Loading...
HomeMy WebLinkAbout07-0925UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust 'COURT OF COMMON PLEAS Company, as Trustee under the :CIVIL DIVISION Pooling and Servicing Agreement dated as of March 1, :Cumberland County 2006, GSRPM Mortgage Loan Trust 2006-1 4828 Loop Central Drive Houston, TX 77081 Plaintiff V. Connie L. Paylor 200 4th Street NO. 07 - 9.19 Box 58 Summerdale, PA 17093 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: EquiCredit Assignments of Record to: GMAC Mortgage Recording Date: 8/25/04 Book: 711 Page: 157 Assignor: GMAC Mortgage Assignee: Deutsche Bank National Trust Company, as Trustee under the Pooling and Servicing Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 Recording Date: LODGED FOR RECORDING 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant (s) , Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 200 4th Street MUNICIPALITY/TOWNSHIP/BOROUGH: East Pennsboro Township COUNTY: Cumberland DATE EXECUTED: 7/13/00 DATE RECORDED: 7/28/00 BOOK: 1628 PAGE: 734 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 1/26/07: Principal of debt due $55,817.84 Unpaid Interest at 10.95% from 11/1/03 to 1/26/07 (the per diem interest accruing on this debt is $16.97 and that sum should be added each day after 1/26/07) 20,075.51 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $53.00 and that sum should be added on the first of each month after 1/26/07) 41334.69 Late Charges (monthlyy late charge of $26.94 should be added in accordance with the terms of the note each month after 1/26/07) 207.30 Suspense Balance (216.44) Attorneys Fees (anticipated and actual to 5% of principal) 2,790.89 TOTAL $83,614.79 7. The attorney's fee 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 sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $83,614.79 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. ?li'? Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 LEGAL DESCRIPTION ALL THOSE TWO CERTAIN ADJACENT LOTS OR PARCELS OF LAND, TOGETHER WITH THE IMPROVEMENTS THEREON ERECTED, SITUATE IN EAST PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE NORTHEAST CORNER OF THE INTERSECTION OF FOURTH STREET AND A SIXTEEN (16) FEET WIDE ALLEY; THENCE NORTHWARDLY ALONG THE EASTERN LINE OF FOURTH STREET, SIXTY (60) FEET TO THE SOUTHERN LINE OF, LOT NO. 93, SECTION "A", ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE EASTWARDLY ALONG THE SOUTHERN LINE OF LOT NO.93, SECTION "A", ONE HUNDRED SIXTY (160) FEET TO THE WESTERN LINE OF A SIXTEEN (16) FEET WIDE ALLEY; THENCE SOUTHWARDLY ALONG THE WESTERN LINE OF SAID SIXTEEN (16) FEET WIDE ALLEY, SIXTY (60) FEET TO THE NORTHWEST CORNER OF THE INTERSECTION OF SAID SIXTEEN (16) FEET WIDE ALLEY WITH THE SIXTEEN (16) FEET WIDE ALLEY FIRST MENTIONED; THENCE WESTWARDLY ALONG THE NORTHERN LINE OF THE SIXTEEN (16) FEET WIDE ALLEY FIRST MENTIONED, ONE HUNDRED SIXTY (160) FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOTS NOS. 91 AND 92, SECTION "A" IN THE PLAN OF LOTS KNOWN AS SUMNERDALE, PENNSYLVANIA, SAID PLAN BEING RECORDED IN THE OFFICE FOR THE RECORDING OF DEEDS IN AND FOR CUMBERLAND COUNTY, IN PLAN BOOK 1, PAGE 44 (REVISED PLAN, BOOK 2, PAGE 109). HAVING THEREON ERECTED A ONE-STORY FRAME DWELLING NUMBER 200 FOURTH STREET, SUM ERDALE, PENNSYLVANIA. (Page 1 of 5) 01. UtW Loan SeTvicing"" 11/6/2006 Connie Paylor 200 4th Street Summerdale, PA 17093 ACT 91 NOTICE 4828 Loop Central Drive Houston, TX 77081 Telephone (800) 999-8501 Fax (713) 966-8906 www.httonloan.com TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official Notice that the mortgage on your home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help save your home. This Notice explains how the program works. To see if HEMAP can help. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address, and phone number of Consumer Credit Counseling A tencies serving your County are listed at the end of the Notice. If you have any questions. you may call the Pennsylvania Housing Finance Agency toll- free at (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, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NLWERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUIDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDME R SU HIPOTECA. EXHIBIT A (Page 2 of 5) HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDERISERVICER: Connie Paylor 200 4th Street Summerdale, PA 17093 18476689 Contact Litton Loan Servicing LP Litton Loan Servicing LP HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE -ACT-), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face- to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT." EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign, and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your 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 DdMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. (Page 3 of 5) AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT Bring it up to date.) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 200 4th Street, IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 11/1/2003 through 11/1/2006 at $591.78 totaling $21,895.86 Other charges Late charges $126.48 Deferred late charges $242.46 NSF charges $$0.00 Deferred NSF charges $$0.00 Suspense balance $$41.10 TOTAL AMOUNT DUE AS OF THIS DATE $22,223.70 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: Cure the default. 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 $22,223.70 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check, certified check, or money order made payable and sent to: IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire Litton Loan Servicing LP Attention: Cash Management Department P.O. Box 4387 Houston, TX 77210-4387 outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF TBE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fee that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attomey's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. (Page 4 of 5) 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 anytime up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale, and any other costs connected with the Sheriff's 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 Sheriff's 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 Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: LITTON LOAN SERVICING LP Address: 4828 Loop Central Drive, Houston, TX 77081 Phone Number: (800) 999-8501 Fax Number: (713) 966-8906 Contact Person: Default Administration Department 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 Sheriff's Sale, a lawsuit to remove you and your fumishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - Under the terms of your mortgage and note, it may be possible to sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY Cumberland (Page 5 of 5) CCCS of Western Pennsylvania, Inc. 2000 Unclestown Road Harrisbure, PA 17102 (717(541-1757 (888)511-2227 Urban Leaeue of MetroooGtan Harrisbure N. 6th Street Harrisburg, PA 17101 (717)234-5925 FAX(717)234-9459 Financial Counseline Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717)762-3285 YWCA of Carlisle 3001 G Street Carlisle, PA 17013 (717) 243-3818 FAX(717)731-9589 Community Action Comm of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717)232-9757 FAX(717)234-2227 Adams County Housine Authori 139-143 Carlisle St Gettysburg, PA 17325 (717)334-1518 FAX(717)334-8326 (Page 1 of 5) 01. Lftm Loan ervicing'o 11/6/2006 Connie Paylor 200 4th Street Box 58 Summerdale, PA 170930058 ACT 91 NOTICE 4828 Loop Central Drive Houston, TX 77081 Telephone (800) 999-8501 Fax (713) 966-8906 www.httonloan.com TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official Notice that the mortgage on your home is in default, and the lender intends to foreclose Specific information about the nature of the default is provided in the attached pages The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM a MAP) may be able to help save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address, and phone number of Consumer Credit Counseling genies serving your County are listed at the end of the Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at (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 I PORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDMUR SU HIPOTECA. (Page 2 of 5) HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: Connie Paylor 200 4th Street Summerdale, PA 17093 18476689 Contact Litton Loan Servicing LP Litton Loan Servicing LP HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face- to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT," EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign, and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your 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. (Page 3 of 5) AGENCY ACTION- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT Bring it up to date.) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at 200 4th Street, IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 11/1/2003 through 11/1/2006 at $591.78 totaling $21,895.86 Other charges Late charges $126.48 Deferred late charges $242.46 NSF charges $$0.00 Deferred NSF charges $$0.00 Suspense balance $$41.10 TOTAL AMOUNT DUE AS OF THIS DATE $22,223.70 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: Cure the default. 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 $22,223.70 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check, certified check, or money order made payable and sent to: IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire Litton Loan Servicing LP Attention: Cash Management Department P.O. Box 4387 Houston, TX 77210-4387 outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fee that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. (Page 4 of 5) 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 anytime up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale, and any other costs connected with the Sheriff s 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 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 anytime exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: LITTON LOAN SERVICING LP Address: 4828 Loop Central Drive, Houston, TX 77081 Phone Number: (800) 999-8501 Fax Number: (713) %6-8906 Contact Person: Default Administration Department 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 Sheriff s Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMMON OF MORTGAGE - Under the terms of your mortgage and note, it may be possible to sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY Cumberland (Page 5 of 5) CCCS of Western Pennsylvania, Inc. 2000 Linelestown Road Harrisbure, PA 17102 (717(541-1757 (8881511-2227 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717)234-5925 FAX(717)234-9459 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717)762-3285 YWCA of Carlisle 3001 G Street Carlisle, PA 17013 (717) 243-3818 FAX(717)731-9589 Community Action Comm of the Capital Reeion 1514 Derry Street Harrisbure, PA 17104 (717)232-9757 FAX(717)234-2227 Adams County Housing Authority 139-143 Carlisle St Gettysburg, PA 17325 (717)334-1518 FAX(717)334-8326 V E R I F I C A T I O N Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. CZ1 J o ? w ? n t" T1. 1. ra -n n ti gn i_J OV3 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Deutsche Bank National Trust Co., ;COURT OF COMMON PLEAS as Trustee under the Pooling and :CIVIL DIVISION Servicing Agreement dated as of :Cumberland County March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 :MORTGAGE FORECLOSURE 4828 Loop Central Drive Houston, TX 77081 Plaintiff V. Connie L. Paylor :NO. 07-925 CIVIL TERM 200 4th Street, Box 58 Summerdale, PA 17093 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant (s) Connie L. Paylor for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $83,614.79 Interest Per Complaint 1,425.48 From 1/27/07 to 4/20/07 Late charges per Complaint 80.82 From 1/27/07 to 4/20/07 Escrow payment per Complaint 159.00 From 1/27/07 to 4/20/07 TOTAL $85,280.09 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been giv n in accordance with Rule 237.1, a copy of which is attached hereto. J UftEN L?OFFICES, .C. ark`s. Udren;'ESQUIRE ttorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDI D DATE : ApAIL PR PROTH UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CSNTSR 111 WOODCREST ROAD, SUITE 200 CHERRY BILL, NJ 08003 856-669-5400 pleadinao@udrIM.com Deutsche Bank National Trust Company, as Trustee under the Pooling and Servicing A reement dated as of March 1, 2006, G9RPM Mortgage Loan Trust 2006-1 Plaintiff V. Connie L. Paylor Defendant(s) TO: Connie L. Paylor 200 4th Street Box 58 Summerdale, PA 17093 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 07-925 Civil Term DATE of Notice: April 9, 2007 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE LISTED BE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DESIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION BE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE BE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO TH8 FAIR DEST COLLECTION PRACTICES ACT, IS LAW FIRM IS DEEMED TO BE A DEBT COLLSC R THIS IS AN ATTEMPT TO CO SCT A DEBT. ANY INFORMATION OBTAINED WILL S FOR THAT POSS. s squire Wo crest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 LIZ UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust Co., ::COURT OF COMMON PLEAS as Trustee under the Pooling and :CIVIL DIVISION Servicing Agreement dated as of :Cumberland County March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 =MORTGAGE FORECLOSURE Plaintiff V. Connie L. Paylor €:NO. 07-925 CIVIL TERM Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NEW JERSEY COUNTY OF CAMDEN SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Servicemembers' Civil Relief Act (108 P.L. 189; 117 Stat. 2835; 2003 Enacted H.R. 100), and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Connie L. Paylor Over 18 As captioned above Unknown Sworn to and subscribed before me this 20th day 9f April, 2007. Name:i Title. 4ARK J.--UDREN, ESQ. ATTORNEY FOR PLAINTIFF UDREN LAW OFFICES, P.C. mary?,^ wm - PUI OFNEWJER3EY COMMMONt D09 116/20 ` SHERIFF'S RETURN - REGULAR! /???t CASE NO: 2007-00925 P tv ''i COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUS VS PAYLOR CONNIE L TIMOTHY REITZ Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT MORT FORE was served upon PAYLOR CONNIE L the DEFENDANT , at 1112:00 HOURS, on the 16th day of March 2007.. at 2.00 4TH STREET SUMMERDALE, PA 17093 by handing to CONNIE L PAYLOR a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 43.20 Affidavit .00 Surcharge 10.00 .00 71.20 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 03/19/2007 UDREN LAW OFFICES By: puty S rif f A.D. } Verbal Confirmation of Service of Complaint Date: Spoke with: Defsndant(s):(?? was served on at: Defendant(s): at: was served on Defendant(s): was served on I at: • Are there any !additional fees due? Yes If so how much?_$ 06 ~` .. CA) n ? UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Co., :COURT OF COMMON PLEAS as Trustee under the Pooling and -CIVIL DIVISION Servicing Agreement dated as of :Cumberland County March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 :MORTGAGE FORECLOSURE Plaintiff V. Connie L. Paylor ::NO. 07-925 CIVIL TERM Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $85,280.09 Interest From 4/21/07 2,341.86 to Date of Sale 9/5/07 Ongoing Per Diem of 16.97 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN LAW OFFICES, P.C. mark-J. Uuren, ESQUIRE ATTORNEY FOR PLAINTIFF A ? 4CL ..? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-925 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST CO., AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MARCH 1, 2006, GSRPM MORTGAGE LOAN TRUST 2006-1, Plaintiff (s) From CONNIE L. PAYLOR (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 $85,280.09 L.L. $.50 Interest FROM 4/21/07 TO DATE OF SALE 9/5/07 - ONGOING PER DIEM OF $16.97 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $2,341.86 Atty's Comm % Atty Paid $167.20 Plaintiff Paid Date: APRIL 20, 2007 (Seal) Due Prothy $2.00 Other Costs CurtA R. Long on tart' By: Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Co., 'COURT OF COMMON PLEAS as Trustee under the Pooling and =CIVIL DIVISION Servicing Agreement dated as of Cumberland County March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 'MORTGAGE FORECLOSURE Plaintiff V. Connie L. Paylor ':NO. 07-925 CIVIL TERM Defendant(s) C E R T I F I C A T E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is. ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( x ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. U N 77N? OFFICES, .C. ark J. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF p n .? ,._ xw cj p w I UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCRLST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Co., :COURT OF COMMON PLEAS as Trustee under the Pooling and :CIVIL DIVISION Servicing Agreement dated as'of :Cumberland County March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 =MORTGAGE FORECLOSURE Plaintiff V. Connie L. Paylor :NO. 07-925 CIVIL TERM Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Deutsche Bank National Trust Co., as Trustee under the Pooling and Servicing Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 200 4th Street, (East Pennsboro Township) Summerdale, PA 17093 1. Name and address of Owner(s) or reputed Owner(s): Name Address Connie L. Paylor 200 4th Street, Box 58 Summerdale, PA 17093 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address none } 4. Name and address of of record: Name the last recorded holder of every mortgage Deutsche Bank National Trust Co., as Trustee under the Pooling and Servicing Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 GMAC Mortgage Corporation Address 4828 Loop Central Drive Houston, TX 77081 P.O. Box 4622, Waterloo, IA 50704 c/o The Law Offices of Barbara A. Fein, PC, Barbara A. Fien and Kristen J. Dipaolo, 425 Commerce Drive, Suite 100, Fort Washington PA 19034 5. Name and address of every other person who has any record lien on the property: Name Address East Pennsboro Township Address to Follow 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: Name Address Real Estate Tax Department Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, PA 17013 13 North Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 M 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 200 4th Street (East Pennsboro Township) Summerdale, PA 17093 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. sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES,,--V-.C. DATED: April 20, 2007 Mark J. Udren, ESQ. Attorney for Plaintiff C-3 c? W UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Co., ;COURT OF COMMON PLEAS as Trustee under the Pooling and :CIVIL DIVISION Servicing Agreement dated as of :Cumberland County March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 :MORTGAGE FORECLOSURE Plaintiff V. Connie L. Paylor ::NO. 07-925 CIVIL TERM Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Connie L. Paylor 200 4th Street, Box 58 Summerdale, PA 17093 Your house (real estate) at 200 4th Street, (East Pennsboro Township) Summerdale, PA 17093 is scheduled to be sold at the Sheriff's Sale on September 5, 2007, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $85,280.09, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) N YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 Q Q y't 1 4? T + z ? ? ...r ?{ ' ? ` ? - ?,, C? - ? ^ j t? ; '"? ?._' ? ? ?7 43 SHERIFF'S RETURN - REGULAR CASE NO: 2007-00925 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS PAYLOR CONNIE L TIMOTHY REITZ Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon PAYLOR CONNIE L the DEFENDANT , at 1112:00 HOURS, on the 16th day of March , 2007 at 200 4TH STREET SUMMERDALE, PA 17093 CONNIE L PAYLOR by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 43.20 Affidavit .00 Surcharge 10.00 .00 3/l4/6? C 7z0 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 03/19/2007 UDREN LAW OFFICES By puty S riff A.D. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCRBST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust .COURT OF COMMON PLEAS Co., as Trustee under the ;CIVIL DIVISION Pooling and Servicing :Cumberland County Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 4828 Loop Central Drive Houston, TX 77081 Plaintiff V. Connie L. Paylor 200 4th Street, Box 58 Summerdale, PA 17093 Defendant(s) NO. 07-925 CIVIL TERM AFFIDAVIT OF SERVICE PURSUANT TO PB.R.C.P.RULE 3`129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriffs Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriffs Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. if service was by order of Court, then proof of compliance with said order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to th relating to unsworn falsification to Dated: August 30, 2007 BY: ties of 18 Pa.C.S. Section 4904 UDREN LAW P. C. marx U .- uaren, zs ire Attorney for Plaint f DDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Co., as Trustee under the Pooling and Servicing Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 Plaintiff V. Connie L. Paylor Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 07-925 CIVIL TERM AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Deutsche Bank National Trust Co., as Trustee under the Pooling and Servicing Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ.; sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 200 4th Street, (East Pennsboro Township) Summerdale, PA 17093 1. Name and address of Owner(s) or reputed Owner(s): Name Address Connie L. Paylor 200 4th Street, Box 58 Summerdale, PA 17093 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address none 4. Name and address of the of record: Name Deutsche Bank National Trust Co., as Trustee under the Pooling and Servicing Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 GMAC Mortgage Corporation last recorded holder of every mortgage Address 4828 Loop Central Drive Houston, TX 77081 P.O. Box 4622, Waterloo, IA 50704 c/o The Law Offices of Barbara A. Fein, PC, Barbara A. Fien and Kristen J. Dipaolo, 425 Commerce Drive, Suite 100, Fort Washington PA 19034 5. Name and address of every other person who has any record lien on the property: Name Address East Pennsboro Township 98 South Enola Drive Enola, PA 17025 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: Name. Address Real Estate Tax Department Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, PA 17013 13 North Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 200 4th Street (East Pennsboro Township) Summerdale, PA 17093 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. sec. 4904 relating to unsworn falsification to authorities. IC)M, P. C. DATED: August 30, 2007 Mark J Udren, squire Attorn v for Pla tiff UDREN LAWOFFICES, P:C. BY: Mark J. Udren, Esquire ATTY I.D. NO.04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY `HILL, NJ 06003-3620 k669»5it80 ATTORNEY FOR PLAINTIFF Deutsche Bank National Trust Co., as COURT OF COMMON PLEAS Trustee under the Pooling and Servicing :::'CIVIL DIVISION Agreement dated as of March,1, 2006, = Cumberland -County , GSRPM Mortgage Loan Trust 2006-1 Plaintiff '-- NO. 07-925 CIVIL TERM V. Connie L. Paylor Defendant(s) TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Connie L. Paylor PROPERTY: 200 4th Street, (East Pennsboro Township) Summerdale, PA 17093 Improvements: RESIDENTIAL DWELLING. The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on SeRkmber 5. 2007, at 10:00 am, at the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or.judgment on the property-which will be extinguished by the sale. You may wish to attend the sale to protect your interests. 4 A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT A I t I I 1i t? N ?- u Q M 6 ,6 to U. dLL E t' m m c E ?o ? w CIO 8 ?a E a u I o l I? D ? U{W?M N?? s 4 --? Z O -? gW? UU Wp= oc ? 12t 0 1 ?? 0 n. F, ? I a ? po0 a ?a z a ui o W `J A w O 00 U cy QWi at ? UU >g o w ui na C?O s to t N E U X Woo 024, Z ZZ mm d? CD "A 0% oa -i ?YL r? o .E 3 ?W U U? CL o+ as Z N O O I g$ $ ng a 6 o a ?M ? rj m 13 r O p ? T ro??J? E? '1mis ?E Ag g t3 L $ r fi n soS CO c ? 3 N it r ,4, t 3tN, E z` m a 1 a m a a°. m 0 c r r? 0 vmz Y 0 CL. aAex to ? U. M `E I U. N a C d r 1t? O O Q 0 J N C U Deutsche Bank National Trust Co, as In the Court of Common Pleas of Trustee under the Pooling and Servicing Cumberland County, Pennsylvania Agreement dated as of March 1, 2006, Writ No. 2007-925 Civil Term GSRPM Mortgage Loan Trust 2006-1 VS Connie L. Paylor Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on May 9, 2007 at 1600 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Connie L. Paylor, by making known unto Marty Hake, Adult in Charge, at 200 4th Street, Summerdale, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Megan Marlow, Deputy Sheriff, who being duly sworn according to law, states that on July 12, 2007 at 1837 hours, she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Connie L. Paylor located at 200 0 Street, Summerdale, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Connie L. Paylor, by regular mail to her last known address of 200 4t Street, Summerdale, PA 17093. This letter was mailed under the date of July 2, 2007 and never returned to the Sheriffs Office. So Answers: ?? R. ma s Kline, Siienff B Real Estate ergeant EXHIBIT B ?' v? ? C ra ?? UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust :COURT OF COMMON PLEAS Co., as Trustee under the .CIVIL DIVISION Pooling and Servicing :Cumberland County Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 :NO. 07-925 CIVIL TERM 4828 Loop Central Drive Houston, TX 77081 Plaintiff V. Connie L. Paylor 200 4th Street, Box 58 Summerdale, PA 17093 Defendant(s) SUGGESTION OF BANKRUPTCY To the Prothonotary: Kindly note on the record that the above Defendant, Connie L. Paylor has filed Chapter 13 Bankruptcy in the Middle District of Pennsylvania on September 4, 2007, Bankruptcy Case No. #07-02784. UDREN LAW OFFICES, P.C. Attorneys o Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE C7 ' z C r C::1 -:1 Deutsche Bank National Trust Co, as In the Court of Common Pleas of Trustee under the Pooling and Servicing Cumberland County, Pennsylvania Agreement dated as of March 1, 2006, Writ No. 2007-925 Civil Term GSRPM Mortgage Loan Trust 2006-1 VS Connie L. Paylor Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on May 9, 2007 at 1600 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Connie L. Paylor, by making known unto Marty Hake, Adult in Charge, at 200 41` Street, Summerdale, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Megan Marlow, Deputy Sheriff, who being duly sworn according to law, states that on July 12, 2007 at 1837 hours, she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Connie L. Paylor located at 200 4t' Street, Summerdale, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Connie L. Paylor, by regular mail to her last known address of 200 41' Street, Summerdale, PA 17093. This letter was mailed under the date of July 2, 2007 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Mark Udren. Sheriff s Costs: Docketing 30.00 Poundage 21.49 Advertising 30.00 Posting Handbills 30.00 Law Library .50 Prothonotary 2.00 Mileage 30.72 Levy 30.00 Surcharge 30.00 Law Journal 395.00 Patriot News 440.36 Share of Bills 15.69 Postpone Sale 40.00 $1095.76 ? i?iy?oP `7". O;Z- ('10140 ;d93 /-;to So Answers: R. Thomas Kline, Sheriff B Real Estate Sergeant t 4 ATTORNEY FOR PLAINTIFF UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Require ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Co., ;COURT OF COMMON PLEAS i as Trustee under the Pooling and :CIVIL DIVISION Servicing Agreement dated as'of `:Cumberland County March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 :MORTGAGE FORECLOSURE Plaintiff V. Connie L. Paylor :NO. 07-925 CIVIL TERM Defendant(s) • I AFFIDAVIT PURSUANT TO RULE 3129.1 Deutsche Bank National Trust Co., as Trustee under the Pooling and Servicing Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1, Plaintiff in the ab ove action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for?!the Writ of Execution was filed the f ollowing information concerning the real property located at: 200 4th Street, (East PennsbOro Township) Summerdale, PA 17093 1. Name and address of Owner(s) or reputed owner(s): Name Address Connie L. Paylor 200 4th Street, Box 58 Summerdale, PA 17093 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address none t r 4. Name and address of the last recorded holder of every mortgage of record: Name Address Deutsche Bank National Trust Co., as Trustee under the Pooling and Servicing Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 4828 Loop Central Drive Houston, TX 77081 GMAC Mortgage Corporation P.O. Box 4622, Waterloo, IA 50704 c/o The Law Offices of Barbara A. Fein, PC, Barbara A. Fien and Kristen J. Dipaolo, 425.Commerce Drive, Suite 100, Fort Washington PA 19034 5. Name and address of every other person who has any record-lien on the property: Name Address East Pennsboro Township Address to Follow 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: Name Address Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue 13 North Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 .I , 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 200 4th Street (East Pennsboro Township) Summerdale, PA 17093 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. sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES,,,IT.C. DATED: April 20, 2007 Mark J. Udren, ESQ. Attorney for Plaintiff .I UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Co., ::COURT OF COMMON PLEAS as Trustee under the Pooling and :CIVIL DIVISION Servicing Agreement dated as of :Cumberland County March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 :MORTGAGE FORECLOSURE Plaintiff V. Connie L. Paylor NO. 07-925 CIVIL TERM Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Connie L. Paylor 200 4th Street, Box 58 Summerdale, PA 17093 Your house (real estate) at 200 4th Street, (East Pennsboro Township) Summerdale, PA 17093 is scheduled to be sold at the Sheriff's Sale on September 5, 2007, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse,. Carlisle, PA, to enforce the court judgment of $85,280.09, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE 0 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 the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) r w ? YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ALL THOSE TWO CERTAIN ADJACENT LOTS OR PARCELS OF LAND, TOGETHER WITH THE MWR0VENIENTS THEREON ERECTED, SITUATE IN EAST PENNSBORO TOWNSHIP, CUMBERLAND -COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE NORTHEAST CORNER OF THE INTERSECTION OF FOURTH STREET AND A SIXTEEN (16) FEET WIDE ALLEY; THENCE NORTHWARDLY ALONG THE EASTERN LINE OF FOURTH STREET, SIXTY (60) FEET TO THE SOUTHERN LINE OF LOT NO. 93, SECTION "A", ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ESTWARDLY ALONG THE SOUTHERN LINE OF LOT NO.. 93, SECTION "A", ONE HUNDRED SIXTY (160) FEET TO THE WESTERN LINE OF A SIXTEEN (16) FEET WIDE ALLEY; THENCE SOUTHWARDLY ALONG THE WESTERN LINE OF SAID SIXTEEN (16) FEET WIDE ALLEY, SIXTY (60) FEET TO THE NORTHWEST CORNER OF THE INTERSECTION OF SAID SIXTEEN (16) FEET WIDE ALLEY WITH THE SIXTEEN (16) FEET WIDE ALLEY FIRST MENTIONED; THENCE WESTWARDLY ALONG THE NORTHERN LINE OF THE SIXTEEN (16) FEET WIDE ALLEY FIRST MENTIONED, ONE HUNDRED SIXTY (160) FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOTS NOS. 91 AND 92, SECTION "A" IN THE PLAN OF LOTS KNOWN AS SUMMERDALE, PENNSYLVANIA, SAID PLAN BEING RECORDED. IN THE OFFICE FOR THE RECORDING OF DEEDS IN AND FOR CUMBERLAND COUNTY, IN PLAN BOOK 1, PAGE 44 (REVISED PLAN, BOOK 2, PAGE 109). HAVING THEREON ERECTED A ONE-STORY FRAME DWELLING NUMBER 200 FOURTH STREET, SUMNIERDALE, PENNSYLVANIA. BEING KNOWN AS: 200 4TH STREET, (EAST PENNSBORO TOWNSHIP) SUMMERDALE, PA 17093 PROPERTY ID NO.: 09-12-2994-052 TITLE TO SAID PREMISES IS VESTED IN CONNIE L. PAYLOR BY DEED FROM EVA H. SINGLE, WIDOW DATED 6/17/88 RECORDED 6/21/88 IN DEED BOOK K33 PAGE 417. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 07-925 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST CO., AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MARCH 1, 2006, GSRPM MORTGAGE LOAN TRUST 2006-1, Plaintiff (s) From CONNIE L. PAYLOR (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 $85,280.09 L.L. $.50 Interest FROM 4/21/07 TO DATE OF SALE 9/5/07 - ONGOING PER DIEM OF $16.97 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $2,341.86 Atty's Comm % Due Prothy $2.00 Atty Paid $167.20 Other Costs Plaintiff Paid Date: APRIL 20, 2007 (Seal) Curti . Long, Pr n ary By: Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 r"LA • Real Estate Sale # 25 On May 2, 2007 the Sheriff levied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, PA Known and numbered as 200 4th Street, Summerdale, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 2, 2007 By: Real Estate ergeant bJ :b V 9Z HO LOOT k f THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Shannon D. Billhime, being duly sworn according to law, deposes and says: That she is a Staff Accountant with The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 18th and 25th day(s) of July and the 1st day(s) of August 2007. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot.-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY SALE #25 kac ...b .......... Sworn to and subscribed before me this 20th day of August 2007 A.D. 7 rrv i. - NO RY PUBLIC CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 RAW EGW* Sob No. 25 writ No. T-m Cm Term Deutsche Sank NatonN Trust Co., as Trustee under the Pooling and Servicing Agreement dated as of March 1 2006, GSRPM Mortgage Loan ?rust 2006=1 VS Connie L ftylor Atty. Not Udren ALL THOSE TWO CW..iIN ADJACENT LOTS OR PARCELS OF LAND, TOGETHER WITH THE IMPRUVI11MIN0 THEREON ERECTED, SITUATE IN L4f PENNSBORO TOWNSHIP, CLWAIER AND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A `POINT IN THE NORTHEAST CORNER OF THE INTERSECTION OF FOURTH STREET AND A SIXTEEN (16) FEET WIDE ALLEY; THENCE NORTHWARDLY ALONG THE EASTERN LINE OF FOURTH STREET, SIXTY (60) FEET TO THE SOUTHERN LINE OF LOT NO. 93, SECTION "A", ON THE HEREINAFTER, MENTIONED PLAN OF LOTS; THENCE EASTWARDLY ALONG THE SOUTHERN LINE OF LOT NO. 93, SECTION "A", ONE HUNDRED SIXTY (160) FEET TO THE WESTERN LINE OF A SIXTEEIN (16) FEET W$ E ALLEY; THENCE SOUTHWARDLY ALONG THE WESTERN LINE OF SAID SIXTEEN (16) FEET WIDE ALLEY, SIXTY (60) FEET TO THE NORTHWEST CORNER OF THE INTERSECTION OF SAID SIXTEEN (16) FEET WIDE ALLEY WITH THE SIXTEEN (16) FEET WIDE ALLEY, FIRST MENTIONED; THENCE WESTWARDLY ALONG THE NOON LINE OF THE SIXTEEN (16) FEET WIDE ALLEY FIRST IENIJM, ONE HUNDRED S=(160) FEETTO A POINT. THE PLACE OF BEGINNING. BEING LOTS NOS. 91 AND 92, SECTION "A" IN THE PLAN OF LOTS KNOWN AS SUMMERDALE, PENNSYLVANIA, SAID PLAN BEING RECORDED IN THE OFFICE FORTHE RECORDING Of DEEDS IN AND FOR CUMBERLAND COUNTY, IN PLAN BOOK 1, PAGE 44 (REVISED PLAN, BOOK 2, PAGE 109). HAVING THEREON ERECTED A ONE- STORY FRAME DWELLING NUMBER 200 FOURTH STREET, SUMMERDALE, PENNSYLVANIA. BEING KNOWN AS: 200 4TH STREET, EAST PENNSBORO TOWNSHIP) SUMMERDALE, PA 17093 ` PROPERTY ID NO.: 09-12-2994-052 TM,E TO SAID PREMISES IS VESTED IN CONNIE L. PAYLOR BY DEED FROM EVA H. SINGLE, WIDOW DATED 6/17/88 RECORDED 6121/88 IN DEED BOOK K33 PAGE 417. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under A.ct 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: July 20, July 27, and August 3, 2007 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. isa arie Coyne, E for SWORN TO AND SUBSCRIBED before me this 3 day of August, :2007 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 REAL ESTATE SALE NO. 25 Writ _No. 2007 923 e=vil Deutsche Bank National Trust Co., as Trustee under the Pooling and Servicing Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-7. VS. Connie L. Paylor Atta.: Mark udren DESCRIPTION ALL those two certain adjacent lots or parcels of land, together with the improvements thereon erected, situate in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in the northeast corner of the intersection of Fourth Street and a sixteen (16) feet wide alley; thence nor-thwardly along the eastern line of Fourth Street, sixty (60) feet to the southern .me or 1,01 No. 93, Section "A", on the hereinaf- ter, mentioned plan of lots; thence eastwardly along the suutl.ern line of Lot No. 93, Section "A", one hundred sixty (160) feet to the western line of a sixteen (1.6) feet wide alley; thence southwardl_y along the western line of said sixteen (16) feet wide alley, sixty (60) feet to the northwest corner of the intersection of said sixteen (16) feet wide alley with the sixteen (16) feet wide alley. first mentioned, thence westwardly along the north- ern line of the sixteen (16) feet wide alley first mentioned. one hundred sixty (160) feet to a point, the place of beginning. BEING Lots Nos. 91 and 92, Sec- tion "A" in the plan of lots known as Summerdale, Pennsylvania, said plan being recorded in the office for the Recording of Deeds in and for Cumberland County, in Plan Book 1, Page 44 (Revised Plan, Book 2, Page 109). HAVING THEREON ERECTED a one-story frame dwelling number 200 Fourth Street. Summerdale, Pennsylvania. BEING KNOWN AS. 200 4th Street, (East Pennsboro Township) Summerdale, PA 17093. PROPERTY ID NO : 09-12-2994- 0,2. TITLE TO SAID PREMISES IS VESTED IN Connie L. Paylor by deed from Eva H. Single, widow dated 6/17,188 recorded 6' /21/88 in Deed Book K33 Page 417. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsoudren.com Deutsche Bank National Trust €:COURT OF COMMON PLEAS Co., as Trustee under the ::CIVIL DIVISION Pooling and Servicing :Cumberland County Agreement dated as of March 1, 2006, GSRPM Mortgage Loan. ::MORTGAGE FORECLOSURE Trust 2006-1 Plaintiff V. E Connie L. Paylor ENO. 07-925 CIVIL TERM Defendant(s) PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the-above matter: Amount due $85,280.09 Interest From 4/21/07 17,784.56 to Date of Sale March 3, 2010 Ongoing Per Diem of 16.97 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN LAW OFFIC S, P.C. BY Attorneys for aintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE 0 F LED -CfFICE OF THE PP.,0- ONUTARY 2009 OCT -8 AM i I: 40 CUW' .- ,._ tt,rS( 6o)!'? ?t.?JTY #24.00 Po ATN 71-40 CBF 1, 045.7(0 to 56.50 " Woo a q. po n $ a84.44 , - a 4,2.00 Uueco erg 1'ro 0 as rtooLq ,2E Lori+ ? F, ?? IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: CONNIE LOU PAYLOR Debtor Bk. No. 1:07-bk-02784 MDF LITTON LOAN SERVICING, AS SERVICER FOR Chapter No. 13 THE MORTGAGEE OF RECORD V. CONNIE LOU PAYLOR Respondent Movant 11 U.S.C. §362 ORDER MODIFYING SECTION 362 AUTOMATIC STAY Upon Consideration of the Motion of LITTON LOAN SERVICING, AS SERVICER FOR THE MORTGAGEE OF RECORD (Movant), and after Notice of Default and the filing of a Certification of Default, it is: ORDERED AND DECREED THAT: The Automatic stay of all proceedings, as provided by 11 U.S.C. 362 is modified with respect to premises, 200 FOURTH STREET, SUMMERDALE, PA 17093, as more fully set forth in the legal description attached to said mortgage, as to allow the Movant to foreclose on its mortgage or take any legal or consensual action enforcement of its right to possession of, or title to, said premises (such actions may include but are not limited to the signing of a deed in lieu of foreclosure or entering into a loan modification agreement) and to allow the purchaser of said premises at Sheriff's Sale (or purchaser's assignee) to take any legal or consensual action for enforcement of its right to possession of, or title to, said premises; and it is further; ORDERED AND DECREED THAT: Rule 4001(a)(3) is not applicable and LITTON LOAN SERVICING, AS SERVICER FOR THE MORTGAGEE OF RECORD may immediately enforce and implement this Order granting Relief from the Automatic Stay. By the covet, J ig' {]DK) This do=wnt is elaactronioally signed and filed on the sate date. Dated: August 18, 2009 Case 1:07-bk-02784-MDF Doc 48 Filed 08/18/09 Entered 08/19/09 11:07:00 Desc Main Document Page 1 of 1 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust :COURT OF COMMON PLEAS Co., as Trustee under the :CIVIL DIVISION Pooling and Servicing :Cumberland County Agreement dated as of March 1, 2006, GSRPM Mortgage Loan :MORTGAGE FORECLOSURE Trust 2006-1 Plaintiff V. Connie L. Paylor :NO. 07-925 CIVIL TERM Defendant(s) CERTIFICATE TO THE SHERIFF I HEREBY CERTIFY THAT: I. The judgment entered in the above matter is based on an Action: A. In Assumpsit (Contract) B. In Trespass (Accident) X C. In Mortgage Foreclosure D. On a Note accompanying a purchase money mortgage and the property being exposed to sale is the mortgaged property. II. The Defendant(s) own the property being exposed to sale as: X A. An individual B. Tenants by Entireties C. Joint Tenants with right of survivorship D. A partnership E. Tenants in Common F. A corporation III. The Defendant(s) is (are): X A. Resident in the Commonwealth of Pennsylvania B. Not resident in the Commonwealth of Pennsylvania C. If more than one Defendant and either A or B above is not applicable, state which Defendant is resident of the Commonwealth of Pennsylvania. Resident: UDREN LAW OFF CES, P.C. BY: Attorneys for' gaotiff MARK J. UDREN, VaQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE FILEQ-OF- CE OF THE' PROTHONOTARY 2009 OCT -8 AEI 11 : 40 CU Niw :-4 --?JUNTY FENNS IN 1 "' UDREN LA79 OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust :COURT OF COMMON PLEAS Co., as Trustee under the :CIVIL DIVISION Pooling and Servicing :Cumberland County Agreement dated as of March 1, 2006, GSRPM Mortgage Loan :MORTGAGE FORECLOSURE Trust 2006-1 Plaintiff V. Connie L. Paylor :NO. 07-925 CIVIL TERM Defendant(s) C E R T I F I C A T E I hereby state that as the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( X ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFIC S P.C. BY: Attorneys foia 1 ntiff MARK J. UDREN, SQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE FiLEa -C)%K CE ,)E TNc p, ?IOTAa'f 2009 OCT -8 AM 11 40 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust :COURT OF COMMON PLEAS Co., as Trustee under the `CIVIL DIVISION Pooling and Servicing :Cumberland County Agreement dated as of March 1, 2006, GSRPM Mortgage Loan :MORTGAGE FORECLOSURE Trust 2006-1 Plaintiff V. Connie L. Paylor :NO. 07-925 CIVIL TERM Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Deutsche Bank National Trust Co., as Trustee under the Pooling and Servicing Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 200 4th Street, Summerdale, PA 17093 1. Name and address of Owner(s) or reputed Owner(s): Name Address Connie L. Paylor 200 4th Street, Box 58 Summerdale, PA 17093 2. Name and address Name SAME AS #1 ABOVE 3. Name and address a record lien on th Name of Defendant(s) in the judgment: Address of every judgment creditor whose judgment is e real property to be sold: Address None 1 y 4. Name and address of record: Name of the last recorded holder of every mortgage Deutsche Bank National Trust Co., as Trustee under the Pooling and Servicing Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 GMAC Mortgage Corporation Address 4828 Loop Central Drive Houston, TX 77081 P.O. Box 4622, Waterloo, IA 50704 c/o The Law Offices of Barbara A. Fein, PC, Barbara A. Fien and Kristen J. Dipaolo, 425 Commerce Drive, Suite 100, Fort Washington PA 19034 5. Name and address of every other person who has any record lien on the property: Name Address Township of East Pennsboro Address to follow 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: Name Address Real Estate Tax Dept. Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Sq., Carlisle, PA 17013 13 N. Hanover St. Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 200 4th Street Summerdale, PA 17093 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. sec. 4904 relating to unsworn falsification to authorities. DATED: October 5, 2009 UDREN LAW OFFICES, P.C. BY: /y . [f l ` J Attorneys for Pl ntiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE ??1.?'',?? "iA?R'? t?., 4f 2aa? acs -a a? ?? + ?o c ? L???? t UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust :COURT OF COMMON PLEAS Co., as Trustee under the :CIVIL DIVISION Pooling and Servicing :Cumberland County Agreement dated as of March 1, 2006, GSRPM Mortgage Loan :MORTGAGE FORECLOSURE Trust 2006-1 Plaintiff V. Connie L. Paylor :NO. 07-925 CIVIL TERM Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Connie L. Paylor 200 4th Street, Box 58 Summerdale, PA 17093 Your house (real estate) at 200 4th Street (East Pennsboro Township)Summerdale, PA 17093 is scheduled to be sold at the Sheriff's Sale on March 3, 2010, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $85,280.09, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-925 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST CO., as Trustee under the Pooling and Servicing Agreement dated as of March 1, 2006, GSRPM MORTGAGE LOAN TRUST 2006-1, Plaintiff (s) From CONNIE L. PAYLOR (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 $85,280.09 L.L. Interest from 4/21/07 to Date of Sale 3/3/10 Ongoing per diem of $16.97 to actual date of sale including if sale is held at a later date -- $17,784.56 Atty's Comm % Due Prothy $2.00 Atty Paid $1,284.46 Other Costs Plaintiff Paid Date: 10/8/09 A-45 Curtis R. ong, Prothono (Seal) Deputy REQUESTING PARTY: Name: ADAM L. KAYES, ESQUIRE Address: UDREN LAW OFFICES, PC WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 86408 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN fit. MINATO, ESQUIRE - ID #75860 PHANDRA M. ARKEMA, ESQUIRE - ID #203437 ?' ca LOUIS A. SIMONI, ESQUIRE - ID #200869 ci?l ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 ?- WOODCREST CORPORATE CENTER _``) 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Co., as Trustee € COURT OF COMMON PLEA under the Pooling and Servicing Agreement =CIVIL DIVISION dated as of March 1, 2006, GSRPM Mortgage :Cumberland County Loan Trust 2006-1 4828 Loop Central Drive Houston, TX 77081 Plaintiff V. Connie L. Paylor 200 4th Street, Box 58 :NO. 07-925 CIVIL TERM Summerdale, PA 17093 Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: January 22, 2010 UD N 0 ICES, P. C. BY Atto Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ,4ffOFJIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE ?UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust :COURT OF COMMON PLEAS Co., as Trustee under the :CIVIL DIVISION Pooling and Servicing :Cumberland County Agreement dated as of March 1, 2006, GSRPM Mortgage Loan :MORTGAGE FORECLOSURE Trust 2006-1 Plaintiff V. Connie L. Paylor ::NO. 07-925 CIVIL TERM Defendant(s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Deutsche Bank National Trust Co., as Trustee under the Pooling and Servicing Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 200 4th Street, Summerdale, PA 17093 1. Name and address of Owner(s) or reputed Owner(s): Name Address Connie L. Paylor 200 4th Street, Box 58 Summerdale, PA 17093 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None ,4. Name and address of record: Name of the last recorded holder of every mortgage Deutsche Bank National Trust Co., as Trustee under the Pooling and Servicing Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 GMAC Mortgage Corporation Address 4828 Loop Central Drive Houston, TX 77081 P.O. Box 4622, Waterloo, IA 50704 c/o The Law Offices of Barbara A. Fein, PC, Barbara A. Fien and Kristen J. Dipaolo, 425 Commerce Drive, Suite 100, Fort Washington PA 19034 5. Name and address of every other person who has any record lien on the property: Name Address Township of East Pennsboro 98 South Enola Drive Enola, PA 17025 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: Name Address Real Estate Tax Dept. Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Sq., Carlisle, PA 17013 13 N. Hanover St. Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 200 4th Street Summerdale, PA 17093 ,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. sec. 4904 relating to unsworn falsification to authorities. DATED: January 22, 2010 UDREX LA%,,9FFICES, P.C. BY: ? Attorneys or Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE VMIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Co., as Trustee under the Pooling and Servicing Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 Plaintiff V. Connie L. Paylor Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 07-925 CIVIL TERM TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Connie L. Paylor PROPERTY: 200 4th Street, (East Pennsboro Township) Summerdale, PA 17093 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on March 3, 2010, at 10:00 am, in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. U a; n 0 3 CD' r O 4t O 4 O_ O CA 1 n C ts' CD C2 Cn O B w C0 V V TI CD C Cl) CID co A a 3 C U) ,P? <D n O <D CL ?C G <D 1 7 O IM Df tD 7 r G1 A W N O co OD V O Cn A W N - Q Z y 6 C CD ? ?' G (D cD V m m CA) o c D m?? i :3 o o w N iD N 3 Q N Q c m o ? rn o 0-0 G7 G) vm -0--1 -0 n cn0 00 Z M.0K m 0 W ? Dy mm b K 0 OC m j i n i 0 ZD ao -n mm MW `D D n p 0 me ?v9 - 3 N? co? Q ?cl _M --I 2 0 --I m o? cS ?OCD ?D nn O? a M ? OZ oDo 0 o OC) ?O ,> ;o;u ?Z m ??r N o ATV v o 0 M r- m F - m 0 U) o w mD 0 70 0 M ?D 2 n ? 00 M co 3 r? ? E ?'? O W 0 In Z cc w O r? ?Om m ?gym o rn -1 Ccn ;? -0 Dfn DZ M? CD T C7 O Z1 Z ? ? x A v ?N ?o m ?< ?m fn ? O > - ?0m _0 S wQ N N W Z A m1 CW 00 C) DD 7 a 00 Co co ° n 3 X03 D 0 0 = r- W G)M ' M w0 r r M o pC? K w- o m n C Z CA m? O i 171 f7 CJ 0 O fD m O Z m N A Am N °o m D- -I ? D c C) D < V.. ? m N 0 oD D V Q Z o m cn m wD U 9 ?_0 F3 Z o m n 3 y C, - - ) r w N 3 4 C) M --I w O y O T fD (D A O _ Z M 1:1 ED ?? M CD CD 00 c N CL n m o CD a m a ! 1 w `° 0 m 1 m ? ?CCDD ? A -e" 4 Fw M CD a--Ll (D 3 (a CD (D C14 CL CD LD A 3 m S m c 1 . O a oK 0 3 c 'u ;: •: ,, ,?' 1 a' JJ s:9 a_ <° 1 @,? MaiiPd Fro 080 0 -' 1 0, ... 1 0M ao c m w m =r 0) C m .2-0 = Ip? < < y'n o N y ON a o m S S N fll 3'O QOmm '. o n? m3m0o'^ m m' m m m 'm N n C ?-• V rn 7?0 N N N m ? > ; 0 N v 07 C c 0 m m o o a o si on A j c Cr 3 0 m c N c n Ch m m y a ro a O Mo y'jc 3 m = c N N m 3 x > " m - 3 c?° ?° 3f° p tv D O a nm ? d??n 3 C?c OCD y g.x K a mmm p p m mOS2.o2 m o o- o d C a N 9193 N 8 R -0 5,m 3 m m , n a 3 (D . m - . N 21r a a ,zmvm@m -n ;a Q) N ?. fD r o m y 0 o n CD ?1 ED OR t0 mmm°-'m=m3 . ?R c = x m vmcm2 i -n 9) N CD Qo a n w ? m °m m O CD - w . 3 o m m = 3 } oEi , - 0 y cD 2 ? 'O C 3 ? N = 01mmav+? y o o m° 3 (D CO m 3 m d. o° m .? e 3 ' d N fD = a v d . ?y .W;- CD SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Speriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor ., d ERIFF Deutsche Bank National Trust Company Case Number vs. 2007-925 Connie L Paylor SHERIFF'S RETURN OF SERVICE 12/23/2009 05:16 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on December 23, 2009 at 1716 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 Connie L. Paylor, located at, 200 4th Street, Summerdale, Cumberland County, Pennsylvania according to law. 01/05/2010 05:14 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on January 5, 2010 at 1714 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Connie L. Paylor, by making known unto, Frank Gorsuett, boyfriend of defendant, at, 200 4th Street, Box 58, Summerdale, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. REM% i t i (c CcUtllySuao Sh0nf, Teloosoft , In;;_ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor QF-F3 "E OF '-F -ERIFF Deutsche Bank National Trust Company Case Number vs. Connie L Paylor 2007-925 SHERIFF'S RETURN OF SERVICE 12/23/2009 05:16 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on December 23, 2009 at 1716 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 Connie L. Paylor, located at, 200 4th Street, Summerdale, Cumberland County, Pennsylvania according to law. 01/05/2010 05:14 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on January 5, 2010 at 1714 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Connie L. Paylor, by making known unto, Frank Gorsuett, boyfriend of defendant, at, 200 4th Street, Box 58, Summerdale, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 03/03/2010 Ronny R. Anderson, 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 March 3, 2010 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Mark J. Udren , on behalf of , Deutsche Bank National Trust Col, as Trustee under the Pooling and Servicing Agreement dates as ofMarch 1, 2006, GSRPM Mortgage Loan Trust 2006-1, 4828 Loop Central Drive, Houston, TX 77081, being the buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of $ 1007.26 SHERIFF COST: $1,007.26 March 22, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF 4f. 00 cd. o ,C-o cc, 464 74fW?' > ;z 3 g vr7 ip) Coun!ySutte Shenfl. I elecsoft . Inc. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 WOODCREST CORPORATE CEN'T'ER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust :COURT OF COMMON PLEAS Co., as Trustee under the =CIVIL DIVISION Pooling and Servicing :Cumberland County Agreement dated as of March 1, 2006, GSRPM Mortgage Loan :MORTGAGE FORECLOSURE Trust 2006-1 Plaintiff V. Connie L. Paylor ENO. 07-925 CIVIL TERM Defendant (s) AFFIDAVIT PURSUANT TO RULE 3129.1 Deutsche Bank National Trust Co., as Trustee under the Pooling and Servicing Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 200 4th Street, Summerdale, PA 17093 1. Name and address of Owner(s) or reputed Owner(s): Name Address Connie L. Paylor 200 4th Street, Box 58 Summerdale, PA 17093 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None n 4. Name and address of the last recorded holder of every mortgage of record: Name Address Deutsche Bank National Trust Co., as Trustee under the Pooling and Servicing Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 GMAC Mortgage Corporation c/o The Law Offices of Barbara A. Fein, PC, Barbara A. Fien and Kristen J. Dipaolo, 425 Commerce Drive, Suite 100, Fort Washington PA 19034 5. Name and address of every other person who has any record lien on the property: Name Address Township of East Pennsboro Address to follow 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: Name Address Real Estate Tax Dept Domestic Relations Section Commonwealth of PA, Department of Revenue 4828 Loop Central Drive Houston, TX 77081 P.O. Box 4622, Waterloo, IA 50704 1 Courthouse Sq., Carlisle, PA 17013 13 N. Hanover St. Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 200 4th Street Summerdale, PA 17093 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. sec. 4904 relating to unsworn falsification to authorities. DATED: October 5, 2009 UDREN LAW OFFICES, P.C. BY: Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE 4- UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust Co., as Trustee under the Pooling and Servicing Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 Plaintiff V. Connie L. Paylor Defendant(s) ATTORNEY FOR PLAINTIFF :COURT OF COMMON PLEAS :CIVIL DIVISION :_Cumberland County MORTGAGE FORECLOSURE NO. 07-925 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. TO: Connie L. Paylor 200 4th Street, Box 58 Summerdale, PA 17093 Your house (real estate) at 200 4th Street (East Pennsboro Township)Summerdale, PA 17093 is scheduled to be sold at the Sheriff's Sale on March 3, 2010, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $85,280.09, obtained by Plaintiff above (the mortgagee) against: you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) i YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ALL THOSE TWO CERTAIN ADJACENT LOTS OR PARCELS OF LAND, TOGETHER WITH THE IMPROVEMENTS THEREON ERECTED, SITUATE IN EAST PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE NORTHEAST CORNER OF THE INTERSECTION OF FOURTH STREET AND SIXTEEN (16) FEET WIDE ALLEY; THENCE NORTHWARDLY ALONG THE EASTERN LINE OF FOURTH STREET, SIXTY (60)FEET TO THE SOUTHERN LINE OF LOT NO. 93, SECTION "A", ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE EASTWARDLY ALONG THE SOUTHERN LINE OF LOT NO. 93, SECTION "All, ONE HUNDRED SIXTY (160) FEET TO THE WESTERN LINE OF A SIXTEEN (16) FEET WIDE ALLEY; THENCE SOUTHWARDLY ALONG THE WESTERN LINE OF SAID SIXTEEN (16) FEET WIDE ALLEY, SIXTY (60) FEET TO THE NORTHWEST CORNER OF THE INTERSECTION OF SAID SIXTEEN (16) FEET WIDE ALLEY WITH THE SIXTEEN (16) FEET WIDE ALLEY FIRST MENTIONED; THENCE WESTWARDLY ALONG THE NORTHERN LINE OF THE SIXTEEN (16) FEET WIDE ALLEY FIRST MENTIONED, ONE HUNDRED SIXTY (160) FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOTS NOS. 91 AND 92, SECTION "A" IN THE PLAN OF LOTS KNOWN AS SUMMERDALE, PENNSYLVANIA, SAID PLAN BEING RECORDED IN THE OFFICE FOR THE RECORDING OF DEEDS IN AND FOR CUMBERLAND COUNTY, IN PLAN BOOK 1, PAGE 44 (REVISED PLAN, BOOK 2, PAGE 109). HAVING THEREON ERECTED A ONE-STORY FRAME DWELLING NUMBER 200 FOURTH STREET, SUMMERDALE, PENNSYLVANIA. BEING KNOWN AS: 200 4T" STREET, SUMMERDALE, PA 17093 PROPERTY ID NO.: 09-12-2994-052 TITLE TO SAID PREMISES IS VESTED IN CONNIE L. PAYLOR BY DEED FROM EVA H. SINGLE, WIDOW DATED 6/17/88 RECORDED 6/21/88 IN DEED BOOK K33 PAGE 417. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 07-925 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST CO., as Trustee under the Pooling and Servicing Agreement dated as of March 1, 2006, GSRPM MORTGAGE LOAN TRUST 2006-1, Plaintiff (s) From CONNIE L. PAYLOR (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 $85,280.09 L.L. Interest from 4/21/07 to Date of Sale 313110 Ongoing per diem of $16.97 to actual date of sale including if sale is held at a later date -- $17,784.56 Atty's Comm % Due Prothy $2.00 Atty Paid $1,284.46 Other Costs Plaintiff Paid Date: 10/8/09 "D, Curtis R. Lone. Prothono] (Seal) Deputy REQUESTING PARTY: Name: ADAM L. KAYES, ESQUIRE Address: UDREN LAW OFFICES, PC WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 86408 On November 5, 2009 the Sheriff levied upon the defendant's interest in the real property situated in EastPennsboro Township, Cumberland County, PA, Known and numbered as 200 4th Street, Summerdale, moi fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 5, 2009 By: Real Estate Coordinator A F} C? ? \ l 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 22, January 29, and Febru 5, 2010 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, Editor TO AND SUBSCRIBED before me this 5 day of February, 2010 V Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY MY Commission Expires Apr 28, 2010 Writ No. 2007-928 Civil Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement dated as of March 1, 2006 GSRPM Mortgage Loan Trust 2006-1 VS. Connie L. Paylor Atty: Mark Udren ALL THOSE TWO CERTAIN adja- cent lots or parcels of land, together with the improvements thereon erected, situate in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and de- scribed as follows, to wit: BEGINNING at a point in the northeast corner of the intersection of Fourth Street and sixteen (16) feet wide alley; Thence northwardly along the eastern line of Fourth Street, sixty (60)feet to the southern line of Lot No. 93, Section `A' on the hereinaf- ter mentioned plan of lots; Thence eastwardly along the southern line of Lot No. 93, Section A one hundred sixty (160) feet to the western line of a sixteen (16) feet wide alley; Thence southwardly along the western line of said sixteen (16) feet wide alley, sixty (60) feet to the northwest corner of the intersection of said sixteen (16) feet wide alley with the sixteen (16) feet wide alley first mentioned; Thence westwardly along the north- ern line of the sixteen (16) feet wide alley first mentioned, one hundred sixty (160) feet to a point, the place of BEGINNING. BEING Lots Nos. 91 and 92, Sec- tion `A" in the plan of lots known as Summerdale, Pennsylvania, said plan being recorded in the Office for the Recording of Deeds in and for Cumberland County, in Plan Book 1, Page 44 (Revised Plan, Book 2, Page 109). HAVING THEREON ERECTED a one-story frame dwelling number 200 Fourth Street, Summerdale, Pennsylvania. BEING KNOWN AS: 200 4TH STREET, SUMMERDALE, PA 17093. PROPERTY ID NO.: 09-12-2994- 052. TITLE TO SAID PREMISES IS VESTED IN Connie L. Paylor by deed from Eva H. Single, widow dated 6/ 17/88 recorded 6/21/88 in Deed Book K33 Page 417. PROPERTY ADDRESS: 200 4th Street, Summerdale, PA 17093. The Patriot-News Co. 812 Mlark?t St. Harrisburg, PA 17101 Inquiries - 717-255-8213 i4tPatriot News Now you know CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Lender Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant 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 she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 01/22/10 Sworn to a s scribed before me this 24 of February, 2010 A.D. Notary Public ............ COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L. Kisner, Notary Public City Of Harrisbuirg, Dauphin County h My Commission Expires Nov. 26, 2011 -& Member. Pennsylvania Assxiatior of Notaries. 01/29/10 02/05/10 Docket Number: 2007-925 CIA Term Deutsche Bank National Trust company as Trustee under the Pooling' and'Servicing Agreement dated as of March 1, 2006 GSRPM Mortgage Loan Trust 2006-1 vs. Connie L Paylor Atty: Mark Udren ALL THOSE TWO CERTAIN ADJACENT LOTS OR PARCELS OF LAND, TOGETHER WITH THE AFROVEMENTS THEREON ERECTED, SITUATE IN EAST PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO Wrr: BEGINNING AT A POINT IN THE NORTHEAST CORNER OF THE INTERSECTION OF FOURTH STREET AND SIXTEEN (16) FEET WIDE ALLEY; THENCE NORTHWARDLY ALONG THE EASTERN LINE OF FOURTH STREET, SIXTY (60)FEET TO THE SOUTHERN LINE OF LOT NO. 93, SECTION "A' ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE EASTWARDLY ALONG THE SOUTHERN LINE OF LOT NO. 93, SECTION A ONE HUNDRED SIXTY (160) FEET TO THE WESTERN LINE OF A SIXTEEN (16) FEET WIDE 0.LLEY;THENCE SOUTHWARDLY ALONG THE WESTERN LINE OF SAID SIXTEEN 16) FEET WIDE ALLEY, SIXTY (60) FEET TO THE NORTHWEST CORNER OF THE INTERSECTION OF SAID _ SIXTEEN (16) FEET WIDE ALLEY WITH THE SIXTEEN (16) FEET WIDE ALLEY FIRST MENTIONED: THENCE WESTWARDLY ALONG THE NORTHERN LINE OF THE SIXTEEN (16) FEET WIDE ALLEY FIRST MENTIONED, ONE HUNDRED SIXTY (160) FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOTS NOS. 91 AND 92, SECTION ."A" IN THE PLAN OR LOTS KNOWN AS SUMMERDALE, PENNSYLVANIA, SAID PLAN BEING RECORDED IN THE OFFICE FOR THE RECORDING OF DEEDS IN AND FOR CUMBERLAND COUNTY, IN PLAN BOOK 1, PAGE 44 (REVISED PLAN, BOOK '_, PAGE '.109)HAVING THEREON ERECTED A ONE-STORY FRAME DWELLING NUMBER 200 FOURTH STREET, SUMMERDALE, PENNSYLVANIA. BEING KNOWN AS: 200 4TH STREET, SUMMERDALE, PA 17093, PROPERTY ID NO.: 09-12-2994-052 THE TO SAID PREMISES IS VESTED IN CONNIE L. PA"LOR BY DEED FROM EVA H. SINGLE, WIDOW DATED 6/17/88 RECORDED 6/2188 IN DEED BOOK K33 PAGE 417. PROPERTY ADDRESS: 200 4th Street, Summerdale, PA 17093 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Zie lg_er, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which GSRPM MORTGAGE LOAN TRUST 2006-1 TR is the grantee the same having been sold to said grantee on the 3RD day of MARCH A.D., 2010, under and by virtue of a writ Execution issued on the 8TH day of OCT, A.D., 2009, out of the Court of Common Pleas of said County as of Civil Term, 2007 Number 925, at the suit of GSRPM MORTGAGE LOAN TRUST 2006-1 TR against CONNIE L PAYLOR is duly recorded as Instrument Number 201007328. IN TESTIMONY WHEREOF, I have h_eerre-unto set my hand and seal of said office this c? G? day of t "A.D. o70 Zo 1-1 of Deeds W0?W=?WEK**Mn U FIN d Monde YC Of JM 2014