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Home My WebLink About03-3215 MILSTEAD & ASSOCIATES, LLC By: Corina M. Caniz, Esquire Attorney ID# 83509 325 New Albany Road Moorestown, NJ 08057 (856) 222-1508 Attorneys for Plaintiff DEUTSCHE BANK COMPANY OF CALIFORNIA, N.A. as trustee under the Pooling: Agreement relating to IMPAC Secured Assets Corporation, Mortgage Pass-Through Certificates, Series 2000-5 500 Enterprise Road, SuiteJ50 Horsham, PA 19044 Plaintiff vs. JEANETTE S. PIERCY 5 Citadel Drive Camp Hill, P A 17011 Defendant(s) COURT OF COMMON PLEAS CUMBERLAND COUNTY TRIAL DIVISION No.: 0'3 - 3~1..s (!,.oi.l'-T~ CIVIL ACTION MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (ph)717-249-3166 800-990-9108 **********AAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAlAAAAAAAAAllAAAAAAAAlAAlllllAlAAAllAAAlAAlAlAAllAl* NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT AllllAAAlAAlAAlAAlAllAAAllAllllAAAlAlAAlllAAllAlAAAllAAllAAAAAlAAAAlAAAAA~AAAAAAAlAAAAAAAAAAAAAAll 1.This communication is from a debt collector. This is an attempt to collect a debt and any information obtained will be used for that purpose. 2.Unless you dispute the validity of this debt, or any portion thereof, within 30 days after receipt of this notice, the debt will be assumed to be valid by our offices. 3.lf you notify our offices in writing within 30 days of receipt of this notice that the debt, or any portion thereof, is disputed, our offices will provide you with verification of the debt or copy of the Judgment against you, and a copy of such verification or judgment will be mailed to you by our offices. MILSTEAD & ASSOCIATES, LLC By: Corina M. Caniz, Esquire Attorney ID# 83509 325 New Albany Road Moorestown, NJ 08057 (856) 222-1508 Attorneys for Plaintiff DEUTSCHE BANK COMPANY OF CALIFORNIA, N.A. as trustee under the Pooling: Agreement relating to IMPAC Secured Assets Corporation, Mortgage Pass-Through Certificates, Series 2000-5 500 Enterprise Road, Suite 150 Horsham, PA 19044 COURT OF COMMON PLEAS CUMBERLAND COUNTY TRIAL DIVISION No.: 03 - .?~S (l,'c.>; L 'T~ Plain tiff vs. JEANETTE S. PIERCY 5 Citadel Drive Camp Hill, PA 17011 CIVIL ACTION MORTGAGE FORECLOSURE Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE I. Plaintiff, Deutsche Bank Company of California, N.A. as trustee under the Pooling and Servicing Agreement relating to IMP AC Secured Assets Corporation, Mortgage Pass-Through Certificates, Series 2000-5 is a mortgage company, having an office and place of business at 500 Enterprise Road, Suite 150, Horsham, P A 19044. 2. Defendant, Jeanette S. Piercy, is the real owner of the premises hereinafter described. 3. The residence ofthe Defendant is 5 Citadel Drive, Camp Hill, P A 17011. 4. On September 29, 2000, Defendant, Jeanette S. Piercy executed and delivered to National City Mortgage Company, d/b/a Accubanc Mortgage Company a note (the "Note") and mortgage (the "Mortgage"), a true and correct copy ofthe Mortgage is attached as Exhibit "A". The Mortgage was recorded on October 5, 2000 in the Department of Records in and for Cumberland County in Mortgage Book 1642 and Page 551. The mortgage was assigned to IMP AC Funding Corporation and recorded on March 2, 2001 in Book 668, Page 1112. Said Plaintiff is property party plaintiff by way of Assignment to be recorded. 5. The said Note and Mortgage were in the principal amount of$123,050.00 with interest at the rate of9.25%, payable as to the principal and interest in equal monthly instaIlrnents beginning in the amount of$1,303.20 commencing on or about November 1,2000. Said Mortgage is incorporated herein by reference. A Lost Note Affidavit is being recorded. 6. The Mortgage covers the following real estate (the "Mortgaged Premises"): 5 Citadel Drive, Camp Hill, P A 17011. 7. The mortgage is in default because payments of principal and interest due February 1, 2003, and monthly thereafter are due and have not been paid, whereby the whole balance of principal and all interest due thereon have become due and payable forthwith together with late charges, escrow deficit (if any) and costs of collection including title search fees and reasonable attorney's fees. 8. The foIlowing amounts are due on the Mortgage and Note: Balance of Principal $121,143.46 Accrued but Unpaid Interest from 1/1/03 through 6/26/03 @ 9.25% per annum ($30.70 per diem) $ 5,433.90 Title Search Fees $ 150.00 Late Charges $ 218.76 Reasonable Attorney's Fees $ 6,057.17 PIR Inspection $ 30.00 PofRec Fee $ 30.00 Mortgage Insurance $ 249.18 Escrow Deficiency $ 143.03 TOTAL as of 6/26/2003 $133,455.50 Plus, the following amounts accrued after 6/26/2003: Interest at the Rate of9.25% per annum ($30.70 per diem); Late Charges; 9. Plaintiff has complied fully with Act No. 91 (35 P.S.~1680.401(c) of the 1983 Session of the General Assembly ("Act 91 ") of the Commonwealth of Pennsylvania. On April 8, 2003 the Act 91 Notice was mailed to the defendant by regular and certified mail at 5 Citadel Drive, Camp Hill, P A 17011. Copies of said notices are attached hereto and made a part hereof as Exhibit "B". WHEREFORE, Plaintiff demands judgment against the Defendant for foreclosure and sale ofthe mortgaged premises in the amount due as set forth in paragraph 8, namely, $133,455.50 plus the following amounts accruing after 6/26/2003, to the date of judgment: (a) interest of$30.70 per day; (b) late charges; plus interest at the legal rate allowed on judgments after the date of judgment, additional attorney's fees (if any) hereafter incurred, and costs of suit. Corina M. Caniz, Esq. Attorney for Plaintiff M .,':"'- .--,,~,~ '-.' VERIFICATION I, Corina M. Caniz, hereby certifY that I am an Attorney for Plaintiff and am authorized to make this verification on Plaintiff s behalf. I verifY that the facts and statements set forth in the forgoing Complaint in Mortgage Foreclosure are true and correct to the best of my know ledge, information and belief. This Verification is made subj ect to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. 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GJV.Nrl::lR: ..u......eII c. 1cIt..h . T ~ OIIDDATED: 9-2,... : JI.-..cr).-""1'tJ 1M COlJIIf'n' ~. ~J_, : 'IDWJ.m: Uti PAGI: iM mn 782PG~ 16 RecordetorD~ . , "",--",,-" .., . . First Mortgaga Loan Sarvicing 3451 Hammond Ave P,O, Box 780 Waterloo, IA 50704-0780 GMA.f Mortgage Date: April 8. 2003 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mort2a2e on vour home is in default. and the lender intends to foreelose, Specific iuformation about the nature of the default is provided in the attached pa2es. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) mav be able to help to save v'our home. This Notice explains how the proeram works. To see ifHEMAP can help. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with vou when vou meet with the Counseline Aeenev. The name. address and phone uumber of Consumer Credit Counse6n2 A2encies servin2 vour Countv are listed at the end of this Notice. If vou have anv questions. v-ou mav call the Pennsvlvania Housine Finance A2enev toll free at 1-800-342.2397, (Persons with impaired hearine can call (717) 780-1869). This Notice contains important legal information, If )'ou have any questions. representatives at the Consumer Credit Counseling AgenC). 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 )'ou find a lawyer. LA NOTIFlCACION EN ADJUNTO ES DE SUMA IMPORT ANCIA. PUESAFECT A SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYL VANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PREST MIO POR EL PROGRAMA LLMIADO "HOMEOWNER'S EMERGI':NCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDI~UR SU HIPOTECA HOMEOWNER'S NAM:E(S): PROPERTY ADDRESS: JEANETTE S. PIERCY 5 CITADEL DR CAMP HILL. PA 17011 LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDERlSERVICER: 307075186 MIA GMAC Mortgage Corporation ..,....-.. ..., . . HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY "'UH 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 REQillREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay offoreclosure on your mortgage for thirty (30) days from the date of this Notice. Dtrring that time you must arrange and attend a "face-to-face" meeting with one ofthe conStuner credit counseling agencies listed at the end of this Notice, THIS MEETING MUST OCCUR "'lTHIN THE NEXT (30) DAYS. IF YOU 00 NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. TIlE PART OF TIllS 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 cOlmseling 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 numbeIS of designated consumer credit cOlmseling agencies for the cOlmtv in which the property is located are set forth at the end ofthis Notice, It is only necessary to schedule one face-to.face meeting. Advise your lender immediatelv of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -. Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowners Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowners Emergency Assistance Program Application with one of the designated conStuner credit cOlmseling agencies listed at the end of this Notice. Only consumer credit cOlmseling 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 you face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED, AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbuISed 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, Dtrring that time, no foreclosure proceedings will be pUISued 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 FOLLO\\1NG PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATIEMPT TO COLLECT THE DEBT. (If you have med bankrupt")' you can still apply for Emergenc}' Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Brine it up to date). NATURE OF THE DEFAULT .' The MORTGAGE debt hela:l1y the above lender is on your property located at: 5 CITADEL DR CAMP HILL, PA 17011 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTIlL Y MORTGAGE P A YMENT.5 for the following months and the following amounts are now past due: February I, 2003, througn April 1, 2003. See attached Exhibit for payment breakdown. Monthly Payments Late Charges NSF Inspections Other Suspense 3,909.60 117.52 0.00 15.00 0.00 0.00 TOTAL AMOUNT PAST DUE: 4,042.12 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): HOW TO CURE THE DEFAULT -- You may cure the default within THIRIT (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 4, 042 . 12 , PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRIT (30) DAY PERIOD. Payments nmst be made either by cash. cashiers check, certified check or money order made payable and sent to: Payment Processing GMAC Mortgage Corporation PO Box 780 Waterloo IA 50704-0780 You can cure any other default by taking the following action within THIRIT (30) DAYS of the date of this letter: (Do not use ifnot applicable.) N t A l' b1 o pp lca e IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRIT (30) DAYS of the date ofthis Notice, the lender intends to exercise its riehts to accelerate the morteaee debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. Iffull payment of the total amount past due is not made within THIRIT (30) DAYS, the lender also intends to instmet its attorneys to start legal action to foreclose upon your morteaeed orooem'. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriffto payoff the mortgage debt. Ifthe lender refers YO\IT case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against against YOlI, 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 amOlmt you owe the lender, which may also include other reasonable costs. Ifvou cure the default within the TIDRTY (30) DAYS period, you will not be required to pay attorney's fees. "........ -c. ~ . . OTHER LENDER REMEDIES -- The lender may also sue you peISonally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE u If you have not cured the defa,dt within the THIR1Y (30) DAY period and foreclosure proceedings have beglm, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total arnmmt 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 l'erforming any other requirements under the mortgage, Curing,\our default in the manner set forth in this notice will restore your mortgage to the same position as ifyoa,had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE u It is estimated that the earliest date that such a Sheriffs Sale ofthe mortgaged property cmdd be held would be approximately six (6) nionths 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 COUISe, the arnmmt needed to cure the default will increase the longer you wait. You may fmd 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: Address: GMAC Mortgage Corporation 3451 Hammond Avenue Waterloo IA 50702 Phone Number: Fax Number: Contact Person: (800) 850-4622 (319) 236-7437 Collection Department EFFECT OF SHERIFF'S SALE.. You should realize that a Sheriff's Sale will end your owneIShip of the mortgaged property and your right to occupy it. If you contimle to live in the property after the Sheriff's Sale, a lawsuit to remove you and your fllmishings and other belongings could be started by the lender at any time, ASSUMPTION OF MORTGAGE -. You mayor may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements ofthe mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPER1Y 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 DEF AUL T CURED BY ANY THIRD P AR1Y ACTING ON YOUR BEHALF, TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEF AUL THAD OCCURRED, IF YOU CURE THE DEF AUL T. (HOVl'EVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE TIlAN TIlREE TIMES IN ANY CALENDAR YEAR,) TO ASSERT THE NONEXISTENCE OF A DEF AUL T IN ANY FORECLOSURE PROCEEDING OR ANY OTIlER LAWSUIT INSTITUTED UNDER TIlE MORTGAGE DOCUMENTS, TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY TIlE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ENCLOSED -..- .... - . . Applicable law requires us to inform you we are attempting to collect a debt and any information you provide will be used for that purpose. If you disagree with our assertion that a default has occurred with your mortgage loan, please contact our offic~immediately at 1-600-850-4622 and speak with one of our'~oan counseling representatives. Thank you for your prompt response concerning this matter. Collection Department Mortgage Loan Servicing . . EXHIBIT February 1, 2003 March 1, 2003 April 1, 2003 @ @ @ 1,303.20 1,303.20 1,303.20 ~, ,', t::J tt ~ il ."'t - ~ (5 \l.J -.Q ~ ....) ()t " ~ ~ C) C <". u(-':' n, ~: ;?;'L ~t ~' ~."- );,;. ,:;) ,",; ",,~Q -. - '.) ,-., .-' -;:;;:' :.J1 -i OJ ::<. SHERIFF'S RETURN - REGULAR CASE NO: 2003-03215 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK CO OF CALIFORNIA VS PIERCY JEANETTE S SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon PIERCY JEANETTE S the DEFENDANT , at 1725:00 HOURS, on the 16th day of July , 2003 at 5 CITADEL DRIVE CAMP HILL, PA 17011 by handing to JEANETTE PIERCY a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 10.35 .00 10.00 .00 38.35 r~~ R. Thomas Kline 07/17/2003 MICHAEL MILSTE '" Sworn and Subscribed to before By: ~ me this '" - day of _~' <..-J-'.,Urv.J A . D . ( <vI-'- t2 )y,~Lv~') ~ {Prothonotary OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Prothonotary TO: Jeanette S. Piercy DEUTSCHE BANK COMPANY OF CALIFORNIA, N.A. as trustee under the Pooling Agreement relating to IMP AC Secured Assets Corporation, Mortgage Pass-Through Certificates, Series 2000-5 Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. No.: 03-3215 Civil Term : JEANETTE S. PIERCY Defendant(s) NOTICE PURSUANT TO RULE 236 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary MORTGAGE FORECLOSURE JUDGMENT BY DEFAULT IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: CORINA M. CANIZ, ESQUIRE #83509 MILSTEAD & ASSOCIATES, LLC 856/482-1400 ,. Notice Pursuant To Fair Debt Co1Iedloa Praetiees Ad This is an attempt to collect a dIM.... arq IDformatioa obtained will be 8IICl for that....l'a.. MILSTEAD & ASSOCIATES, LLC BY: CORINA M. CANIZ, ESQUIRE Attorney ID# 83509 Woodland Falls Corporate Park 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorneys for Plaintiff DEUTSCHE BANK COMPANY OF CALIFORNIA, N.A. as trustee under the Pooling Agreement relating to IMP AC Secured Assets Corporation, Mortgage Pass-Through Certificates, Series 2000-5 Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. No.: 03-3215 Civil Term JEANETTE S. PIERCY Defendant(s) PRAECIPE TO ENTER DEFAULT JUDGMENT TO THE PROTHONOTARY Kindly enter Default Judgment in favor of Plaintiff, Deutsche Bank Company of California, N.A. as trustee under the Pooling Agreement relating to IMPAC Secured Assets Corporation, Mortgage Pass-Through Certificates, Series 2000-5 and against the defendant(s), Jeanette S. Piercy, for failure to Answer the Complaint in Civil Action - Mortgage Foreclosure. Service was made on the Defendant(s), Jeanette S. Piercy via Cumberland County Sheriff on July 16,2003. Assess damages as follows: Total debt as of 6/26/03 Interest from 6/26/03 to 9/8/03 $ 133,455.50 2,271.80 TOTAL AMOUNT OF JUDGMENT$ 135,727.30 :.~:;;:~ Carina M. Caniz, Esquire #83509 MILSTEAD & ASSOCIATES, LLC BY: CORINA M. CANlZ, ESQUIRE Attorney ID# 83509 Woodland Falls Corporate Park 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorneys for Plaintiff DEUTSCHE BANK COMPANY OF CALIFORNIA, N.A. as trustee under the Pooling Agreement relating to IMP AC Secured Assets Corporation, Mortgage Pass-Through Certificates, Series 2000-5 Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. No.: 03-3215 Civil Term JEANETTE S. PIERCY Defendant(s) AFFIDAVIT OF ADDRESSES STATE OF NEW JERSEY SS COUNTY OF CAMDEN I, Corina M. Caniz, Esquire, being duly sworn according to law, upon my oath, depose and say: I. I certifY that the Plaintiffs address is 500 Enterprise Road, Horsham, PA 19044. 2. I certifY that the Defendant(s), Jeanette S. Piercy's address is 5 Citadel Drive, Camp Hill, PA 17011. 3. I certifY that the foregoing information is true and correct to the best of my knowledge, information and belief. Sworn and Subscribedko before me this II day /'6'f'$€P~ IJdJ~ \J '=if-hUll ! to - < Corina M. Caniz, Esquire # 83509 DAWN HOFFMAN NOTARV PUBlIC OF NEW JERSEY Commlaslon Expbe5 1/9/'J.OO7 MILSTEAD & ASSOCIATES, LLC BY: CORINA M. CANIZ, ESQUIRE Attorney ID# 83509 Woodland Falls Corporate Park 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorneys for Plaintiff DEUTSCHE BANK COMPANY OF CALIFORNIA, N.A. as trustee under the Pooling Agreement relating to IMP AC Secured Assets Corporation, Mortgage Pass-Through Certificates, Series 2000-5 Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. No.: 03-3215 Civil Term JEANETTE S. PIERCY Defendant(s) AFFIDAVIT OF NON- MILITARY SERVICE STATE OF NEW JERSEY SS COUNTY OF CAMDEN I, Corina M.Caniz, Esquire, Attorney at Law, being duly sworn according to law, upon my oath, depose and say: I. That the Defendants are not in the Military, Naval of Air Services of the United States of any other Country within the provision of the Soldiers' and Sailors' Civil Relief Action of Congress, as amended; and 2. That the Defendant is at least 21 years of age and reside at 5 Citadel Drive, Camp Hill, P A 170 II. The affiant has ascertained the foregoing information by personal inquiry and knowledge and makes this Affidavit with the authority. Sworn and Subscribed to before me ~is 1/ day r:?fu~ /W1~ '0 DAWN HOFFMAN " ~.., 'e Of Hl'4/ JalSf 1 N01AA'l......... <........ \/9/2007 COlI\mIsl;Ion .......- Mils ead & Associates, LLC "riM M !.:.?11[j~8 MILSTEAD & ASSOCIATES, LLC BY: CORINA M. CANIZ, ESQUIRE Attorney 10# 83509 Woodland Falls Corporate Park 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorneys for Plaintiff DEUTSCHE BANK COMPANY OF CALIFORNIA, N.A. as trustee under the Pooling Agreement relating to IMPAC Secured Assets Corporation, Mortgage Pass-Through Certificates, Series 2000-5 Plaintiff vs. JEANETTE S. PIERCY Defendant(s) STATE OF NEW JERSEY COUNTY OF CAMDEN COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 03-3215 Civil Term AFFIDAVIT OF SERVICE SS I, Corina M. Caniz, Esquire, Attorney at Law, being duly sworn according to law, upon my oath, depose and say: 1. I am a member of the firm of Michael J. Milstead, Esquire, attorneys for Plaintiff in the above entitled cause of action. 2. Notice, Rille 237.1 was forwarded to the Defendant(s), place of residence by regular mail on August 7, 2003 and has not been returned to this office, so it can be assumed that same has been delivered to Defendants. Sworn and Subscribed to before me this II day @~/~ DAWN HOFFMAN NOTARY PU8UC Of NEW JERSEY GllIllIfII*n ExpIres 1/9/2007 o;:~a Corina M. Caniz, Esquire # 835 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Prothonotary TO: Jeanette S. Piercy August 7,2003 DEUTSCHE BANK COMPANY OF CALIFORNIA, N.A. COURT OF COMMON PLEAS as trustee under the Pooling Agreement relating to IMP AC CUMBERLAND COUNTY Secured Assets Corporation, Mortgage Pass-Through Certificates, Series, 2000-5 Plaintiff vs. No.: 03-3215 Civil Term JEANETTE S. PIERCY Defendant NOTICE, RULE 237.1 IMPORTANT NOTICE You are in default because you have failed to take action required of you in this case. Unless you act within ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 or 800-990-9108 " .. - _11 Michael J. Milste.d. Esq mich.eMtmilsteadllw.com MILSTEAD & ASSOCIATES, LLC Attorneys at Law Woodland Falls Corporate Park 220 Lake Drive East, Ste 301 Cherry Hill, New Jersey 08002 TEL (856) 482-4100 FAX (856) 482-9190 Phib.de1phi. Addreu: 23S Sou1h 13'" Street PbIladelphiA, PA 19107 Corimo M. Cudz. Eaq. PA ok NJ ccanizOm.illlteadlaw.com Un Ann Thomu. Forec1osUJ'l! Administrator lthomuOmilsteadJaw.com Please Reply To: NJ Office Our File No, '1.()l'53""t Pursuant to the Soldiers' and Sailors' Civil Relief Act of 1940, specifically, 60 U.S.C.A. Section 601 et sec., please provide us with the current Military Status of the following persons: NAME SSNIDOB NO~ ~ MIL ~:5,\)ie,,-y '22lo3:0':S'i?''!3 ,x.. IN MIL SERVICE VirginiaBroo~~"~ Date: Or 1 8 AUO 2003 Deborah Watson Date: SHERIFF'S RETURN - REGULA? ' 'I' 0153~ CASE NO: 2003-03215 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK CO OF CALIFORNIA VS PIERCY JEANETTE S SHAWN HARRISON Sherift or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon PIERCY JEANETTE S the DEFENDANT , at 1725:00 HOURS, on the 16th day of July , 2003 at 5 CITADEL DRIVE CAMP HILL, PA 17011 by handing to JEANETTE PIERCY a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 10.35 .00 10.00 .00 38.35 r~~~ . , R. Thomas Kline ' 07/17/2003 MICHAEL MILST '- Sworn and Subscribed to before By: me this day of 'ff A.D. Prothonotary ?: A:.l (.J ~ ~ ~ i :-0 ~ B f ~ ~ ~ llJ u.::; I ~ & ~J ~~ ,...... n " Milstead & Associates. LLC BY: Corina M. Caniz, Esquire Attorney 10 No. 83509 325 New Albany Road Moorestown, NJ 08057 Attorney for Plaintiff 03-7-01539 DEUTSCHE BANK COMPANY OF CALIFORNIA, N.A., as trustee under the pooling and Servicing Agreement relating to IMPAC Secured Assets Corporation, Mortgage Pass-Through Certificates, Series 2000-5 : COURT OF COMMON PLEAS : UM\ERLAND CUJNlY Plaintiff : CIVIL ACTION vs. : NO. 03-3215 Civil Team JEANETTE S. PIERCY Defendant : Affidavit Regarding : Lost Note Affiant. being duly sworn, deposes and says: 1, I am over the age of 18 years and believe in the obligations of an oath, 2. Among my duties is supervision of the records for the Deutsche Bank Company of California, NA, et al. In that capacity, I am familiar with record keeping procedures for the Deutsche Bank Company of California, N,A" et al. 3, In connection with this case, a diligent search was conducted in an attempt to locate the original executed Note; however, it is not in the records area and is presumed to be lost. 4, The Bank is the owner, holder and possessor of the Note and Mortgage that is the subject of the action. .' The foregoing statements are known by me to be true of my own knowledge, Vh1V. Sworn to and Subscribed before me this I "1'1'- day of cf' ~ ,2003 -:;In. d-~ NOTARIAL SEAL REGINA M, FREOEIltCK, Notary Public Harsham Twp" Montgomery CounIy M Commission Ex' Oct 22, 2004 '. n t: -v~:~,. r~l ~:::: ./ (II ~t; :::1 -< '~ -'J ,<.,'\ ,...' "-<::.' r;;" ':J (P . : -;) MILSTEAD & ASSOCIATES, LLC By: Corina M. Caniz, Esquire Attorney ID#83509 220 Lake Drive East - Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorneys for Plaintiff Deutsche Bank Company of California, N .A. as trustee Under the Pooling and Servicing Agreement relating to IMP AC Secured Assets Corporation, Mortgage Pass- Through Certificates Series 2000-5 Plaintiff : COURT OF COMMON PLEAS : CUMBERLAND COUNTY vs. : NO.: 03-3215 Civil Term Jeanette S. Piercy Defendant PRAECIPE FOR WRIT OF EXECUTION IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: 1. Directed to the Sheriff of Cwnberland County; 2. Against the Defendants in the above captioned matter; 3. And index this writ against the Defendants as follows: Jeanette S. Piercy 4. Real Property involved: 5 Citadel Drive Camp Hill, P A 17011 Amount Due Interest from 09/20/03 to 03/03/04 TOTAL (Costs to be added) $ 135,727.30 $ 3,658.84 $ 139,386.14 Dated: I) II'( 03 Respectfully submitted, Milst~illt~LC "- Corina M. Caniz, Esquire ~( c ~ ~ ~~ 0 .t, .()~~~ A:J . il 'i . ';' ~ "r O"1i..>o vt R C)or (I ~ 0 CtlD () ~) ~ 1 I ' , rttJ ,.. ~ f:P . DP:: - ::~ '" ~ :: ~ ~ ::. ---t) . -J . .. .. - .. ~- ~ '.0) -, ,-,OJ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 03-3215 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK COMPANY OF CALIFORNIA, N.A. AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT RELATING TO IMPAC SECURED ASSETS CORPORATION, MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2000-5, Plaintiff (s) From JEANETTE S. PIERCY (I) 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) Ifproperty 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 himlher that he/she has been added as a garnishee and is enjoined as above stated, Amount Due $135,727.30 Interest FROM 9120/03 TO 3/3/04 - $3,658.84 Atty's Comm % Atty Paid $120.35 Plaintiff Paid Date: NOVEMBER 18, 2003 L.L. $.50 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) Prothono~ ~ CBy: Ja"....... P "l~ Deputy REQUESTING PARTY: Name CORINA M. CANIZ, ESQUIRE Address: MILSTEAD & ASSOCIATES, LLC 220 LAKE DRIVE EAST - SUITE 301 CHERRY fiLL, NJ 08002 Attorney for: PLAINTIFF Telephone: 856-482-1400 Supreme Court ID No, 83509 ALL that certain piece or parcel of land together with the improvements thereon erected, situate in Lower Allen Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the Southern side of a 50 foot wide road known as Citadel Drive, which point, measures along the Southern side of Citadel Drive, is 363.95 feet West of the Southwest comer of Citadel Drive and Colgate Drive, and which point also is at the Northwest comer of Lot No. 125 on Part of Plan No.2, Cedar Cliff Manor, recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 7, Page 13; thence at right angles to Citadel Drive Southwesterly along the Western line of Lot No. 125 aforesaid, 125 feet to a point at the Northern line of Lot No. 131 on Plan No.1, Cedar Cliff Manor, recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 6, Page 33; thence Westwardly along the Northern line of Lot Nos. 131 and 130 on Plan No.1, Cedar Cliff Manor aforesaid, 70 feet to a point at the Eastern line of Lot No. 127 on Part of Plan No.2, Cedar Cliff Manor aforesaid; thence at right angles to Citadel Drive Northwardly along the Eastern line of Lot No. 127 aforesaid, 125 feet to a point at the Southern side of Citadel Drive; thence Eastwardly along the southern side of Citadel Drive, 70 feet to a point, being the place of beginning. BEING Lot No. 126 on the Plan of Lots known as "Part of Plan No.2, Cedar Cliff Manor", which plan was approved by the Commissioners of Lower Allen Township on January 12, 1955 and is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 7, Page 13. BEING known and numbered as 5 Citadel Drive, Camp Hill, Pennsylvania. Being Parcel No. 13-23-0547-588 IMPROVEMENTS THEREON: RESIDENTIAL DWELLING Tax ParcellD: 13-23-0547-588 Address: 5 Citadel Drive CampHill,PA 17011 MILSTEAD & ASSOCIATES, LLC By: Corina M. Caniz, Esquire Attorney ID#83509 220 Lake Drive East - Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorneys for Plaintiff Deutsche Bank Company of California, N.A. as trustee Under the Pooling Agreement relating to IMP AC Secured Assets Corporation, Mortgage Pass-Through Certificates Series 2000-5 Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. NO.: 03-3215 Civil Term Jeanette S. Piercy Defendants AFFIDA VlT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Deutsche Bank Company of California, et aI., Plaintiff in the above entitled cause of action, sets forth as ofthe date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 5 Citadel Drive, Camp Hill, P A 17011: 1. Name and address of Owner(s) or Reputed Owner(s): Jeanette S. Piercy 5 Citadel Drive Camp Hill, P A 17011 2. Name and address ofDefendant(s) in the Judgment: Jeanette S. Piercy 5 Citadel Drive Camp Hill, P A 170113 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Deutsche Bank Company of California, N .A. as trustee under the Pooling Agreement relating to IMP AC Secured Assets Corporation, Mortgage Pass-Through Certificates, Series 2000-5 (Plaintiff herein) 500 Enterprise Road Horsham, P A 19044 Child Support Enforcement Agency Domestic Relations 13 N. Hanover St Carlisle, P A 17013 4. Name and address ofthe last recorded holder of every mortgage of record: Deutsche Bank Company of California, N .A. as trustee under the Pooling Agreement relating to IMP AC Secured Assets Corporation, Mortgage Pass-Through Certificates, Series 2000-5 (Plaintiff herein) 500 Enterprise Road Horsham, P A 19044 Pennsylvania Housing Finance Agency Homeowner's Emergency Mortgage Assistance 2101 North Front Street Harrisburg, P A 17105 Patriot Bank 155 East High Street Pottstown, P A 19464 5. Name and address of every other person who has any record lien on the property: None known. 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: Occupant,S Citadel Drive Camp Hill, PA 17011 7. Name and address of every person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Occupant, 5 Citadel Drive Camp Hill, P A 170 II 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 unders d that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 reI ti g t-o unsw~c to authorities. {I II L CaRINA M. CANIZ, ESQUIRE #83509 Sworn and Subscribed to before ~ me this;' day of NN 2003~~ li/bf%n OAWN HOffMAN MOTAllV P\JWC Of HEW JfllSFf c()IlI/llI$sIOfI Ex\)lre6 "9/'2007 .. ~!-: {]~, ; (") ';;; ,- j~;_:~ !~~ ., -'! MILSTEAD & ASSOCIATES, LLC By: Corina M. Caniz, Esquire Attorney ID#83509 220 Lake Drive East - Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorneys for Plaintiff Deutsche Bank Company of California, N.A. as trustee Under the Pooling Agreement relating to IMP AC Secured Assets Corporation, Mortgage Pass-Through Certificates Series 2000-5 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. NO.:03-3215 Civil Term Jeanette S. Piercy Defendant :REAL PROPERTY :PURSUANT :NOTICE OF SHERIFF'S SALE OF :TO PENNSYL V ANlA RULE OF :CIVIL PROCEDURE 3129 TAKE NOTICE: Your house (real estate) at 5 Citadel Drive, Camp Hill, P A 17011 is scheduled to be sold at Sheriffs Sale on March 3, 2004 at 10:00 am in the Commissioner's Hearing Room, Cumberland County Courthouse, Carlisle, P A 17013 to enforce the Court Judgment of $135,727.30 obtained by Deutsche Bank Company of California, et al. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The Sale will be cancelled if you pay to Corina M. Caniz, Attorney for Plaintiff, back payments, late charges, costs and reasonable attorneys fees due. To find out how much you must pay, you may call Corina M. Caniz at 856-482-1400. 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 following page and how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling Corina M. Caniz at 856-482-1400. 2. You may be able to petition the Court to set aside the Sale if the bid price was grossly inadequate compared to the market value of your property. 3. The Sale will go through only if the Buyer pays the Sheriff the full amount due on the Sale. To find out if this has happened you may call Corina M. Caniz at 856-482-1400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the Sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a Deed to the Buyer. At that time, the Buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A Schedule of distribution of the money bid for your house will be filed by the Sheriff approximately 30 days after the date of Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the Sale. YOU SHOULD TAKE TIDS PAPER TO YOU 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 Carlisile, PA 17013 (800) 990-9108 03-7-01539 ALL that certain piece or parcel of land together with the improvements thereon erected, situate in Lower Allen Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the Southern side of a 50 foot wide road known as Citadel Drive, which point, measures along the Southern side of Citadel Drive, is 363.95 feet West of the Southwest corner of Citadel Drive and Colgate Drive, and which point also is at the Northwest corner of Lot No. 125 on Part of Plan No.2, Cedar Cliff Manor, recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 7, Page 13; thence at right angles to Citadel Drive Southwesterly along the Western line of Lot No. 125 aforesaid, 125 feet to a point at the Northern line of Lot No. 131 on Plan No. I, Cedar Cliff Manor, recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 6, Page 33; thence Westwardly along the Northern line of Lot Nos. 131 and 130 on Plan No.1, Cedar Cliff Manor aforesaid, 70 feet to a point at the Eastern line of Lot No. 127 on Part of Plan No.2, Cedar Cliff Manor aforesaid; thence at right angles to Citadel Drive Northwardly along the Eastern line of Lot No. 127 aforesaid, 125 feet to a point at the Southern side of Citadel Drive; thence Eastwardly along the southern side of Citadel Drive, 70 feet to a point, being the place of beginning. BEING Lot No. 126 on the Plan of Lots known as "Part of Plan No.2, Cedar Cliff Manor", which plan was approved by the Commissioners of Lower Allen Township on January 12, 1955 and is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 7, Page 13. BEING known and numbered as 5 Citadel Drive, Camp Hill, Pennsylvania. Being Parcel No. 13-23-0547-588 IMPROVEMENTS THEREON: RESIDENTIAL DWELLING Tax Parcel ID: 13-23-0547-588 Address: 5 Citadel Drive CampHill,PA 17011 ~~ .....C.I. r~: ,. " C'). U.' -c r" p" ~;:.. -s::~ ',!-I ..':' J~n Deutsche Bank Company of California N.A. as Trustee Under the Pooling Agree- Ment Relating to IMPAC Secured Assets Corporation, Mortgage Pass-through Certificates Series 2000-5 VS Jeanette S. Piercy In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-3215 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Corina Caniz. Sheriffs Costs: Docketing Poundage Advertising Posting Handbills Levy Surcharge Service Law Journal Patriot News Law Library Prothonotary Share of Bills 30.00 16.45 15.00 15,00 15.00 20,00 19.32 367.70 309,43 .50 1.00 29.32 $ 838.72 paid by attorney 02/24/04 Sworn and subscribed to before me This dt. ;;. day of -:J-...t-f,"<MJ 2004, A.~7-'- 0 ~ / ~ Prothonotary S.~.v (- ~~,,~ R. Thomas Kline, Sheriff · \ ~'t> 0z. 'IlfO:<"..2..J fl..-. It-dO 1'1 MILSTEAD & ASSOCIATES, LLC By: Corina M. Caniz, Esquire Attorney ID#83509 220 Lake Drive East - Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorneys for Plaintiff Deutsche Bank Company of California, N.A. as trustee Under the Pooling Agreement relating to IMP AC Secured Assets Corporation, Mortgage Pass-1brough Certificates Series 2000-5 Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. NO.: 03-3215 Civil Term Jeanette S. Piercy Defendants AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Deutsche Bank Company of California, et al., Plaintiff in the above entitled cause of action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 5 Citadel Drive, Camp Hill, P A 170 II: 1. Name and address ofOwner(s) or Reputed Owner(s): Jeanette S. Piercy 5 Citadel Drive Camp Hill, PA 17011 2. Name and address of Defendant(s) in the Judgment: Jeanette S. Piercy 5 Citadel Drive Camp Hill, P A 170113 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Deutsche Bank Company of California, N .A. as trustee under the Pooling Agreement relating to IMP AC Secured Assets Corporation, Mortgage Pass-Through Certificates, Series 2000-5 (Plaintiff herein) 500 Enterprise Road Horsham, P A 19044 Child Support Enforcement Agency Domestic Relations 13 N. Hanover St Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: Deutsche Bank Company of California, N.A. as trustee under the Pooling Agreement relating to IMP AC Secured Assets Corporation, Mortgage Pass-Through Certificates, Series 2000-5 (Plaintiff herein) 500 Enterprise Road Horsham, P A 19044 Pennsylvania Housing Finance Agency Homeowner's Emergency Mortgage Assistance 2101 North Front Street Harrisburg, PA 17105 Patriot Bank 155 East High Street Pottstown, P A 19464 5. Name and address of every other person who has any record lien on the property: None known. 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: Occupant,S Citadel Drive Camp Hill, PA 17011 7. Name and address of every person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Occupant,5CiWrlelDrive Camp Hill, PA 17011 1 verifY that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I unders d that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 reI ti g to unsw~cn to authorities. { {I ilL W. CORINA M. CANIZ, ESQU~ #83509 'V Sworn and Subscribed to before ~ me this I day of NN 2003~ h ~ DAWN HOFFMAN NOl~RY P08lIC Of liW JalStY C~ Exp!m 1/9/'1007 . THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderAct No, 587, Approved May16,1929 Commonwealth of Pennsylvania, County of Dauphin} ss Michael Morrow, being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co" a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal ollice 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~ 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 20th and 27th day(s} of January and the 3rd day(s) of February 2004. 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 behaif 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 ollice for the Recording of Deeds in and for said County of Dau hin in iscellaneous Book "M", Volume 14, Page 317, PUBLICATION COpy 5 ALE #43 Sworn to and subscribed b fore t s 23rd day f%ebr 2004 AD, Notanal Seal ~ / TenyLRussell,NotaryP -//L?~/-"'/ City Of HarrisbUrg, Dauphin Cou L/'~ ~ MyCommissionExpiresJune6,2006 NARY PUBLIC MeIroer, PennsylvanIa - Of NoIf\\Ircommission expires June 6, 2006 CUMBERlAND COUNTY SHERIFFS OFFICE CUMBERlAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO" Dr, For publishing the notice or publication attached hereto on the above stated dates Total $ 309,43 Publisher's Receipt for Advertising Cost The Patriot News Co" publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid, By,.",'.,.""...""".,."".,.""'.,."'.,...."'.,"".,.,."", , M..h ,'_~1II1Dc! IO.-....~..........' 11111*11 " .~ ,~i'''' _ '-~I'lIoaiI>odu 1_: ......11,............- "..~Jf',N I'I."~......-' ......,...,..1>.11 ..;:J_........oI t'IIldrI_lI '..-". ...... .......-..~ _.",,-,~......,.. .', ..... '. .' . .,., Cl,,\l1-"~~ ~.tI_ " ~'1 ~.v~~:~ ~ 'm~.~~~'l. ;!om.. ~ ... ,10 C\IIM lJIt,-, f PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, ofthe 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, VlZ: JJ\~J\RY 16,23,30,2004 J\ffiant 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. REAL ESTATE SALE NO. 43 Writ No, 2003-3215 Civil Deutsche Bank Company of California. N.A. as trustee under the pooling agreement relating: to IMPAC Secured Assets Corporation. Mortgage pass- tlrrough certificates series 2000-5 VS, Jeanette S. Piercy Atty, , Corina Caniz ALL that certain piece or parcel of land together with the improve- ments thereon erected. situate in Lower Allen Township. Cumberland County. Pennsylvania. bounded and described as follows: BEGINNING at a point on the Southern side of a 50 foot wide road known as Citadel Drive. which point, measures along the Southern side of Citadel Drive, is 363.95 feet West of the Southwest corner of Citadel Drive and Colgate Drive, and which point also is ~~~_ N~~~_,.~~: ~~0 Oisa Marie co~~, Editor SWORN TO J\ND SUBSCRIBED before me this 30 day of JJ\NUJ\RY 2004 ~~ L. .Jh1J .0AJ NOTrR~t~;;' T ~ LOIS E. SNYDER, Notary Public Carlisle BOlO, Cumberland COUnty My Commission Expires M8ICh 5, 2005 ~ described ms l\-'u........~~ BEGINNING at a point on the Southern side of a 50 foot wide road knOV1!1 as Citadel Drive, which potnt, measures along the Southern side of Citadel Drive. is 363,95 feet West of the Southwest corner of Citadel Drive and Colgate Drive, and which point also is at the Northwest cor- ner of Lot No. L25 on Part of Plan No.2. Cedar Cliff Manor, recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 7. Page 13; thence at right angles to Citadel Drive Southwesterly along the West- ern line of Lot No. 125 aforesaid. 125 feet to a point at the Northern line of Lot No. 131 on Plan No. 1, Cedar Cliff Manor, recorded in the Office of the Recorder of Deeds in and for Cumberland County. Penn- sylvania, in Plan Book 6. Page 33; thence Westwardly along the North- ern line of Lot Nos. 131 and 130 on Plan No.1, Cedar Cliff Manor afore- said, 70 feet to a point at the East- ern line of Lot No. 127 on Part of Plan No.2, Cedar C1UT Manor afore- said; thence at right angles to CIta~ del Drive Northwardly along the Eastern line of Lot No. 127 afore- said. 125 feet to a point at the Southern side of Citadel DrIve; thence Eastwardly along the south~ ern side of Citadel Drive. 70 feet to a point, being the place of begin- ning. BEING Lot No, 126 on the Plan of Lots known as "Part of Plan No. 2, Cedar Cliff Manor~. which plan 'WaS approved by the Commission~ era of Lower Allen Township on January 12, 1955 and is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania. in Plan Book 7, Page 13, BEING known and numbered as 5 Citadel Drive, Camp HilL Penn- sylvania. Being Parcel No, 13-23-0547-588, IMPROVEMENTS THEREON: RESIDENTIAL DWELLiNG, Tax Parcel ID: 13-23-0547-588, Address: 5 Citadel Drive. Camp Hill. PA 17011. ,. / In the Court of Common Pleas of Cumberland County, P A Deutsche Bank Company of California, N.A., as Trustee Under the Pooling and Servicing Agreement relating to IMP AC Secured Assets Corporation, Mortgage Pass- through Certificates Series 2000-5 Plaintiff Vs. Jeanette S. Piercy Defendant(s) CIVIL ACTION NO,: 03-3215 Civil Term Praecipe For Writ of Execution (Mortgage Foreclosure) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: 1. Directed to the Sheriff of Cumberland County; 2. Against the Defendant( s) in the above captioned matter; 3, and index this writ against the Defendant( s) as follows: Jeanette S. Piercy 4. Real property involved: 5 Citadel Drive Camp HilI, PA 17011 AMOUNT DUE $135,727.30 INTEREST From 9/20/03 to Date of $ Sale at $22.31 per diem TOTAL $ (Costs to be added) December 6, 2005 ..,....:: (000754211 r0 ~ ? ~t ~ - 9J ~ ~ ~ ~ (J- e. + tf ~ ~'\ -:;, " ,) ,,---, ~4:,"^../ (""'.... . -:::, <.j>' " --.c\ ~.\ _. '. >,\', C',) :;::. ---0 l.!\ v,\ ~) . '~, ,.. I,j,\ ~ 0 '/. ') .....) <D 'l-' /-ci C,J... ~y <- --< -lq. ~..... ~ v' <> B ~ J " , ~ - \' -------------- ," / ALL that certain piece or parcel ofland together with the improvements thereon erected, situate in Lower Allen Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the Southern side of a 50 foot wide road known as Citadel Drive, which point, measures along the Southern side of Citadel Drive, is 363.95 feet West of the Southwest comer of Citadel Drive and Colgate Drive, and which point also is at the Northwest comer of Lot No. 125 on Part of Plan No.2, Cedar Cliff Manor, recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 7, Page 13; thence at right angles to Citadel Drive Southwesterly along the Western line of Lot No. 125 aforesaid, 125 feetto a point at the Northern line of Lot No. 131 on Plan No, 1, Cedar Cliff Manor, recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 6, Page 33; thence Westwardly along the Northern line of Lot Nos. 131 and 130 on Plan No.1, Cedar Cliff Manor aforesaid, 70 feet to a point at the Eastern line of Lot No. 127 on Part of Plan No.2, Cedar Cliff Manor aforesaid; thence at right angles to Citadel Drive Northwardly along the Eastern line of Lot No. 127 aforesaid, 125 feet to a point at the Southern side of Citadel Drive; thence Eastwardly along the southern side of Citadel Drive, 70 feet to a point, being the place of beginning. BEING Lot No. 126 on the Plan of Lots known as "Part of Plan No.2, Cedar Cliff Manor", which plan was approved by the Commissioners of Lower Allen Township on January 12, 1955 and is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 7, Page 13. BEING KNOWN AS 5 Citadel Drive, Camp Hill, PA 17011 PARCEL ID NO: 13-23-0547-588 IMPROVEMENTS THEREON CONSIST OF: Residential Dwelling {00075421l UNITED STATES BANKRUPTCY COURT MIDDLE DISTRICT OF PENNSYLVANIA IN RE: JEANETTE S. PIERCY CHAPTER 13 CASE NO.: 1-04-bk-00296 Debtor(s) ORDER DISMISSING CASE Upon consideration ofTrustee's Motion to Dismiss (and hearing if appropriate), and it having been determined that this case should be dismissed, it is ORDERED that the case of the above-named debtor(s) be and it hereby is dismissed and it is further ORDERED that the trustee hereby is discharged from further responsibility in this case, and it is further ORDERED that all pending adversary proceedings in this case be and they hereby are dismissed, and it is further ORDERED that any outstanding fees are immediately due and payable to the U ,8, Bankruptcy Court, By thr Comt, ~~~~ Dated: November 28, 2005 This electronic order is signed and filed on the same date. MDPA-DrSMISS2.WPT REV 6/05 I' . , MILSTEAD & ASSOCIATES, LLC By: Pina S. Wertzberger, Esquire Attorney ID# 77274 Woodland Falls Corporate Park 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorney for Plaintiff Deutsche Bank Company of California, N.A., as Trustee Under the Pooling and Servicing Agreement relating to IMPAC Secured Assets Corporation, Mortgage Pass-through Certificates Series 2000-5 Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 03-3215 Civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 vs. Jeanette S. Piercy Defendant(s) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Deutsche Bank Company of California, N.A., as Trustee Under the Pooling and Servicing Agreement relating to IMPAC Secured Assets Corporation, Mortgage Pass-through Certificates Series 2000-5, Plaintiff in the above entitled cause of action, sets forth as of the date the praecipe for writ of execution was filed the following information concerning the real property located at 5 Citadel Drive, Camp Hill, P A 17011: I. Name and address ofOwners(s) or Reputed Owner(s): Jeanette S. Piercy 5 Citadel Drive Camp Hill, P A 170 II 2, Name and address of Defendant(s) in the Judgment: Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: None Known (00075421} " , i 4, Name and Address of the last recorded holder of every mortgage of record: Deutsche Bank Company of California, N.A" as Trustee Under the Pooling and Servicing Agreement relating to IMP AC Secured Assets Corporation, Mortgage Pass-through Certificates Series 2000-5 (Plaintiff herein) 500 Enterprise Road, Suite 150 Harsham, P A 19044 Pennsylvania Housing Finance Agency 211 North Front Street P.O. Box 8029 Harrisburg,PA 17105 5. Name and address of every other person who has any record lien on the property: None Known 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: None Known 7, Name and address of every person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Tenant/Occupant 5 Citadel Drive Camp Hill, PA 17011 Department of Domestic Relations Cumberland County Courthouse 13 N. Hanover Street Carlisle, PAl 70 13 Commonwealth of Pennsylvania Department of Welfare P.O. Box 2675 Harrisburg, P A 17105 I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein e made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswo ifi at~~ tq, "tho ies. na S. Wertzberg Attorney for Plaint f Date: December 6, 2005 {00075421} t-,"l ',\ (.' ~, .. ( MILSTEAD & ASSOCIATES, LLC By: Pina S, Wertzberger, Esquire Attorney ID# 77274 Woodland Falls Corporate Park 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorney for Plaintiff Deutsche Bank Company of California, N.A., as Trustee Under the Pooling and Servicing Agreement relating to IMP AC Secured Assets Corporation, Mortgage Pass-through Certificates Series 2000-5 Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 03-3215 Civil Term Vs. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PA.R.C.P. 3129 Jeanette S. Piercy Defendant(s) TAKE NOTICE: Your house (real estate) at 5 Citadel Drive, Camp Hill, P A 17011 is scheduled to be sold at Sheriffs Sale on March 8, 2006 at 10:00 am in the Commissioner's Hearing Room, Cumberland County Courthouse, Carlisle, P A 17013 to enforce the Court Judgment of $135,727.30 obtained by Deutsche Bank Company of California, N.A., as Trustee Under the Pooling and Servicing Agreement relating to IMP AC Secured Assets Corporation, Mortgage Pass-through Certificates Series 2000-5. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The Sale will be cancelled if you pay to Milstead and Associates, LLC, Attorney for Plaintiff, back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call 856-482-1400. 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. {00075421 ) " ( 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 next page and how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling Milstead and Associates, LLC at 856-482-1400. 2. You may be able to petition the Court to set aside the Sale ifthe bid price was grossly inadequate compared to the market value of your property. 3. The Sale will go through only if the Buyer pays the Sheriff the full amount due on the Sale. To find out ifthis has happened you may call Milstead and Associates, LLC at 856-482-1400, 4. Ifthe amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the Sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a Deed to the Buyer. At that time, the Buyer may bring legal proceedings to evict you. 6. You may be entitled to a share ofthe money which was paid for your house. A Schedule of distribution of the money bid for your house will be filed by the Sheriff on a date specified by the Sheriff not later than 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. 7. You may also have other rights and defenses, or ways of getting your house back. if you act immediately after the Sale. YOU SHOULD TAKE THIS PAPER TO YOU 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 32 S, Bedford Street Carlisle, P A 17013 (717) 249-3166 (800) 990-9108 03-7-01539 [00075421 } . ( ALL that certain piece or parcel of land together with the improvements thereon erected, situate in Lower Allen Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the Southern side of a 50 foot wide road known as Citadel Drive, which point, measures along the Southern side of Citadel Drive, is 363.95 feet West of the Southwest comer of Citadel Drive and Colgate Drive, and which point also is at the Northwest comer of Lot No. 125 on Part of Plan No.2, Cedar Cliff Manor, recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 7, Page 13; thence at right angles to Citadel Drive Southwesterly along the Western line of Lot No. 125 aforesaid, 125 feet to a point at the Northern line of Lot No. 131 on Plan No.1, Cedar Cliff Manor, recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 6, Page 33; thence Westwardly along the Northern line of Lot Nos. 131 and 130 on Plan No.1, Cedar Cliff Manor aforesaid, 70 feet to a point at the Eastern line of Lot No. 127 on Part of Plan No.2, Cedar Cliff Manor aforesaid; thence at right angles to Citadel Drive Northwardly along the Eastern line of Lot No. 127 aforesaid, 125 feet to a point at the Southern side of Citadel Drive; thence Eastwardly along the southern side of Citadel Drive, 70 feet to a point, being the place of beginning. BEING Lot No. 126 on the Plan of Lots known as "Part of Plan No.2, Cedar Cliff Manor", which plan was approved by the Commissioners of Lower Allen Township on January 12, 1955 and is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 7, Page 13. BEING KNOWN AS 5 Citadel Drive, Camp Hill, PA 17011 PARCEL 10 NO: 13-23-0547-588 IMPROVEMENTS THEREON CONSIST OF: Residential Dwelling {00075421} C' (-.., --j"j ,_n, " ~) '.' I .. MILSTEAD & ASSOCIATES, LLC By: Pina S. Wertzberger, Esquire Attorney ID# 77472 Woodland Falls Corporate Park 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorney for Plaintiff Deutsche Bank Company of California, N.A., as Trustee Under the Pooling and Servicing Agreement relating to IMP AC Secured Assets Corporation, Mortgage Pass-through Certificates Series 2000-5 COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 03-3215 Civil Term Plaintiff AFFIDAVIT PURSUANT TO Pa.R.C.P.3129.2 Vs. Jeanette S. Piercy Defendant STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND ) ) I, Pina S. Wertzberger, Esquire, of full age, being duly sworn according to law, upon my oath, depose and say, 1. On January 9, 2006, a copy of the Notice of Sheriffs Sale of Real Property was served upon the defendant. Jeanette S. Piercy, by the Sheriffs Office of Cumberland County, A copy of the Sheriffs return is attached hereto and made a part hereof as Exhibit "A", 2. On January 6, 2006, a notice of Sheriffs Sale was served upon lien holders of record and interested parties by ordinary mail. A copy ofthe certificate of mailing is attached hereto and made a part hereof as Exhibit "B". _/ l00085784} ./ , 7, 0153~ Deutsche Bank Company of California N,A., as Trustee Under the Pooling and Servicing Agreement relating to IMP AC Secured Assets Corporation, Mortgage Pass-Through Certificates Series 2000-5 VS Jeanette S, Piercy The Court of Common Pleas of Cumberland County, Pennsylvania Writ No, 2003-3215 Civil Term Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on January 09, 2006 at 12:35 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit; Jeanette S. Piercy, by making known unto Janis Hamann, adult daughter of the defendant, at 5 Citadel Drive, Camp Hill, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same, Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on January 09, 2006 at 12:35 o'clock P,M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Jeanette S. Piercy, located at 5 Citadel Drive, Camp Hill, 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: Jeanette S. Piercy, by regular mail to her last known address of 5 Citadel Drive, Camp Hill, PA 17011. This letter was mailed under the date of January 10,2006 and never returned to the Sheriffs Office, Sworn and subscribed to before me This _ day of ~/~~ R, Thomas Kline, S'h;;ff BY '- !tt~ 1vLdJ) Real Estate Se geant 2006, A,D, ,- 4 '" ~ '0; m E m , '0 u. , ~ ?- m 0; i of 0. 1; C m W 0 i E ;;= 0; m U ;?;;; 0:: w m.c .. ! 0:: o ~ 0:: u. ~'- 0 m= 'C- W m 0 I- ~ ~ '" ~.. C .!!! "5. '.. -0 ::t;.. c 0 lIlU. Z m_ ~ m '" .. c '" "'0 'm 0.:= q.. 0:: E~ lIlU. '" m'C =- _m ~~ l- x 0 ~Z III ,,- 0 <(15 o::u. 0. 0:: "'" 0 G:lQ>~ U. ~'Co C ~ . '" mU U 1l lIl", 0 ...I m c lD 0 .. c " 'C.. W .. ~ I- ~ c E ~ '" ~- ~- ~- ii: c .. ~ m 0 '0; =0 ,E> .. 0 0:: :;; -;;;0. 0. 'C 0- -:? 0. m 0. ~ '" 11 0 . ad! '" :5:5 t)..: "g ~ ~~ U '", <(mo:: w m >- r 0:: DD ::: U g'm ,- '" :Om ...I ~'" ;{ :l!U =- u. '" 0 SE .. w '0; '0; .. 0. :;; :;; u. ~ m Ciiu -g w Jl~Cl!f: .. 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'" '" o :E,g "'" m .!!!:::c II) c CIl ~ rtl 0 Q) g lll'Q) ~ c::E~-g m::C 0"" m-C 0.0 E.~cJ-....Q)a..c Q) - ('II :s.... m.- t: &:s CJ.i~.!! Ul 0 .- tV II) O'_.!!! Q) J!l. 'OCC;lllQ)!?CU ai 5'~ t:~~~ B ...J",_ .~coac....o':;: - '-:0 g~..e rnfu :i ID..e 2 U 0.= IJ) (f) E~ii)Q.iQ.io:o~ (f) o..oCo..EO_clll w ~ ~8g=~~~ 0:: tii ~~o_~~~-8 ~ c >...... 0 ,_ 0 _ W o -", ~ It) IJ) III III cu u'c: El9-1J)_ 0.'0 C lllEEo~.gCf.llll Z '5-8 i3~ ~~=~ 00( g.=.g.5w a.~. c~ '- _ - C >.0::; Ul W .!!2~'iiicuo'2uB u: lllE~.9~E~'- i= ::I'x~o.g-8~~ .0:: ~ Ecu ~.~~.=E ~!S~ - 0..-00.. '- CU'- OlllX::::l>.Eo-~c' c.cuJlJ)_::::I"-Ulll oJ-.... lll'c: EOo.c ~o' -= (l)OE'- 1::..... !!=-g'!!:!lll~~::::I,~U .!!!~::::I~-gEu~:oc~ o IJ) (1)'- (I) c c -8-c"C a.E.c cu-g~w -~(I)O::::lJ-Clcu_~ 2* !3~,500-o'~CI) Q)'- 00 xoU.: lll~ ~~.g~~~.E~g6 w 0:: w I- III a w 0:: 0:: o u. " '" '"' o C. 0:: E w'" o.g> et ::2: w'" 1-0 ",E <(- :;; 0 I-m lIlE 0" o.~ J \\ .~ o ~ - '"' O.c ~'C .82 E ,!!2 "'l:t ~...I ZUlQ.i mBu c,!!:! ii 1-0.'" .. M '" ~ o ,.; .... .... '" M =- 0:: o U. III 0. ~ ... ;3 .. e .....' , , ~:::..... Cr'~ --1 :r 1'";1 -" !:--.='! '-...-.-' C) =~--; (...) C:J (/..' ...(-.1 -.-< COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which Deutsche Bank Co of California N A Tr is the grantee the same having been sold to said grantee on the 8th day of March A.D., 2006, under and by virtue of a writ Execution issued on the 7th day of Dec, A.D., 2005, out of the Court of Common Pleas of said County as of Civil Term, 2003 Number 3215, at the suit of Deutsche Bank Co of Cali fomi a N A Tr against Jeanette S Piercv is duly recorded in Deed Book No. 274, Page 1833. IN TESTIMONY WHEREOF, I ha4lereunto set my hand and seal of said office this f/ day of ,A.D. Recorder of Deeds CumbIItend County, c.IIfe, PA e.- lit.... ....,"'.....1010 ^ , Deutsche Bank Company of California N.A, as Trustee Under the Pooling and Servicing Agreement relating to IMP AC Secured Assets Corporation, Mortgage Pass-lbrough Certificates Series 2000-5 VS Jeanette S. Piercy The Court of Common Pleas of Cwnberland County, Pennsylvania Writ No. 2003-3215 Civil Term Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on January 09, 2006 at 12:35 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriff's Sale and Description, in the above entitled action, upon the within named defendant, to wit: Jeanette S. Piercy, by making known unto Janis Hamann, adult daughter of the defendant, at 5 Citadel Drive, Camp Hill, Cwnberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on January 09, 2006 at 12:35 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Jeanette S. Piercy, located at 5 Citadel Drive, Camp Hill, 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: Jeanette S. Piercy, by regular mail to her last known address of 5 Citadel Drive, Camp Hill, PA 17011. This letter was mailed under the date of January 10, 2006 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cwnberland County, Pennsylvania on March 08, 2006 at 10:00 o'clock AM. He sold the same for the swn of $1.00 to Pina Wertzberger, Esquire, for Deutsche Bank Company of California, N.A, as Trustee Under the Pooling and Servicing Agreement Relating to IMP AC Secured Assets Corporation, Mortgage Pass-lbrough Certificates, Series 2000-5. It being the highest bid and best price received for the same, Deutsche Bank Company of California, N.A, as Trustee Under the Pooling and Servicing Agreement Relating to IMPAC Secured Assets Corporation, Mortgage Pass-Through Certificates, Series 2000-5 of500 Enterprise Road, Suite 150, Horsham, PA 19044, being the buyer in this execution, paid to SheriffR. Thomas Kline the swn of$I,072.42. Sheriffs Costs: Docketing Poundage $30.00 21.03 " Posting Bills Advertising Acknowledging Deed Auctioneer Prothonotary Mileage Certified Mail Levy Surcharge Postage Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed 15.00 15.00 30.00 10.00 1.00 13.20 3.66 15.00 20.00 .78 443.00 369.20 21.05 25.00 39.50 $1,072.42 Sworn and subscribed to before me This 1 ~ day of 2006, A.D. ~~~..<:?~~ R. Thomas Kline, Sheriff BY Jo~ Real Estat ergeant \Ii) . ,,0' ~? ,\.00 ~y"\ 6' 101 tt.-..,'1 fPY.1 ,. / MILSTEAD & ASSOCIATES, LLC By: Pina S. Wertzberger, Esquire Attorney ID# 77274 Woodland Falls Corporate Park 220 Lake Drive East, Suite 30 I Cherry Hill, NJ 08002 (856) 482-1400 Attorney for Plaintiff Deutsche Bank Company of California, N.A., as Trustee Under the Pooling and Servicing Agreement relating to IMPAC Secured Assets Corporation, Mortgage Pass-through Certificates Series 2000-5 Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 03-3215 Civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 vs. Jeanette S. Piercy Defendant(s) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Deutsche Bank Company of California, N.A., as Trustee Under the Pooling and Servicing Agreement relating to IMP AC Secured Assets Corporation, Mortgage Pass-through Certificates Series 2000-5, Plaintiff in the above entitled cause of action, sets forth as of the date the praecipe for writ of execution was filed the following information concerning the real property located at 5 Citadel Drive, Camp Hill, P A 17011: ' 1. Name and address ofOwners(s) or Reputed Owner(s): Jeanette S. Piercy 5 Citadel Drive Camp Hill, P A 17011 2. Name and address of Defendant(s) in the Judgment: Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: None Known (OOO75421) ". , 4. Name and Address of the last recorded holder of every mortgage of record: Deutsche Bank Company of California, N.A., as Trustee Under the Pooling and Servicing Agreement relating to IMP AC Secured Assets Corporation, Mortgage Pass-through Certificates Series 2000-5 (Plaintiff herein) 500 Enterprise Road, Suite 150 Horsham, P A 19044 Pennsylvania Housing Finance Agency 211 North Front Street P.O. Box 8029 Harrisburg, P A 17105 5. Name and address of every other person who has any record lien on the property: None Known 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: None Known 7. Name and address of every person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Tenant/Occupant 5 Citadel Drive Camp Hill, PA 17011 Department of Domestic Relations Cumberland County Courthouse 13 N. Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare P.O. Box 2675 Harrisburg, P A 17105 I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein e made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswo i at' t tho' es. as. Wertzberg Attorney for Plaint Date: December 6. 2005 \,1") "~n I .,c:. V:(, -.. b ]: :Sri , ,. '-. . Ii' . ,....,., (OOO75421) .., I1Z z( d L- 3JO SIll Vd ').114000 UNV1~3l1Hnl) JUlH:ilHS :aM! JIG 3:lI.dJO . MILSTEAD & ASSOCIATES, LLC By: Pina S. Wertzberger, Esquire Attorney ID# 77274 Woodland Falls Corporate Park 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorney for Plaintiff Deutsche Bank Company of California, N.A., as Trustee Under the Pooling and Servicing Agreement relating to IMP AC Secured Assets Corporation, Mortgage Pass-through Certificates Series 2000-5 Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY : No.: 03-3215 Civil Term Vs. : NOTICE OF SHERIFF'S SALE OF : REAL PROPERTY PURSUANT TO PA,R.C.P. 3129 Jeanette S. Piercy Defendant(s) TAKE NOTICE: Your house (real estate) at 5 Citadel Drive, Camp Hill, P A 17011 is scheduled to be sold at Sheriff's Sale on March 8, 2006 at 10:00 am in the Commissioner's Hearing Room, Cumberland County Courthouse, Carlisle, PA 17013 to enforce the Court Judgment of$135,727.30 obtained by Deutsche Bank Company of California, N.A., as Trustee Under the Pooling and Servicing Agreement relating to IMP AC Secured Assets Corporation, Mortgage Pass-through Certificates Series 2000-5. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT TillS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The Sale will be cancelled if you pay to Milstead and Associates, LLC, Attorney for Plaintiff, back payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay, you may call 856-482-1400. 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. {OO07542I} 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 next page and how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling Milstead and Associates, LLC at 856-482-1400. 2. You may be able to petition the Court to set aside the Sale if the bid price was grossly inadequate compared to the market value of your property. 3. The Sale will go through only if the Buyer pays the Sheriff the full amount due on the Sale. To find out if this has happened you may call Milstead and Associates, LLC at 856-482-1400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the Sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a Deed to the Buyer. At that time, the Buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A Schedule of distribution of the money bid for your house will be filed by the Sheriff on a date specified by the Sheriff not later than 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. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the Sale. YOU SHOULD TAKE TIDS PAPER TO YOU 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 32 S. Bedford Street Carlisle, P A 17013 (717) 249-3166 (800) 990-9108 03-7-01539 {00075421} , ALL that certain piece or parcel ofland together with the improvements thereon erected, situate in Lower Allen Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the Southern side of a 50 foot wide road known as Citadel Drive, which point, measures along the Southern side of Citadel Drive, is 363.95 feet West of the Southwest corner of Citadel Drive and Colgate Drive, and which point also is at the Northwest corner of Lot No. 125 on Part of Plan No.2, Cedar Cliff Manor, recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 7, Page 13; thence at right angles to Citadel Drive Southwesterly along the Western line of Lot No. 125 aforesaid, 125 feet to a point at the Northern line of Lot No. 131 on Plan No. I, Cedar Cliff Manor, recorded in the Office of the RecorderofDeeds in and for Cumberland County, Pennsylvania, in Plan Book 6, Page 33; thence Westwardly along the Northern line of Lot Nos. 131 and 130 on Plan No.1, Cedar Cliff Manor aforesaid, 70 feet to a point at the Eastern line of Lot No. 127 on Part of Plan No.2, Cedar Cliff Manor aforesaid; thence at right angles to Citadel Drive Northwardly along the Eastern line of Lot No. 127 aforesaid, 125 feet to a point at the Southern side of Citadel Drive; thence Eastwardly along the southern side of Citadel Drive, 70 feet to a point, being the place of beginning. BEING Lot No. 126 on the Plan of Lots known as "Part of Plan No.2, Cedar Cliff Manor", which plan was approved by the Commissioners of Lower Allen Township on January 12, 1955 and is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 7, Page 13. ., BEING KNOWN AS 5 Citadel Drive, Camp Hill, PA 17011 PARCEL ill NO: 13-23-0547-588 IMPROVEMENTS THEREON CONSIST OF: Residential Dwelling {OO075421} \lm 1"(" -' ."....1- ... '~_ ," .J b J: :)[1 \ '; , ~ . h~ l( d L - 330 SIll vi~~~oiHrlo1~8f3jj~a WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N005-3215 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK COMPANY OF CALIFORNIA N.A. as Trustee Under the Pooling and Servicing Agreement Relating to IMP AC Secured Assets Corporation, Mortgage Pass-through Certificates Series 2000-5 Plaintiff (s) From Jeanette S. Piercy (I) You are directed to levy upon the property of the defendant (s)and to sell See Legal Discription , (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 himlher that he/she has been added as a garnishee and is enjoined as above stated, Amount Due$135,727.30 L.L. Interest From 9/20/03 to Date of Sale at $22.31 per diem Atty's Comm % Due Prothy $1.00 Atty Paid $971.72 Plaintiff Paid Date: December 7, 2005 Other Costs (Seal) CURTIS R. LONG :;th~4?~ Deputy REQUESTING PARTY: Name Pina S. Wertzgerger, Esq. Address: Milstead & Associates, LLC Woodland Falls Corporate Park 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 Attorney for: Plaintiff Telephone: 856-482-1400 Supreme Court ill No, 77274 , ~"l\1 (IF r. ., J ~. -:'" L:l j' .)" '....',. "\.'. Real Estate Sale # 43 On Decemberl2, 2005 the Sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA Known and numbered as 5 Citadel Drive, Camp Hill, more fully described on Exhibit "A" e> ~ ~ GV ~ filed with this writ and by this reference incorporated herein. Date: December 12,2005 BY0o~~ Real Estate Sergeant rlJl I( c:.rJ L.~iJ.. V, :A i.M~~OjB~~1~lJmfJ , . . ".. 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 Michael Morrow, being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co" a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular dailyand/or Sunday! Metro editions which appeared in the 24th and 31st day(s) of January and the 7th day(s) of February 2006. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co, aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317, PUBLICATION COPY S ALE #43 Sworn to and subscribed be 06 A.D. . . CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTIIOUSE CARLISLE, P A, 17013 , , , . PRO;)F OF PUBLICATION 01- .'~OTICE IN CUMBERLAND LAW JOURNAL (Under Acl No, 587, approved May 16, 1<)29), P. L.1784 STATEOFPENNSYLVANi\ : 55. COUNTY OF CUMBERLA,\lJ : Lisa Marie Coyne, I-:'.quire, Editor 01 the CnmberLllld Law Journal, of the County and State aforesaid, being duly S\hlrll, according lu law, deposes and says that the Cumberland Law Journal, a legal periodical pubi"lied in the Boruugh of Carlisle in the County and State aforesaid, was established January 2, . ')52, imd designated by the local courts as the official legal periodical for the publication ,,[ "Illegal notices, and has, since January 2, 1952, been regularly issued weekly in the said (\)(:IIIV, and thai tile printed notice or publication attached hereto is exactly the same as was prim'll In the regul", editions and issues of the said Cumberland Law Journal on the following dates, VIZ: January 20, 2., icbruary 3, 2(Ju6 Affiant further depose, lllert he is authurized to veriry this statement by the Cumberland Law Journal, a legal periodio: "I' general circulation, and tl'ilt he is not interested in the subject matter of the aforesaid nOli,,' or advertisement, and tl1,,1 all allegations in the foregoing statements as to time, place aiL! i'haracler 01 publication are 11'lle, ~ Isa Millie Coyne, Editor SWO TO Al\[) SUBSCRIBED before me this _~day of Febmarv. 2006 ~A~)L r.-" ~..,,~__ NOTARli\L SEAL I ~O!S E. SNYDER, Notary Puhlic ; , ~a:!~;l::,~:?,;~ cumber~:(jc~~~~~()9 ..._"',."'..t,'''....'........".,.,.,..~''''. IlSAI. _TATS MI.& 110. 4S Wrtt No. 2003-3215 Civil Deutsche Bank Company of California. N.A.. as Trustee Under the Pooltng and ServIcing Agreement relattng to IMPAC Secured Assets Corporation. Mortgage Pass-Through Certificates Series 2000-5 vs. Jeanette S. Piercy Atty,: Plna Wertzberger ALL that certain piece or parcel of land together with the improve- ments thereon erected. situate in I..-- Allen Townshlp, Cumberland County. Pennsylvania. bounded and described as follows: BEGINNING at a point on the Southern side of a 50 foot wide road known as Citadel DrIve. which point. measures along the Southern side of Citadel Drive. is 363.95 feet West of the Southwest corner of Citadel DrIve and Colgate DrIve. and which point also Is at the Northwest corner of Lot No. 125 on Part of Plan No.2. Cedar Cliff Manor, re- corded in the Office of the Recorder of Deeds in and for Cumberland County' I Pennsylvania. in Plan Book 7. Page 13: thence at rIght angles to Citadel DrIve Southwesterly along the Western line of Lot No. 125 aforesaid. 125 feet to a point at the Northern line ofLat No. 131 on Plan No.!, Cedar Cliff Manor, recorded in the Office of the Recorder of Deeds in and for Cumberland County. PennsylvanJa, in Plan Book 6, Page 33; thence Westwardly along the Northern line of Lot Nos, 131 and 130 on Plan No, I. Cedar Cliff Manor aforesaid, 70 feet to a point at the Eastern line of Lot No, 127 on Part of Plan No.2, Cedar Cliff Manor aforesaid; thence at right angles to Citadel Drtve North- wardly along the Eastern line of Lot No. 127 aforesaid, 125 feet to a point at the Southern side of Cita- del Drtve: thence Eastwardly along the southern stde of Citadel Drive. 70 feet to a point. being the place of beginning, BEING Lot No, 126 on the Plan of Lots known as "Part of Plan No. 2. Cedar Cliff Manor". which plan was approved by the Commission- ers of Lower Allen Township on January 12. 1955 and is recorded in the Office of the Recorder of Deeds in and (or Cumberland County. Pennsylvania. in Plan !look 7. Page 13. BEING KNOWN AS 5 Citadel DrIve. Camp Hm. PA 1701l. PARCEL ID NO: 13-23-0547- 588. IMPROVEMENTS THEREON CONSIST OF: Residential Dwelling,