff Paid Due Prothy $1.00 Other Costs Date: FEBRUARY 13, 2007 (Seal) Curti Long, Pr o ary By: Deputy REQUESTING PARTY: Name MARTHA E. VON ROSENSTIEL, ESQUIRE Address: 649 SOUTH AVENUE, UNIT 7 P.O.BOX 307 SECANE, PA 19018 Attorney for: PLAINTIFF Telephone: 610-328-2887 Supreme Court ID No. 52634 .., t ? t. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-6954 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LASALLE BANK, N.A. AS TRUSTEE FOR THE MLMI TRUST SERIES 2006-HE2, Plaintiff (s) From WANDA K. SHOWERS (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 $76,863.34 L.L. $.50 Interest FROM 1/16/07 TO SALE DATE AT $12.64 PER DIEM - $1883.36 Atty's Comm % Atty Paid $114.40 Plaintiff Paid Date: FEBRUARY 13, 2007 (Seal) Due Prothy $1.00 Other Costs 1 02K Cu 's R. Long,P k?l n tary By: Deputy REQUESTING PARTY: Name MARTHA E. VON ROSENSTIEL, ESQUIRE Address: 649 SOUTH AVENUE, UNIT 7 P.O.BOX 307 SECANE, PA 19018 Attorney for: PLAINTIFF Telephone: 610-328-2887 Supreme Court ID No. 52634 TM)L ? d-44 ??a 6 Q :j r ?Jl i WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-6954 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LASALLE BANK, N.A. AS TRUSTEE FOR THE MLMI TRUST SERIES 2006-HE2, Plaintiff (s) From WANDA K. SHOWERS (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 $76,863.34 L.L. $.50 Interest FROM 1/16/07 TO SALE DATE AT $12.64 PER DIEM - $1883.36 Atty's Comm % Atty Paid $114.40 Plaintiff Paid Date: FEBRUARY 13, 2007 (Seal) Due Prothy $1.00 Other Costs L Curti A Long, Pr o ry By: Deputy REQUESTING PARTY: Name MARTHA E. VON ROSENSTIEL, ESQUIRE Address: 649 SOUTH AVENUE, UNIT 7 P.O.BOX 307 SECANE, PA 19018 Attorney for: PLAINTIFF Telephone: 610-328-2887 Supreme Court ID No. 52634 SAWN be Aft ? ate, 0% u ?...? J s., .J _1 i.?? ? ,.. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-6954 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LASALLE BANK, N.A. AS TRUSTEE FOR THE MLMI TRUST SERIES 2006-HE2, Plaintiff (s) From WANDA K. SHOWERS (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 $76,863.34 L.L. $.50 Interest FROM 1/16/07 TO SALE DATE AT $12.64 PER DIEM - $1883.36 Atty's Comm % Atty Paid $114.40 Plaintiff Paid Date: FEBRUARY 13, 2007 (Seal) Due Prothy $1.00 Other Costs (Ilt - I A44 Curtis Long, Pro aryBy: Deputy REQUESTING PARTY: Name MARTHA E. VON ROSENSTIEL, ESQUIRE Address: 649 SOUTH AVENUE, UNIT 7 P.O.BOX 307 SECANE, PA 19018 Attorney for: PLAINTIFF Telephone: 610-328-2887 Supreme Court ID No. 52634 "a.% TFWL MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 649 SOUTH AVENUE, SUITE 7 SECANE, PA 19018 Martha E. Von Rosenstiel, Esquire Leslie J. Rase, Esquire Keri P. Claeys, Esquire Phone: (610) 328-2887 Fax: (610) 328-2649 February 1, 2007 Cumberland Sheriff's Office Real Estate Division 1 Courthouse Square Carlisle, PA 17013 RE: LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006- HE2 v. Wanda K. Showers 134 East North Street Carlisle, PA 17013 Docket# 0 6- 6 9 5 4 Our File# 20154 Dear Sir or Madam: Enclosed please find the documents necessary to schedule the above property for the June 13,'2007 date. Please make service on person(s) named AT ALL ADDRESSES INDICATED OR serve any adult in charze of premises and note name and relationship to defendant(s) on service return. Special service will be noted. Wanda K. Showers 134 East North Street Carlisle, PA 17013 I have enclosed a self-addressed stamped envelope for your convenience in returning the service forms. Thank you for your assistance in this matter. Sincerely yours, Ca4,o4 Lyww Meeh,a,w Carol Lynn Meehan Paralegal SHERIFF'S RETURN - REGULAR CASE NO: 2006-06954 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LASALLE BANK N A VS SHOWERS WANDA K SHAWN HARRISON Sheriff or Deputy Sheriff 'f Cumberland County,Pennsylvania, who being duly sworn acco li says, the within COMPLAINT - MORT FORE was served upo ? SHOWERS WANDA K DEFENDANT at 1952:00 HOURS, on the 7th day of Decp?kb at 134 EAST NORTH STREET CARLISLE, PA 17013 by handing to WANDA SHOWERS a true and attested copy of COMPLAINT - MORT FORE ng to law, the r , 2006 tog her with 11 and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 4.40 Affidavit 00 Qe-1 Surcharge 10.00 R. Thomas Kline .00 ? 32.40 12/12/2006 MARTHA VONROS TIEL i Sworn and Subscibed to By: before me this day Dep y Sheril of A.D. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE2 V. Wanda K. Showers NO. 06-6954 Praecipe for Writ of Execution TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: AMOUNT DUE $76,863.34 INTEREST from 01/16/07 to- 3/5/08 At $12.64 per diem $ 5,232.96 (Costs to be added) ? W U1 'O 0 $ ? 9V d C`? _ C? L, Olb Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 649 South Avenue, Unit 7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney I.D.# 52634 LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE2 c/o Wilshire Credit Corp 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005 Plaintiff vs. Wanda K. Showers 134 East North Street Carlisle, PA 17013 Defendant Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 06-6954 AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF DELAWARE MARTHA E. VON ROSENSTIEL, attorney for the plaintiff in the above action, sets forth as of the date the praecipe for the Writ of Execution was filed the following information concerning the real property located at 134 East North Street, Carlisle, PA 17013. 1. Name and address of owners(s) or reputed owner(s) Wanda K. Showers 134 East North Street Carlisle, PA 17013 2. Name and address of defendant(s) in the judgment: Wanda K. Showers 134 East North Street Carlisle, PA 17013 3. Name and address of the last recorded holder of every mortgage of record: Mortgage Electronic Registration Systems, Inc. P.O. Box 2026 Flint, MI 48501-2026 4. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, PA 17013 Cumberland County Register of Wills County Courthouse Carlisle, PA 17013 Attorney General of the United States c/o Assistant Attorney General, Tax Division U.S. Department of Justice Post Office Box 227 Washington, DC 20044 PA Department of Revenue Inheritance Tax Bureau Strawberry Square, 11 th Floor Harrisburg, PA 17128-1100 Family Court/Domestic Relations Office One Courthouse Square Carlisle, PA 17013 Bureau of Compliance Clearance Support Section/ATTN: Sheriffs Sale Dept. 281230 Harrisburg, PA 17129-1230 Dept. of Public Welfare Box 2675 Harrisburg, PA 17105 OCCUPANTS/TENANTS 134 East North Street Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ? r..,, s--? :? = `° _w c ? _. ? ... ,. CJ -! ?r- t-,1.., ? ? ? fS t ? j'.T1 .. _ _ _ ? ,? ,. i ? i """a ti ? ' ? ?? J f _ : y G) 4 ?-,. ' ?? ? i b. ? A Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 649 South Avenue, Unit 7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney I.D.# 52634 LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE2 c/o Wilshire Credit Corp 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005 Plaintiff vs. Wanda K. Showers 134 East North Street Carlisle, PA 17013 Defendant Attorney for Plaintiff : COURT OF COMMON PLEAS : CUMBERLAND COUNTY No: 06-6954 CERTIFICATION I hereby certify that I am the attorney of record for the plaintiff in this action against real property, and further certify that the property is: ( ) FHA Tenant Occupied or Vacant ( ) Commercial ( ) As a result of a Complaint in Assumpsit (X) That the plaintiff has complied in all respects with Section 403 of the Mortgage Assistance Action Including but not limited to: (a) Service of the notice on defendants (b) Expiration of 30 days since service of the Notice (c) Defendants failure to request or appear at the meeting with the mortgagee or Consumer Counseling Agency (d) Defendants failure to file application with the Homeowners Emergency Assistance Program. I further agree to indemnify and hold harmless the Sheriff for any falseXtatements given herein. . 1 an Kosensthe for Plaintiff Dated: October 12, 2007 n,? - - ? =? _- ? ? -?% r ?? s? ? -.,c Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 649 South Avenue, Unit 7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney I.D.# 52634 Attorney for Plaintiff LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE2 c/o Wilshire Credit Corp 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005 Plaintiff vs. Wanda K. Showers 134 East North Street Carlisle, PA 17013 Defendant : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : No: 06-6954 THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Wanda K. Showers 134 East North Street Carlisle, PA 17013 Your house and/or real estate at 134 East North Street, Carlisle, PA 17013 is scheduled to be sold at Sheriff's Sale on March 5, 2008 at 10:00 a.m. to enforce the court judgment of $76,863.34 obtained by LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE2 against you. NOTICE OF OWNERS RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take IMMEDIATE action: 1. The sale will be cancelled if you pay to LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE2 the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call (610) 328-2887. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. . J You may contact an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling (610) 328-2887. 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 the 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 (610) 328-2887. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money, which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on a date to be announced by the Sheriff. 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 posted. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (800) 990-9108 (717) 249-3166 CLAIM FOR EXEMPTION To the Sheriff. I, the above named defendant, claim exemption of property from levy or attachment: (1) From my real property in my possession which has been levied upon, (a) I desire that my $300.00 statutory exemption be set-aside in kind (specify real property to be set-aside in kind): I request a prompt court hearing to determine the exemption. Notice of the hearing should be given to me at (Address) (Telephone Number) I verify that the statements made in this Claim for Exemption are true and correct. 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. Date: Signature THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 717 240-6391 MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 649 SOUTH AVENUE, SUITE 7 SECANE, PA 19018 Martha E. Von Rosenstiel, Esquire Keri P. Claeys, Esquire Phone: (610) 328-2887 Fax: (610) 328-2649 October 12, 2007 TO: Wanda K. Showers 134 East North Street Carlisle, PA 17013 RE: NOTICE OF SALE OF REAL PROPERTY: 134 East North Street, Carlisle, PA 17013 Amount of Judgment: $76,863.34 Date of Judgment: 1/16/2007 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 06-6954 Plaintiff: LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE2 Defendants: Wanda K. Showers Dear Sir/Madam: Please be advised that the property and improvements, if any, located at and known as 134 East North Street Carlisle, PA, 17013 will be sold by the Sheriff of Cumberland County on March 55 2008 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Wanda K. Showers. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. i Sincerely yours, Von Rosenstiel MVR# 20154 dk WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180 to 3183 and Rule 3257 LaSalle Bank N.A. as trustee for the MI MI Trust Series 2006-HE2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. Wanda K. Showers Commonwealth of Pennsylvania: County of No. 06-6954 Civil Term Term, 20------- E.D, No. Term, 20 ------ A.D. WRIT OF EXECUTION (MORTGAGE FORECLOSURE) 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 (specifically describe property below): PREMISES: 134 East North Street Carlisle, PA 17013 Amount Due Interest from 1/17/07 to 3/5/06 @ $12.64 per diem Attorney's fees Costs Total as endorsed. $ 76,863.34 $ 5,232.96 Prothonotary, Common Pleas Court of Dated Cumberland County, Penna. (SEAL) By: Deputy w¢ I °z N ? ?< N ? a v) Z? a? --? U ; U Ou zo ? ,x N z z xW ?E A A _ r w ¢ zU aH 3 0 s rr? C 3 o? ? o U ? w o O ? ap H P-4 0 3 "n 0 U a? a w O 'C a ti V C!1 cr a? ? o0 ° >°?OC ?? Q M Q N W X OC p C M G/1 r ?o" d ?o ? o O y z a " M s4 s .. 3 U) ul N $?d ti b LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected situate in Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: On the North by East North Street; on the East by property now or formerly of George Laley; on the South by Locust Alley and on the West by property now or formerly of George W. Diehl; containing thirty (30) feet in front of said East North Street and extending in depth two hundred and forty (240) feet to said Locust Alley on the South. BEING improved with a two-story house and garage. BEING known and numbered as 134 East North Street. TAX PARCEL 402-21-0318-243 TITLE TO SAID PREMISES IS VESTED IN Wanda K. Showers by Deed from Richard H. Cook and Arla M. Cook, his wife dated 10/31/2005 and recorded 10/31/2005 in Record Book 271, Page 3433. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-6954 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LASALLE BANK, N.A. as Trustee for the MLMI TRUST SERIES 2006-HE2, Plaintiff (s) From WANDA K. SHOWERS (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 $76,863.34 L.L. $.50 Interest from 1/16/07 to 3/05/08 at $12.64 per diem -- $5,232.96 Atty's Comm % Due Prothy $2.00 Atty Paid $138.40 Other Costs Plaintiff Paid Date: 10/19/07 urtis R. Long, Prothon ary (Seal) By: &6., Deputy REQUESTING PARTY: Name MARTHA E. VON ROSENSTIEL, ESQUIRE Address: 649 SOUTH AVENUE, UNIT 7 PO BOX 307 SECANE, PA 19018 Attorney for: PLAINTIFF Telephone: 610-328-2887 Supreme Court ID No. 52634 I Martha E. Von Rosenstiel, P.C. Attorney for Martha E. Von Rosenstiel 649 South Avenue, Unit 7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney I.D.# 52634 LaSalle Bank, N.A. as Trustee for the MLMI : COURT OF COA Trust Series 2006-HE2 : CUMBERLAND c/o Wilshire Credit Corp 14523 SW Millikan : Way, Suite 200 Beaverton, OR 97005 ; Plaintiff No: 06-6954 vs. Wanda K. Showers : 134 East North Street Carlisle, PA 17013 Defendant AFFIDAVIT OF SERVICE OF NOTICES PURSU COMMONWEALTH OF PENNSYLVANIA: COUNTY OF DELAWARE SS #20154-TM PLEAS TO RULE 3129.1 3 MARTHA E. VON ROSENSTIEL, attorney for the plaintiff in the above action, hereby certifies that service of the Notice under Rule 3129.1, in the above ma er was made on all interested parties, set forth below, by regular first class mail, postage p epaid, as evidenced by the attached certificates of mailing: 1. Name and address of the last recorded holder of every Mortgage Electronic Registration Systems, Inc. P.O. Box 2026 Flint, MI 48501-2026 2. Name and address of every other person who has any record whose interest may be affected by the sale: Cumberland County Tax Claim Bureaj 1 Courthouse Square Carlisle, PA 17013 of record: in the property and Cumberland County Register of Wills J County Courthouse Carlisle, PA 17013 • ' ' Attorney General of the United States,, ' c/o Assistant Attorney General, Tax Division U.S. Department of Justice Post Office Box 227 Washington, DC 20044 PA Department of Revenue Inheritance Tax Bureau Strawberry Square, 11 0' Floor Harrisburg, PA 17128-1100 Family Court/Domestic Relations Office One Courthouse Square Carlisle, PA 17013 Bureau of Compliance i Clearance Support Section/ATTN: Sheriff's Sale Dept. 281230 Harrisburg, PA 17129-1230 Dept. of Public Welfare Box 2675 Harrisburg, PA 17105 OCCUPANTS/TENANTS! 134 East North Street Carlisle, PA 17013 I verify that the statements made in this affidavit are true and personal knowledge or information and belief. I understand that false subject to the penalties of 18 Pa. C.S. Section 4904 relating to to the best of my herein are made falsification to authorities. E. Von Rosenstiel v for Plaintiff For Accountable M 11 ?2 Q 1,5 q ft cy?D 0 O CO OD V O) CA A W N .a _r m = N Q d m 7 0 p Z W °a ? N y O m C y CO) Q) aa * CD M:q Z -I ?I'U? o o xma xoDo ao p?-n xw? ZI *.-o -In> d? o o n C? cc 1 > O M co g3v o n? ?? 1-05 m ov vc? C 3o?W oy d o? m??D ?sumo NOinxo N o C M C 0? X03-+ O WO O O N y 0 y WO C y N(nN p = 3 N C? ? CA Q.?«CD -A 0 ?woov3 M , N Q 7 w c ? (D C =r n' ! C E O y. 7 ? n X C O ( p AA N? N o -0 O O r- AA O x 'O y d ?•N G) O N (7 Cs O ?O N D RI Dy.+. N ° r AZ m ? N - _ . - c c ° DpmC lD -w _ ?CI) ;0 O v3'o? p a > C `?' O a 0 O G ?O i u'i ? °° a 0-40 Dw o !n D ? c (D 0 s on v ??o ? vv 3 ? .4 cnV O x m D C15 n o W -4 cno oQ a °c Z y U Of_n N ? O` N 0 -4 ;L j °n N ?v CD -4 C (D O O N O - (G N OA2 C N 00- C Q N t' W D (D +. O cn o N Q) A CO m W ? C ?D ao w +. L C .. CD W q U) D CD p CO) m :D CD 5C y -h a -0 N O 7 CD 'n . . C1 O in fD n @ CO) p? N .» O O 7 in CD - N O y N y ?p ?I z c 3 r 3 CD m a - l ? ??? ? 00 ;D y ao r- m cc CD m ° v cD CD a ,0 m ? ? a m .. - o ? ' g6 -n M -0 X (5 O f»D y ;0 y n 3 a 0 P o 2 CL o? ?3 o CL 1; CL 3 CD M 0a / C? W d 1 p? 7 O• t ti\ C U) O 5E3 0X 0 D N O? ' O H I U 3• A 7 0 fD ?o Cr 3 p cu m 0< ' y g o Q ma Bi N_ r- Tr C m C S 4m Q O (? V y y n0 O=r C. fD ?oQa o - d? n C) CL nv ?,? m ? nnn i?om o 0 8'CD ° ¦ rc S' m o ' 0 m ? vm? oo 3 o ? pr i` Cr N UN o n, y)r O Cr °i ) -n 3 m i L _ ? 1 OFiS ?D 3 y Cyl i 0 CL !R 3 0 ll P g_ M m o .3 C ° -f m i 4'0 ja =r A9: CA CD ? o m w to f ~"P 1 j `Pt t r` Q #20154-CMS-TM Martha E. Von Rosenstiel, P.C. Attorney for Plaintiff Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit 7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney I.D. # 52634 LASALLE BANK, N.A. AS TRUSTEE FOR COURT OF COMMON PLEAS THE MLMI TRUST SERIES 2006-HE2 CUMBERLAND COUNTY Plaintiff VS. WANDA K. SHOWERS Defendant No: 06-6954 MOTION FOR SPECIAL SERVICE Movant, by its counsel, Martha E. Von Rosenstiel, Esquire, moves this Honorable Court for an Order directing service of the Notice of Sale and all subsequent notices upon the above captioned defendant by regular mail and certified mail to the Defendant's last known address of 426 South Baltimore Avenue, Mount Holly Springs, PA 17065 and by posting of the premises located at 134 East North Street Carlisle, PA 17013 (hereinafter "Subject Premises") and in support thereof avers the following: 1. The Plaintiff filed its Complaint in Mortgage Foreclosure against the Defendant, Wanda K. Showers, on or about December 4, 2006, for the Defendant, Wanda K. Showers's failure to make monthly mortgage payments due. 2. On or about January 16, 2007 judgment was entered against the Defendant, Wanda K. Showers, and in favor of the Plaintiff, LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE2. 3. On or about February 13, 2007, a writ of execution was issued listing the Subject Premises for the June 13, 2007, Cumberland County Sheriff's Sale. 4. The June 13, 2007 Sheriff's Sale was stayed as the Defendant, Wanda K. Showers, was approved for PHFA assistance. 5. Approval of the PHFA assistance was rescinded on September 13, 2007. 6. On or about October 19, 2007, a writ of execution was re-issued listing the Subject Premises for the March 5, 2008 Cumberland County Sheriff's Sale. 7. The March 5, 2008 Sheriff's Sale was postponed to May 7, 2008 to allow Plaintiff to effectuate service upon Defendant, Wanda K. Showers. 8. Plaintiff has been unable to serve the Notice of Sale upon Defendant, Wanda K. Showers. The Sheriff and Process Server's Returns of no Service is attached hereto made part hereof and marked as Exhibit A. 9. Pursuant to Pennsylvania Rules of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defendant, Wanda K. Showers. 10. An Affidavit of Reasonable Investigation setting forth the specific inquiries made and the results therefore is attached hereto made part hereof and marked as Exhibit B. WHEREFORE, as Plaintiff respectfully requests this Honorable Court enter an pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Notre of Sale and all subsequent notices by certified and regular mail to the Defendant and by posting of the Subject Premises. Martha E. Von Rosenstiel Attorney for Plaintiff Date: March 05, 2008 #20154-CMS-TM Martha E. Von Rosenstiel, P.C. Attorney for Plaintiff Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit 7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney I.D. # 52634 LASALLE BANK, N.A. AS TRUSTEE FOR COURT OF COMMON PLEAS THE MLMI TRUST SERIES 2006-HE2 CUMBERLAND COUNTY Plaintiff : VS. WANDA K. SHOWERS Defendant No: 06-6954 BRIEF IN SUPPORT OF ITS MOTION FOR SPECIAL SERVICE Movant, by its counsel, Martha E. Von Rosenstiel, Esquire, moves this Honorable Court for an Order directing service of the Notice of Sale and all subsequent notices upon the above captioned defendant by regular mail and certified mail to the last known address of 426 South Baltimore Avenue, Mount Holly Springs, PA 17065 and by posting of the premises located at 134 East North Street Carlisle, PA 17013 (hereinafter "Subject Premises") and in support thereof avers the following: 1. FACTS The Plaintiff filed its Complaint in Mortgage Foreclosure against the Defendant, Wanda K. Showers, on or about December 4, 2006, for the Defendant, Wanda K. Showers's failure to make monthly mortgage payments due. On or about January 16, 2007 judgment was entered against the Defendant, Wanda K. Showers, and in favor of the Plaintiff, LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE2. On or about February 13, 2007, a writ of execution was issued listing the Subject Premises for the June 13, 2007, Cumberland County Sheriff's Sale. The June 13, 2007 Sheriff s Sale was stayed as the Defendant, Wanda K. Showers, was approved for PHFA assistance. Approval of the PHFA assistance was rescinded on September 13, 2007 and on or about October 19, 2007 a writ of execution was re-issued listing the Subject Premises for the March 5, 2008 Cumberland County Sheriff's Sale. The March 5, 2008 Sheriff's Sale was postponed to May 7, 2008 to allow the Plaintiff to effectuate service upon the Defendant, Wanda K. Showers. II. ARGUMENT Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule the plaintiff may move the Court for a special order directing the method of service. The Motion shall be accompanied by an Affidavit stating the nature and extent of the investigation, which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. The Court in Romeo v. Looks, 369 Pa. Super 608 (1982) stated that "Before resort to substituted service maybe had, however, a plaintiff must have demonstrated a good faith effort to locate the defendant through more direct means." An illustration of good faith effort to locate the Defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and employers of the Defendant and (3) examination of local telephone directories, voter registration records, local tax records, and motor vehicle records. Kittannine Coal Co. Inc v International Mining Co Inc 551 F. Supp. 834 (1982), Romeo v. Looks, 369 Pa. Super 608 (1987). As set forth in the Sheriff and Process Server's Returns of no Service, marked Exhibit A, the Plaintiff has been unable to serve the Notice of Sale after several attempts. A good faith effort to discover the whereabouts of the defendant has been made as evidenced by the attached Affidavit of Reasonable Investigation marked Exhibit B. The Plaintiff submits that it has made a good faith effort to locate and serve the Defendant, Wanda K. Showers, and has been unable to do so. WHEREFORE, Plaintiff respectfully requests service of the Notice of Sale and all subsequent notices by certified and regular mail and by posting of the Subjec/Premises by the Sheriff. ly submitted, E. Von Rosenstiel Attorney for Plaintiff Date: March 5, 2008 #20154-CMS-TM Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit 7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney I.D. # 52634 Attorney for Plaintiff LASALLE BANK, N.A. AS TRUSTEE FOR COURT OF COMMON PLEAS THE MLMI TRUST SERIES 2006-HE2 CUMBERLAND COUNTY Plaintiff VS. No: 06-6954 WANDA K. SHOWERS Defendant CERTIFICATE OF SERVICE Martha E. Von Rosenstiel, Esquire hereby certifies that she is the attorney for the Plaintiff herein, and that service of the Motion for Special Service, brief in support thereof, attached exhibits, and proposed order in the above matter was made upon the following: Wanda K. Showers 134 East North Street Carlisle, PA 17013 And 426 South Baltimore Avenue Mount Holly Springs, PA 17065 by regular first class mail, postage prepaid, deposited with the United States Postal 3/5/2008. This verification is made subject to the penalties of 18 Pa.C.S. §4904 falsification to authorities. on to unsworn Martha E. Von Rosenstiel, Esquire Attorney for Plaintiff Dated: March 05, 2008 MAY BE U50 PM DONN I IC AND IW WATIMAL MAR„ PROVm6 PM VBMAWE- K)SIMASfER Received Fn ti it ? y - MARTHA VON R .92 1 P 649 SOUTH ; 0002664019 MAILED FROM SECANE, PA 1901 E On pim oford w.v fflo sddi 1 to: INanda K ShOAMM 426 South Baltimore Avenue Maufft Nally s, PA 17065 3817, Mar.1 "9 MAY N U30 POK 00M UM AND INMNATIMAL MAR., PW)VVEPM WOMAMLT- sa ru-erg Received Plum MARTHA VON It649 SOUTH UNIT 7 SECANE, PA 19018 one piece of NOW V wail addrewred to: Affix roe ham in stamps Or meter poor awd Poet wort. owl iR of W PITNEY BOWES > 001.05° MAR 05 2008 :IP CODE 1,II.1 a .. y Afra he ham in go D0 T Or meter powase aad ' ? PON MWL Ey Bowan 05° 001 ,02 1 P . 0002664019 MAR 05 2008 MAILED FROM IP(:ODE 19018 anrla K Shnutar 134 East North Street f ' i PS Form 3817, Mar.1969 VERIFICATION MARTHA E. VON ROSENSTIEL, ESQUIRE, of full age, being duly sworn according to law deposes and says that she is the attorney for the Plaintiff in the foregoing action; that she is duly authorized to make this verification on behalf of the Plaintiff; that she is fully familiar with the facts in this matter; and that the statements made in the foregoing MotVn for Special Service are true and correct to the best of her knowledge, information and E. Von Rosenstiel Dated: March 05, 2008 LaSalle Bank, N.A. as Trustee for the MLMI In the Court of Common Pleas of Trust Series 2006-HE2 c/o Wilshire Credit Cumberland County, Pennsylvania Corp Writ No. 2006-6954 Civil Term VS ?? G Wanda K. Showers ' 3 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant, to wit: Wanda K. Showers, but was unable to locate her in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sheriffs Sale and Description as NOT FOUND as to the defendant, Wanda K. Showers. The house located at 134 East North Street, Carlisle, PA is vacant. The Carlisle Post Office advises the defendant's mail is still delivered to the given address. Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on January 10, 2008 at 1430 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 Wanda K. Showers located at 134 East North Street, Carlisle, Cumberland County, Pennsylvania according to law. So Answers: R. Thomas Kline, Sheriff B Real Estate $ rgeant oenert ? - AFFIDAVIT OF SERVICE PLAINTIFF: LaSalle Bunk, NA .as Trustee for the MLMI Trust Series 200"E2 DEFENDANT COURT OF COMMON PLEAS Wanda K. Showers Cumberland COUNTY COURT NO. 06.6954 SERVE UPON: Wanda K. Showers 426 South Baltimore Avenue Mount Holly Springs, PA 17065 SPECIAL MIS'IRUCTIONS: Please serve the defendant listed above. Thank you. TYPE OF ACTION XX WRIT OF EXECUTION 20154ONC-TM SALE DATE: 3MM (Please serve notice by 2/29/08. 'T'hank you) SERVED Served and made known to Defendant, on the _ day of . 200_, at o'clock, . M., at Commonwealth of Pennsylvania, in the manner described below: Defendant personally served. Adult family member with whom Defendant resides. Relationship is Adult in charge of Defendant's residence who refused to give naaw"ationshi . Manager/Clerk of place of lodging in which Defendant resides. - Agent or person in charge of Defendant's office or usual place of business. Other DemAption: Age Height Welght Race Sex Other 1 , a competent adult, being duly sworn according to law, depose and state that I personally handed to a true and correct copy of the WRIT OF EXECUTION issued in the captioned case on the date and at the address indicated above. Swom to and subscribed before me this day of , 20 Notary: BY NOT SERVED On the - day of d , 20(5 8 at + o'clock ?. M., Defendant NOT FOUND because: Moved Unknown _ No Answer Vacant Date of Time of Aftmi* Result+ A 7 0 8 7' ?; c o fu q Y Swotn to ana subscribed before me this of =aettlh- Notary. ?'? v By: G?? U A170RN€1! VAM IL tt111MW Martha E. Von Rosenstiei, P.C. Raft 649 So Avenue, Unit 7 . Secane, PA 19018 a 610428-2887 tl11 INR INi11MRN1 COMA w o.Iew?IOe tIMrIMS «w ea 9n 1I FULL SPECTRUM LEGAL SERVICES, INC. AFFIDAVIT OF GOOD FAITH INVESTIGATION File Number: 20154-TM Attorney Firm: Law Offices of Marty Von Rosenstiel Subject: Wanda K. Showers Current Address: 426 South Baltimore Avenue, Mount Holly Springs, PA 17065 Property Address: 134 East North Street, Carlisle, PA 17013 Mailing Address: 426 South Baltimore Avenue, Mount Holly Springs, PA 17065 I, Kerri Smith, being duly sworn according to law, do hereby depose and state as follows, I have conducted an investigation into the whereabouts of the above-noted individual(s) and have discovered the following: 1. CREDIT INFORMATION A. SOCIAL SECURITY NUMBER Our search verified the following information to be true and correct Wanda K. Showers - xxx-xx-8748 B. EMPLOYMENT SEARCH Wanda K. Showers - A review of the credit reporting agencies provided no employment information. C. INQUIRY OF CREDITORS Our inquiry of creditors indicated that Wanda K. Showers reside(s) at: 1,34 East North Street, Carlisle, PA 17013. 1I. INQUIRY OF TELEPHONE COMPANY A. DIRECTORY ASSISTANCE SEARCH Our office contacted directory assistance, which had no listing for Wanda K. Showers. B. On 02-08-08 our office made a telephone call to the phone number (717) 243-3151 and received the following information: spoke with an unidentified female who confirmed that Wanda K. Showers reside(s) at: 426 South Baltimore Avenue, Mount Holly Springs, PA 17065. III. ADDRESS INQUIRY A. NATIONAL ADDRESS UPDATE On 02-08-08 we reviewed the National Address database and found the following information: Wanda K. Showers - 426 South Baltimore Avenue, Mount Holly Springs, PA 17065. B. ADDITIONAL ACTIVE MAILING ADDRESSES Per our inquiry of creditors, the following is a possible mailing address: no addresses on file. ooNerr ? - IV. OTHER INQUIRIES A. DEATH RECORDS As of 02-08-08 Vital Records and all public databases have no death record on file for Wanda K. Showers. B. COUNTY VOTER REGISTRATION The county voter registration was unable to confirm a registration for Wanda K. Showers residing at last registered address. V. ADDITIONAL INFORMATION OF SUBJECT A. DATE OF BIRTH Wanda K. Showers - 01-01-1971 * Our accessible databases have been checked and cross-referenced for the above named individual(s). * Please be advised our database information indicates the subject resides at the current address. I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing states made by me are willfully false, I am subject to punishment. I hereby verify that the statements made herein are true and correct to the best of my knowledge, information and belief and that this affidavit of investigation is made subject to the p?e?nalt?ies of 18 Pa C.S. Sec. 4904 relating to unsworn falsification to authorities. / AFFIANT - Kerri Smith Full Spectrum Legal Services, Inc. Sworn to and subscribed before me this 8th day of February, 2008. The above information is obtained from available public records and we are only liable for the cost of the affidavit kls NpTA w. SEAL Ryp1yP GAL`rU" i\!d^fYl'Ublic Cky 0i Pni et;e,r . ?aiia Mlr Covvf scion E x ?rep qjpzsTkw 21, 2008 -0 mc Sal t AFFIDAVIT OF SERVICE PLAINTIFF: LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE2 DEFENDANT Wanda K. Showers SERVE UPON: Wanda K. Showers 426 South Baltimore Avenue Mount Holly Springs, PA 17065 SPECIAL INSTRUCTIONS: Please serve the defendant listed above. Thank you. COURT OF COMMON PLEAS Cumberland COUNTY COURT NO. 0"9664 TYPE OF ACTION XX WRIT OF EXECUTION 20154CNGTM SALE DATE: 315108 (Please serve notice by 2/29/08. Thank you) SERVED Served and made known to Defendant, on the _ day of , 200, at o'clock, . M., at , Commonwealth of Pennsylvania, in the manner described below: Defendant personally served. Manager/Clerk of place of lodging in which Adult family member with whom Defendant resides. Defendant resides. Relationship is Agent or person in charge of Defendant's office Adult in charge of Defendant's residence who refused or usual place of business. to give nametrelationshi . Other Description: Age Height Weight Race Sex Other 1, , a competent adult, being duly sworn according to law, depose and state that I personally handed to a true and correct copy of the WRIT OF EXECUTION issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this day of 20 Notary: By: 1 J NOT SERVED On the -aj " ay of / C Ua? 20-69 at 1'94 o'clock ?. M., Defendant NOT FOUND because: Moved Unknown_ No Answer Vacant Date of Atte t: Time of Attempt: Result: kJ2 VJQfc Vt S to an subscribed before me this / da of 200 Notary: Byja*, ATTORNEY ' CAM Martha E. Von Rosenstlel, P.C. IL 648 So h Avenue, Unit 7 • Secane, PA 19018.610-328-2887 U1101111111101 W4 $1wA1M01 COON r CMAVANW / me"" "W 19. lot i E'y ? C? C C=? - F E5 MIS .M yoww.? *sow ?of'?° I lot .04 MAR 0 7 20081)4Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. LASALLE BANK, N.A. AS TRUSTEE FOR THE MLMI TRUST SERIES 2006-HE2 Plaintiff No: 06-6954 VS. WANDA K. SHOWERS Defendant ORDER IA% AND NOW, this It day of Maxc? , 2008, upon consideration of Plaintiffs Motion for Special Service and any response thereto (if any), it is hereby: ORDERED and DECREED that Plaintiff may obtain service on Wanda K. Showers by mailing a true and correct copy of the Notice of Sale and all subsequent notices by certified mail and regular, first class mail at the last known address of 426 South Baltimore Avenue, Mount Holly Springs, PA 17065 and by posting the premises of 134 East North Street, Carlisle, PA 17013. BY THE COURT: V'i V A AS Vi 3d 1 C .g WV 11 8vw 8002 T^I_, C- -031Y Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887 Attorney I.D.# 52634 LASALLE BANK, N.A. AS TRUSTEE FOR THE MLMI TRUST SERIES 2006-HE2 Plaintiff VS. WANDA K. SHOWERS Defendan#(s) #20154CAM - TM Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 06-6954 SUPPLEMENTAL AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1 MARTHA E. VON ROSENSTIEL, ESQUIRE, attorney for the Plaintiff in the above action, hereby verifies that on March 14, 2008, true and correct copies of the Notice of Sheriff's Sale were served upon recorded defendant, WANDA K. SHOWERS by posting the premises pursuant to court order d ted March 10, 2008. A copy of the order and affidavit(s) of service attached hereto as Exhibit I. I verify that the statem6ts made in this affidavit are true and correct to the best of my porsonal knowledge or I 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. i Mart ha E. Von Rosenstiel I Attorney for Plaintiff Dated: March 14, 2008 MAR 0 7 7008 • IN THE COURT OF COMMON PLEAS Off' CUMBERLAND COUNTY, PENNA. LASALLE BANK, N.A. AS TRUSTEE FOR THE MLMI TRUST SERIES 2006•HE2 Plaintiff No: 06-6954 vs. WANDA K. SHOWERS Defendant ORDER AND NOW, this ' day of 2008, upon consideration o Plaintiffs Motion for Special Service and any response thereto (if any), it is hereby: ORDERED and DECREED that Plaintiff may obtain service on Wanda I. Showers by mailing a true and correct copy of the Notice of Sale and all subsequent notices II y certified mail and regular, firs! class mail at the last known address of 426 South Baltimore Av nue, Mount Holly Springs, PA 17065 and by posting the premises of 134 East North Street, 4lisle, PA 17013. BY THE COURT: J 4# V1 J- - . Postal c:0 (Domestic Mail Only; No Insurance Coverage Provided) ru - m r Ie- Poe stag $ 5 - CA4( m Certified Fee ;?• `?, ?Q A tatmark 9 C3 C3 Retum Receipt Fee (Endorsement Required) 1WHere C3 p Restricted Delivery Fee (Endorsement Required) $0.00 QOa oq e & Fees Total Posta $ #5' g rp Sent n 1 O N Street, Apt N - 50VY ` or PO Box No. (Y-?l(? 1M?1f I 9 . C' 7 1P 4 - 1 ` ? , ? S? J ctions t f I Form 3800, August 2006 ru ns or See Reverse ..ta iv alt ING A?p1 fee rac is 1?4? or wow polb"pire aw AtIO'?l' d W1ll., WO WT WAk*. rnC for omcru pROVW E FOF. ir1S MARTHA VON'LW 649 SOUTH A UNIT 7 SECANF PA 19018 um pica of arli m" UWW Wanda K. Showers Mount Hol PS form i5 1 i•, PITNEY BOWES $ 001.050 MAR 13 2008 ZIP CODE 1 901 8 V (? r-13 AFFIDAVIT OF SERVICE PLAINTIFF: LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE2 DEFENDANT COURT OF COMMON PLEAS Wanda K. Showers Cumberland COUNTY COURT NO. 06-6954 SERVE UPON: TYPE OF ACTION XX WRIT OF EXECUTION Wanda K. Showers 134 East North Street Carlisle, PA 17013 SPECIAL INSTRUCTIONS: SALE DATE: 5/7/08 Please POST the mortgaged premises in accordance with court order on or before 4/4/08. Thank you. 20154CNC-TM SERVED Served and made known to (V4-P X19 u, S16'-1QPAS Defendant, on the a?, day of M 200_L, at d- S7 o'clock, Pr . M., at 13 Q 1; Asr Mm CA i/' LISc,E , Commonwealth of Pennsylvania, in the manner described below: Defendant personally served. Adult family member with whom Defendant resides. Relationship is Adult in charge of Defendant's residence who refused to ive name/relationship. Manager/Clerk of place of lodging in which Defendant resides. Agent or person in charge of Defendant's office or usual place of business. t? Other Q 1??5 wiT4- NU7KF-4,F s? Description: Age Height Weight Race 1, CA;i? 1,10 L- L , a competent adult, being duly sworn according to law, depose and state that I personally hemde*to - pS a true and correct copy of the WRIT OF EXECUTION issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this 2-10 day of t?A e4f- 20::? Notate THEODORE J. ARRIS NOTARY PUBLIC STATE OF NEW JERSEY *@MNIMISSION E 10/2512012 Moved Unknown 1 By: _ ?T?, ??x NOT SERVED 20 , at o'clock . M., Defendant NOT FOUND because: No Answer Vacant Date of Attempt: Time of Attempt: Result: v Wl" lV Q IU z UUC.%,!IVUU before me this day of 200_. Notary: By: ATTORNEY Martha E. Von Rosenstiel, P.C. 649 S outh Avenue, Unit 7 • Secane, PA 19018 • 610-328-2887 ?{ 1 (?q9 Sex Other, t?? ? c q p 1 m COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which MLMI TRUST SERIES 2006-HE2 TR is the grantee the same having been sold to said grantee on the 7TH day of MAY A.D., 2008, under and by virtue of a writ Execution issued on the 19TH day of OCT, A.D., 2007, out of the Court of Common Pleas of said County as of Civil Term, 2006 Number 6954, at the suit of MLMI TRUST SERIES 2006-HE2 TR against WANDA K SHOWERS is duly recorded as Instrument Number 200820635. IN TESTIMONY WHEREOF, I have he unto set my hand andAeal of said office this ?-- day of A.D. ? (70 of Deeds Raoordl(d DZW& Cwftr" Cooly, CarYga, PA ComurN m EON tw First Monday of Jan. 2010 LaSalle Bank, N.A. as Trustee for the MLMI In the Court of Common Pleas of Trust Series 2006-HE2 c/o Wilshire Credit Cumberland County, Pennsylvania Corp Writ No. 2006-6954 Civil Term VS Wanda K. Showers R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant, to wit: Wanda K. Showers, but was unable to locate her in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sheriffs Sale and Description as NOT FOUND as to the defendant, Wanda K. Showers. The house located at 134 East North Street, Carlisle, PA is vacant. The Carlisle Post Office advises the defendant's mail is still delivered to the given address. Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on January 10, 2008 at 1430 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 Wanda K. Showers located at 134 East North Street, Carlisle, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on May 7, 2008 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Martha E. Von Rosenstiel, on behalf of LaSalle Bank, N.A., as Trustee for MLMI Trust Series 2006-HE2. It being the highest bid and best price received for the same, LaSalle Bank N.A., as Trustee for MLMI Trust Series 2006-HE2, of 14523 SW Millikan Way, Suite 200, Beaverton, OR 97005, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $912.52. Sheriffs Costs: Docketing $30.00 Poundage 17.50 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 48.00 Auctioneer 10.00 Law Library .50 Prothonotary 2.00 Mileage 9.60 Levy 15.00 Surcharge 20.00 Post Pone Sale 20.00 Law Journal 355.00 Patriot News 274.25 Share of Bills 16.17 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $ 912.52 ? ??°f o8- So Answers: R. Thomas 1me' Sheriff BY eant Real Estate erg Chi 4 ?? 3G?' Martha E. Von Rosenstiel, P.C. Martha E. Von R'osenstiel 649 South Avenue, Unit 7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney I.D.# 52634 LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE2 c/o Wilshire Credit Corp 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005 Plaintiff VS. Wanda K. Showers 134 East North Street Carlisle, PA 17013 Defendant Attorney for Plaintiff ° ? 11 rt ?. ?Vf; COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 06-6954 AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF DELAWARE SS MARTHA E. VON ROSENSTIEL, attorney for the plaintiff in the above action, sets forth as of the date the praecipe for the Writ of Execution was filed the following information concerning the real property located at 134 East North Street, Carlisle, PA 17013. 1. Name and address of owners(s) or reputed owner(s) Wanda K. Showers 134 East North Street Carlisle, PA 17013 2. Name and address of defendant(s) in the judgment: Wanda K. Showers 134 East North Street Carlisle, PA 17013 3. Name and address of the last recorded holder of every mortgage of record: Mortgage Electronic Registration Systems, Inc. P.O. Box 2026 Flint, MI 48501-2026 4. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, PA 17013 Cumberland County Register of Wills County Courthouse Carlisle, PA 17013 Attorney General of the United States c/o Assistant Attorney General, Tax Division U.S. Department of Justice Post Office Box 227 Washington, DC 20044 PA Department of Revenue Inheritance Tax Bureau Strawberry Square, 11th Floor Harrisburg, PA 17128-1100 Family Court/Domestic Relations Office One Courthouse Square Carlisle, PA 17013 Bureau of Compliance Clearance Support Section/ATTN: Sheriff's Sale Dept. 281230 Harrisburg, PA 17129-1230 Dept. of Public Welfare Box 2675 Harrisburg, PA 17105 OCCUPANTS/TENANTS 134 East North Street Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Martha E. Von Rosenstiel, P.C. Attorney for Plaintiff Martha E. Von Rosenstiel 649 South Avenue, Unit 7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney I.D.# 52634 LaSalle Bank, N.A. as Trustee for the MLMI : COURT OF COMMON PLEAS Trust Series 2006-HE2 : CUMBERLAND COUNTY c/o Wilshire Credit Corp 14523 SW Miilikan : Way, Suite 200 Beaverton, OR 97005 Plaintiff No: 06-6954 vs. Wanda K. Showers 134 East North Street Carlisle, PA 17013 Defendant THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Wanda K. Showers 134 East North Street Carlisle, PA 17013 Your house and/or real estate at 134 East North Street, Carlisle, PA 17013 is scheduled to be sold at Sheriff's Sale on March 5, 2008 at 10:00 a.m. to enforce the court judgment of $76,863.34 obtained by LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE2 against you. NOTICE OF OWNERS RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff s Sale you must take IMMEDIATE action: 1. The sale will be cancelled if you pay to LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE2 the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call (610) 328-2887. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may contact an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling (610) 328-2887. 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 the 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 (610) 328-2887. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money, which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on a date to be announced by the Sheriff. 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 posted. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (800) 990-9108 (717) 249-3166 CLAIM FOR EXEMPTION To the Sheriff: I, the above named defendant, claim exemption of property from levy or attachment: (1) From my real property in my possession which has been levied upon, (a) I desire that my $300.00 statutory exemption be set-aside in kind (specify real property to be set-aside in kind): I request a prompt court hearing to determine the exemption. Notice of the hearing should be given to me at (Address) (Telephone Number) I verify that the statements made in this Claim for Exemption are true and correct. 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. Date: Signature THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 717 240-6391 MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 649 SOUTH AVENUE, SUITE 7 SECANE, PA 19018 Martha E. Von Rosenstiel, Esquire Keri P. Claeys, Esquire Phone: (610) 328-2887 Fax: (610) 328-2649 October 12, 2007 TO: Wanda K. Showers 134 East North Street Carlisle, PA 17013 RE: NOTICE OF SALE OF REAL PROPERTY: 134 East North Street, Carlisle, PA 17013 Amount of Judgment: $76,863.34 Date of Judgment: 1/16/2007 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 06-6954 Plaintiff: LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE2 Defendants: Wanda K. Showers Dear Sir/Madam: Please be advised that the property and improvements, if any, located at and known as 134 East North Street Carlisle, PA, 17013 will be sold by the Sheriff of Cumberland County on March 5, 2008 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Wanda K. Showers. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. 1 Sincerely yours, . Von Rosenstiel MVR# 20154 dk WRIT OF EXECUTION _ (MORTGAGE FORECLOSURE) P.R.C.P. 3180 to 3183 and Rule 3257 LaSalle Bank N.A. as trustee for the MLMI Trust Series 2006-HE2 vs. Wanda K. Showers Commonwealth of Pennsylvania: County of IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 06-6954 Civil Term Term, 20------- E.D. No. Term, 20 ------ A.D. WRIT OF EXECUTION (MORTGAGE FORECLOSURE) 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 (specifically describe property below): PREMISES: 134 East North Street Carlisle, PA 17013 Amount Due Interest from 1/17/07 to 3/5/06 @$12.64 per diem Attorney's fees Costs Total $ 76,863.34 $ 5,232.96 as endorsed. Dated_ - (SEAL) Prothonotary, Common Pleas Court of Cumberland County, Penna. By: Deputy I O ? hN N N W s 40 a . ? E-" y N > W . ?v (?] c0 irk V) V ¢.b 3 ?p Z N a V z o z W W x N W CO -cs Cct W d zV o? ? O V a?i W a. W w w ? O ed pG ? W W i -. G RS a. 0 T cr H 0 a ' V y 00 all 0 0 a >r-00 00 oa er w ??°? ?o p ., an na n? c 5 .? N T m Cu a u M V a? 3 N d H b ozz LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected situate in Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: On the North by East North Street; on the East by property now or formerly of George Laley; on the South by Locust Alley and on the West by property now or formerly of George W. Diehl; containing thirty (30) feet in front of said East North Street and extending in depth two hundred and forty (240) feet to said Locust Alley on the South. BEING improved with a two-story house and garage. BEING known and numbered as 134 East North Street. TAX PARCEL #02-21-0318-243 TITLE TO SAID PREMISES IS VESTED IN Wanda K. Showers by Deed from Richard H. Cook and Arla M. Cook, his wife dated 10/31/2005 and recorded 10/31/2005 in Record Book 271, Page 3433. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-6954 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LASALLE BANK, N.A. as Trustee for the MLMI TRUST SERIES 2006-HE2, Plaintiff (s) From WANDA K. SHOWERS (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 $76,863.34 L.L. $.50 Interest from 1/16/07 to 3/05/08 at $12.64 per diem -- $5,232.96 Atty's Comm % Due Prothy $2.00 Atty Paid $138.40 Other Costs Plaintiff Paid Date: 10/19/07 Curtis R. Long, Prothono (Seal) By: L_?e n _ L. Deputy REQUESTING PARTY: Name MARTHA E. VON ROSENSTIEL, ESQUIRE Address: 649 SOUTH AVENUE, UNIT 7 PO BOX 307 SECANE, PA 19018 Attorney for: PLAINTIFF Telephone: 610-328-2887 Supreme Court ID No. 52634 Real Estate Sale #32 On November 7, 2007 the Sheriff levied upon the defendant's interest in the real property situated in Carlisle Borough, Cumberland County, PA Known and numbered as 134 East North Street, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 7, 2007 By: a?c?w Real Estate Sergeant PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 25, February 1 and February 8, 2008 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Marie Coyne, SWORN TO AND SUBSCRIBED before me this 8 day of February, 2008 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary PubiIC CARLISLE BORO, CUMBERLAND COUNTY MY Commission Expires Apr 28, 2010 FAM EWA" 9" 30. 32 Writ No. 2006-6954 Civil LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE2 c/o Wilshire Credit Corp vs. Wanda K. Showers Atty.: Martha Von Rosenstiel DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected situate in Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: On the North by East North Street; on the East by property now or for- merly of George Laley; on the South by Locust Alley and on the West by property now or formerly of George W. Diehl; containing thirty (30) feet in front of said East North Street and extending in depth two hundred and forty (240) feet to said Locust Alley on the South. BEING improved with a two-story house and garage. BEING known and numbered as 134 East North Street. TAX PARCEL #02-21-0318-243. TITLE TO SAID PREMISES IS VESTED IN Wanda K. Showers by Deed from Richard H. Cook and Arla M. Cook, his wife dated 10/31/2005 and recorded 10/31/2005 in Record Book 271, Page 3433. The Patriot-News Co. I r 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8292 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 the Patr1*otAvXtws 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 Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 01130/08 02/06/08 02/13/08 ......... . .... ...... t Sworn to a bsc ibed befor his 2?February, 2008 A.D. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal ! Sherrie L Kisner, Notary Public City Of Harrisburg, Dauphin County My Corm*sior Expires Nov. 26,2014 Member, Pennsylvania Association of Not- REAL ESTATE SALE NO. 32 Writ No. 2006-6954 Civil Term LaSalle Bank, N.A. as Trustee for ...e MLMI Trust Series 2006-HE2 do Wilshire Credit Corp VS Wanda. K. Showers Attorney Martha Von Rosenstiel DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected situate in Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: On the North by East North Street; on the East by property now or formerly of George Laley; on the South by Locust Alley and on the West by property now or formerly of George W. Diehl; containing thirty (30) feet in front of said East North Street and extending in depth two hundred and forty (240) feet to said Locust Alley on the South. BEING improved with a two-story house and garage. BEING known and numbered as 134 East North Street. TAX PARCEL #02-21-0318-243 TITLE TO SAID PREMISES IS VESTED IN Wanda K. Showers by Deed from Richard H. Cook and Arla M. Cook, his wife dated 101311 2005 and recorded 1013112005 in Record Book 271, Page 3433.