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HomeMy WebLinkAbout07-4753PECHT & ASSOCIATES Herbert P. Henderson, II, Esquire 55 West High Street Elizabethtown, PA 17022 (717) 367-2800 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW JAMES F. DOUGHERTY Plaintiff No. b ~- y x.53 ~.~.~.~ "7~.t,.~.~ vs. AMANDA L. MAJOR Defendant ACTION IN CUSTODY CUSTODY COMPLAINT 1. The Plaintiff, James F. Dougherty, is an adult individual, residing at 1404 Walnut Street, Camp Hill, Pennsylvania 17011. 2. The Defendant, Amanda L. Major, is an adult individual, with a last known address of 410 Sutro Court, Hemet, California 92544. Despite repeated requests, Defendant has failed to provide Plaintiff with her current address. 3. The Father seeks primary physical and shared legal custody of the following child: Ruby Major, age 1 month, born July 3, 2007. 4. The child was born out of wedlock. 5. The child is presently in the custody of Mother, Amanda L. Major, who resides at 410 Sutro Court, Hemet, California 92544. 6. Since her birth, the child has resided with the following persons and at the following addresses: (a) Amanda L. Major, 410 Sutro Court, Hemet, California 92544. 7. The Mother of the child currently resides at 410 Sutro Court, Hemet, California 92544. She is single. 8. The Father of the child currently resides at 1404 Walnut Street, Camp Hill, Pennsylvania 17011. He is single. 9. The relationship of the Plaintiff to the child is that of natural father. The Father currently resides alone. 10. The relationship of the Defendant to the child is that of natural mother. The Mother currently resides with maternal grandparents, Mr. and Mrs. Major, (first names unknown to Plaintiff), and the subject child. 11. Plaintiff believes and therefore avers that jurisdiction properly vests in Pennsylvania and venue in the Court of Common Pleas of Cumberland County due to the fact that Defendant did without justification, excuse, or reason flee the Commonwealth of Pennsylvania during her pregnancy for the State of California. 12. Plaintiff believes and therefore avers that if, in fact, the Defendant would have remained in the Commonwealth that the she would not be permitted to flee the Commonwealth for the State of California and expect California to exercise jurisdiction until she had resided there with the child for a period of six months and, therefore, she should not be permitted to flee the Commonwealth while pregnant, give birth in the State of California and be able to have jurisdiction conferred. 13. Plaintiff believes and therefore avers that this Court should exercise a discretion and accept jurisdiction and enter an Order directing that the Commonwealth is the proper forum for determining the respective custody rights. 14. The Father has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 15. The Father has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 16. The Father does not know of a person not a party to the proceeding who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 17. The best interest and permanent welfare of the child will be served by granting the relief requested because: (a) Father has the facilities to provide for the care, comfort, and needs of the child, as well as the genuine desire and ability to while she is in Father's custody. (b) Father believes that the child would benefit from an ongoing relationship with both of her natural parents pursuant to a schedule of primary and partial physical custody. (c) Mother failed to provide Father with notice of birth as it was Father's wish to be there at the time of child's birth. (d) Mother has acted contrary to the best interest of the child by keeping the child from Father in retribution for matters having nothing to do with the custody or care of child. 15. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, the Father respectfully requests your Honorable Court to grant primary physical and shared legal custody of the child to him. & ASSOCIATES, PC Herbert P. Henderson, II, Esquire Attorney for Father 55 West High Street Elizabethtown, PA 17022 Telephone: (717) 367-2800 Attorney I.D. #56304 7185189718 I.T. DEPT 15:04:40 08-03-2007 2 /2 VERIFICATION I have read the foregoing and hereby affirm that it is true and correct to the best of my lmowledge, information and belief. This verification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to the unsworn falsification to authorities. CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was served on the following individual and in the manner set forth on the ~ day of , 2007. Service by certified mail, addressed to: Amanda L. Major 410 Sutro Court Hemet, California 92544 Respectfully Submitted, PECHT & ASSOCIATES, PC By: Herbert P. Henderson, II, Attorney for Father 55 West High Street Elizabethtown, PA 17022 Telephone: (717) 367-2800 Attorney I.D. #56304 'lp ~ # ~ ~ rv =; `~ ~ ~ ~ ' ~ ,~~. „~ ~ ~'°} ""~ JAMES F. DOUGHERTY IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. • 2007-4753 CIVIL ACTION LAW AMANDA L. MAJOR IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, August 21, 2007 ,upon. consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. ,the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, September 13, 2007 ____ at _9:00 AM for aPre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard. by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Dawn S. Sunda Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled. individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD UNE, Ci0 TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 t , _ -, ~' ~ : ~'"~1tn~ 'C~ ~ B F ~',~! ~ ~ Ali ,..t ,d' L.UUV ii ~ V+ '- NOV 2120D7 JAMES F. DOUGHERTY Plaintiff vs. AMANDA L. MAJOR Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2007-4753 CIVIL ACTION LAW . IN CUSTODY ORDER AND NOW, this 1_ 9th_ day of November, 2007 ,the conciliator, being advised by the plaintiffls counsel that custody proceedings have been initiated and are in process in California, hereby relinquishes jurisdiction. No custody conciliation conference shall be scheduled as afollow-up to the initial conference on September 13, 2007. FOR THE COURT, Dawn S. Sunday, Esquire Custody Conciliator C7 ~, ~ Q ` .. ,~ s7 . E.i n ~'~ ~ C.7 ~- , ~„ - "t. !'t't _ v ~ „>. fV C7"1 ~ -'x7 ~ -~ ?~- ~... _-j G... C_~' ~ f n C..3 •~ C:~ ~ .~ fV •' ~ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff __. .., ~ ~_"~ Jody S Smith Chief Deputy Edward L Schorpp Solicitor Deutsche Bank Trust Co vs. Karena J Winters `~ JAN29 PM 3~ 24 MS t' ~° ~ , „t,~tdr~ d (~.: r•. ~~ SHERIFF'S RETURN OF SERVICE Case Number 2007-4763 10/01/2009 06:36 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on 10/1/09 at 1836 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 Karena J. Winters, located at, 212 North 2nd Street, Enola, Cumberland County, Pennsylvania according to law. 10/16!2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Karena J. Winters but was unable to locate her in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale and Description as NOT FOUND as to the defendant Karena J. Winters, 212 North 2nd Street, Enola, PA is vacant, defendant did not leave a forwarding address at the post office. 12/08/2009 Property sale postponed to 1/6/2010. 01/06/2010 Property sold to Mortgage Company for 1.00 on 1/6/10 01/11/2010 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 December 9, 2009 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Stuart Winneg, on behalf of Deutsche Bank National Trust Company, as Trustee for Soundview Home Loan Trust 2006-E01, 12650 Ingenuity Drive, Orlando, FL 32826, being the buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of $ 905.25 SHERIFF COST: $905.25 January 11, 2010 SO~ERS, NY R ANDERSON, SHERIFF ~~u~ ~c ~ ~~~ ~~ Lv ~C ~ ~' ~ 5 J~' ~-- ~' ` 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 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsC~udren.com ATTORNEY FOR PLAINTIFF Deutsche Bank Trust Co. :COURT OF COMMON PLEAS Americas, as Trustee and :CIVIL DIVISION Custodian for Soundview Home .Cumberland County Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc. as its :MORTGAGE FORECLOSURE attorney-in-fact Plaintiff _ v. Karena J. Winters Defendant(s) NO. 07-4763 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129.1 Deutsche Bank Trust Co. Americas, as Trustee and Custodian for Soundview Home Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact, 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: 212 North 2nd Street, Enola, PA 17025 1. Name and address of Owner(s) or reputed Owner(s): Name Address Karena J. Winters 212 North 2nd Street, Enola, PA 17025 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 i ~~ 4'.~Name~and address of the last recorded holder of every mortgage of record: Name Address Deutsche Bank 4708 Mercantile Drive Trust Co. Americas, Fort Worth, TX 76137 as Trustee and Custodian for Soundview Home Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc. as its attorney-in-fact 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. Domestic Relations Section Commonwealth of PA, Department of Revenue 7. Name and address of has knowledge who has affected by the sale: Name Tenants/Occupants Address 212 North 2nd Street (East Pennsboro Township) Enola, PA 17025 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: July 1, 2009 UDREN LA FFICES,~P.C. BY : ~' / li~ Att~rfnq~y for Plaintiff MARK J~. DREN, ESQUIRE 'Q'UART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE 1 Courthouse Sq., Carlisle, PA 17013 13 N. Hanover St. Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 every other person of whom the plaintiff any interest in the property which may be Deutsche Bank Trust Co. :COURT OF COMMON PLEAS Americas, as Trustee and :CIVIL DIVISION Custodian for Soundview Home :Cumberland County Loan Trust 2006-EQ1 by: Saxon Mortgage Services, Inc. as its :MORTGAGE FORECLOSURE attorney-in-fact Plaintiff v. Karena J. Winters €NO. 07-4763 CIVIL TERM Defendant(s) UpREN'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 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Karena J. Winters 212 North 2nd Street, Enola, PA 17025 Your house (real estate) at 212 North 2nd Street (East Pennsboro Township) Enola, PA 17025 is scheduled to be sold at the Sheriff's Sale on December 9, 2009, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $102,415.04, 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 NtAY•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 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 ALL THAT PARCEL OF LAND IN EAST PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, STATE OF PENNSYLVANIA, AS MORE FULLY DESCRIBED IN DEED BOOK 197, PAGE 1146, ID# 45-17-1044-2000, BEING KNOWN AND DESIGNATED AS BEING ALL THAT CERTAIN LOT OF GROUND SITUATED ON THE WEST SIDE OF NORTH SECOND STREET, BEING KNOWN AND SHOWN AS LOT NO. 4A ON A CERTAIN PLAN OF LOTS ENTITLED "FINAL SUBDIVISION PLAN FOR JANNIE MILDRED ESLINGER, ALSO KNOWN AS MILDRED, JENNIE ESLINGER" DATED MARCH 25, 1979, AND RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA IN PLAN BOOK 38, PAGE 103. HAVING THEREON ERECTED A DWELLING KNOWN AND NUMBERED AS 212 SECOND STREET. DEED FROM TODD A. DIETRICH AND FRAN DIETRCH, HUSBAND AND WIFE AS SET FORTH IN DEED BOOK 197, PAGE 1146 DATED 04/23/1999 AND RECORDED 04/23/1999, CUMBERLAND COUNTY RECORDS, COMMONWEALTH OF PENNSYLVANIA. BEING KNOWN AS: 212 NORTH 2ND STREET, ENOLA, PA 17025 PROPERTY ID NO.: 45-17-1044-2000 TITLE TO SAID PREMISES IS VESTED IN KARENA J. WINTERS, SINGLE PERSON BY DEED FROM TODD A. DIETRICH AND FRAN DIETRICH, HUSBAND AND WIFE DATED 4/23/99 RECORDED 4/23/99 IN DEED BOOK 197 PAGE 1146. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) N007-4763 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK TRUST CO AMERICAS, AS TRUSTEE AND CUSTODIAN FOR SOUNDVIEW HOME LOAN TRUST 2006-EQl BY: SAXON MORTGAGE SERVICES, INC. AS ITS ATTORNEY-IN-FACT Plaintiff (s) From KARENA J. WINTERS (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$102,415.04 L.L. Interest FROM 9/23/07 TO DATE OF SALE DECEMBER 9, 2009 -ONGOING PER DIEM OF $22.32 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $18,056.88 Atty's Comm % Due Prothy $2.00 Atty Paid $2,063.76 Other Costs Plaintiff Paid Date: July 14, 2009 Curtis . Long, P no ary (Seal) By: Deputy REQUESTING PARTY: Name STUART WINNEG, 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. 45362 Real Estate Sale # On August 19, 2009 the Sheriff levied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, PA Known and numbered as, 212 North 2"d Street, Enola, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 19, 2009 By: e.. Rea sae oordinator j ._ _ , ~~ ~, ~l '° 1 ,- -~',E PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 23, October 30 and November 6, 2009 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. Wdt No. 2007-4763 Civil Deutsche Bank Trust Co. Americas, as Trustee and Custodian for Soundview Home Loan Trust 2006- EQl by: Saxon Mortgage Services, Inc., as its Attorney-in-Fact vs. Karena J. Winters Atty: Stuart Winneg ALL that parcel of land in East Pennsboro Township, Cumberland County, State of Pennsylvania, as more fully described in Deed Book 197, Page 1146, ID# 45-17-1044- 2000, being known and designated as BEING all that certain lot of ground situated on the west side of North Second Stxeet, being known and shown as Lot No. 4A on a certain plan of lots entitled "Final Subdivi- ...,... rn__ e__ r_~_._..._u__~ ,,. _, /L,fsa Marie Coyne, E~Qitor SWORN TO AND SUBSCRI/BED before me this _.._ 6 day of November, 2009 Notary ~~~+<w.~ ~tAL DEBORAH A COLLINS NoTary Public CARLISLE BORO, CUMBERLAND COUNN --- The Patriot-News Co. • $12 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 ~e~lahiot-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 Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Leslie Kramer, 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: 10/23/09 10/30/09 Sworn to and~su ~ scribed before this,- d of ovember, 2009 A.D. ~Lt-tit((, ~~' -~" Notary Publi ~-_--~-' COMMONWEALTH OF PENNgyLVANIA Notar.'al Spa! Sherrio L nRr, Ncrtary Public City 0- Narrl~k~e.ir~, Dauphin County My Commis+n~ ;=;:~i~ ~4ov. 26, 2011 Member, Penneylvanis~Aesoclatlon .p- Notarl~~ 11 /06109 1NMt No. Z0~17-4i'~i Gt7rM ~m Dry ~b~k7fwrt Ca. p Aenb~kens, ~atttu~ bred C'ubMdibn for ~duridvlow Mon~b L~gn Must ~0~6-EtX1 byp Slutbn ,I~AOI't9b~b ~lNIC~r IfICr ab ItE A#ome~r-ln-Fact ~Ib I~brenb J. vVtirtbrs • Atty: Stuer< Wfnrrieip ALL THAT PARCET. OF LAND-IN EAST PENAISBORO. TOVUNSHII', CUMBERLAND COUNTY, STATE OF'PBI~NSYLVANIA, AS MORE FIJLGY' DESCt~ED IN DEED BOOK 197, •PAGE 1145; ID#, 43-17-1044-2000, BEING IfiI!iOWNT'ANt) D~StONATED AS BEING Alit' THAT CERTAIN LOT: OF GROUND S~f[JATED ON THE WEST S)DE OF .NORTH SECOND STREET, BEING KNOWN ANTI) SIiOWN AS.j.OT Nt). 4A ON A CERTAIN ,PLAN OF-LOTS ENTITLED "1+A(AL SUBDJVtffiK)N PCA1V fIOR'JANNiE MILDREI)'ESLIlVGEtt, ALSO KN©WN AS MB.DRED, ]ENNIE ESiJN(JER" DATED .MARCH 25,1979 (tND RECOTtDED ItV T}IE OFFCCE OF T4'IE RF,CORDER OP DEEbS IlV AND PUR CUMBBRt.AND C4IJNTY, PENNSYLVANIA IN PLAN BOOK 38, PAGE 103. ~ , ,~, ~~~ , FRAN p1BTRCt1,.liIJS,BA~Fp AND W$~B AS SEI'' . JN DPA,D B001~ 197, PAGE 1146 DATII? ANb RECORDI~ 041231 1999, C~1MB CAUNT7 RBGORDS, . CflMMONWEPiC'fS~t, ~INSYLVANIA. BEINGICNOWNAS:; „212'I~RTH:ZND STRSR't' ~iOLA PIA 19025 ;. PROFE@1'Y B> NO; y 45~}Tr1gp4~2000 T1TLR Ta SAJD PREMISES IS:`V$31ED.IN KARENA J. WINI'HRS, 61NGLE PERSftii gY DEBD I~O~!I-~DDD A. ' t718'iRIC#I ANIb AA,AN:DIEt'AB~t; HUS~ANp Fi~iD WIl'E IaA7'P,D ,Y33(9q U2'V99 IN DEED BOOK J91 PA{i81146: 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 Sheriffs Deed in which .SOUNDVIEW HOME LOAN TRUST 2006-EQ1 TR is the grantee the same having been sold to said grantee on the 9TH day of DEC A.D., 2009, under and by virtue of a writ Execution issued on the 14TH day of JULY, A.D., 2009, out of the Court of Common Pleas of said County as of Civil Term, 2007 Number 4763, at the suit of SOUNDVIEW HOME LOAN TRUST 2006-EQ1 TR AIF against KARENA J WINTERS is duly recorded as Instrument Number 201002688. ~: - IN TESTIMONY WHEREOF, I have hereunto set my hand ~ _ -- and eal of said office this ~ da of Y ,~ -~ - - ~,,' , A.D. ~~ o ~ D _,~ :, .. f :._ ~~ ~~ ;~~ t:~ ~ ,~ _ ., ,.-~ Re r r of Deeds ~~ ~ r~, ~` ~ ,~ ~. ~a 4.,~ ~~ ~~.,~ ~ 6w ,~b r ' w ci Js:rl. ~U i~