HomeMy WebLinkAbout07-4881PHELAN HALLINAN &SCHMIEG, LLP
LAWRENCE T. PHELAN, ESQ., Id. No. 32227
FRANCIS S. HALLINAN, ESQ., Id. No. 62695
DANIEL G. SCHMIEG, ESQ., Id. No. 62205
ONE PENN CENTER PLAZA, SUITE 1400
PHILADELPHIA, PA 19103
~215Z 563-7000 1s97so
DEUTSCHE BANK NATIONAL TRUST
COMPANY AS TRUSTEE UNDER THE POOLING
AND SERVICING AGREEMENT DATED AS OF
SEPTEMBER 1, 2005, GSAMP TRUST 2005-WMC1
4828 LOOP CENTRAL DRIVE
HOUSTON, TX 77081-2226
Plaintiff
v.
RICHARD A. STAMBAUGH
KRISTINA M. STAMBAUGH
141 EAST MAIN STREET
WALNUT BOTTOM, PA 17266
Defendants
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM
NO. D? - N881 C' tvi l TeXn+
CUMBERLAND COUNTY
CIVIL ACTION -LAW
COMPLAINT IN MORTGAGE FORECLOSURE
File #: 169750
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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(800)990-9108
File #: 159750
IF THIS IS THE FIRST NOTICE THAT YOU HAVE
RECEIVED FROM THIS OFFICE, BE ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION
PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977),
DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE
DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S)
DO SO IN WRITING WITHIN THIRTY (30) DAYS OF
RECEIPT OF THIS PLEADING, COUNSEL FOR
PLAINTIFF WILL OBTAIN AND PROVIDE
DEFENDANT(S) WITH WRITTEN VERIFICATION
THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED
TO BE VALID. LIKEWISE, IF REQUESTED WITHIN
THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING,
COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S)
THE NAME AND ADDRESS OF THE ORIGINAL
CREDITOR, IF DIFFERENT FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT UNTIL
THE END OF THE THIRTY (30) DAY PERIOD
FOLLOWING FIRST CONTACT WITH YOU BEFORE
SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH
THE LAW PROVIDES THAT YOUR ANSWER TO THIS
File #: 159750
COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN
TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION
OF THAT TIME. FURTHERMORE, NO REQUEST WILL
BE MADE TO THE COURT FOR A JUDGMENT UNTIL
THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU
HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF
YOU REQUEST PROOF OF THE DEBT OR THE NAME
AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN
THE THIRTY (30) DAY PERIOD THAT BEGINS UPON
YOUR RECEIPT OF THIS COMPLAINT, THE LAW
REQUIRES US TO CEASE OUR EFFORTS (THROUGH
LITIGATION OR OTHERWISE) TO COLLECT THE DEBT
UNTIL WE MAIL THE REQUESTED INFORMATION TO
YOU. YOU SHOULD CONSULT AN ATTORNEY FOR
ADVICE CONCERNING YOUR RIGHTS AND
OBLIGATIONS IN THIS SUIT.
IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A
DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT
A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON
REAL ESTATE.
File #: 159750
Plaintiff is
DEUTSCHE BANK NATIONAL TRUST COMPANY
AS TRUSTEE UNDER THE POOLING AND SERVICING
AGREEMENT DATED AS OF SEPTEMBER 1, 2005,
GSAMP TRUST 2005-WMC1
4828 LOOP CENTRAL DRIVE
HOUSTON, TX 77081-2226
2. The name(s) and last known address(es) of the Defendant(s) are:
RICHARD A. STAMBAUGH
KRISTINA M. STAMBAUGH
141 EAST MAIN STREET
WALNUT BOTTOM, PA 17266
who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described.
3. On 06/30/2005 mortgagor(s) made, executed, and delivered a mortgage upon the
premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION
SYSTEMS, INC. AS A NOMINEE FOR WMC MORTGAGE CORP. which mortgage is
recorded in the Office of the Recorder of CUMBERLAND County, in Book: 1913, Page:
3412. PLAINTIFF is now the legal owner of the mortgage and is in the process of
formalizing an assignment of same. The mortgage and assignment(s), if any, are matters
of public record and are incorporated herein by reference in accordance with Pa.R.C.P.
1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to
pleadings if those documents are of public record.
4. The premises subject to said mortgage is described as attached.
File ft: 159'750
5.
6
The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 04/01/2007 and each month thereafter are due and unpaid, and by the terms
of said mortgage, upon failure of mortgagor to make such payments after a date specified
by written notice sent to Mortgagor, the entire principal balance and all interest due
thereon are collectible forthwith.
The following amounts are due on the mortgage:
Principal Balance $104,483.05
Interest $3,314.09
03/01/2007 through 08/16/2007
(Per Diem $19.61)
Attorney's Fees $1,250.00
Cumulative Late Charges $139.44
06/30/2005 to 08/16/2007
Cost of Suit and Title Search 550.00
Subtotal $109,736.58
Escrow
Credit $0.00
Deficit $0.00
Subtotal 0.00
TOTAL $109,736.58
7
If the mortgage is reinstated prior to a Sheriffs Sale, the attorney's fee set forth above may
be less than the amount demanded based on work actually performed. The attorney's fees
requested are in conformity with the mortgage and Pennsylvania law. Plaintiff reserves its
right to collect attorney's fees up to 5% of the remaining principal balance in the event the
property is sold to a third party purchaser at Sheriff s Sale, or if the complexity of the
action requires additional fees in excess of the amount demanded in the Action.
File #: 159750
B. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment)
against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a
sepazate Action to establish that right, if such right exists. If Defendant(s) has/have
received a dischazge of personal liability in a bankruptcy proceeding, this Action of
Mortgage Foreclosure is in no way an attempt to reestablish such personal liability
dischazged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged
premises pursuant to Pennsylvania Law.
9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's
Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or
Notice of Default as required by the mortgage document, as applicable, have been sent to
the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by
said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff
or an authorized consumer credit counseling agency, or has/have been denied assistance
by the Pennsylvania Housing Finance Agency.
File #: 159750
10. This action does not come under Act 6 of 1974 because the original mortgage amount
exceeds $50,000.
WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum
of $109,736.58, together with interest from 08/16/2007 at the rate of $19.61 per diem to the date
of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure
and sale of the mortgaged property.
PHELA HALLI/NAN &SCHMIEG, LLP
/ f
By: //Francis S. Hallinan
LAWRENCE T. PHELAN, ESQUIRE
DANIEL G. SCHMIEG, ESQUIRE
FRANCIS S. HALLINAN, ESQUIRE
Attorneys for Plaintiff
File #: 159750
LEGAL DESCRIPTION
ALL the following described real estate lying and being situate in the Village of Walnut Bottom,
South Newton Township, Cumberland County, Pennsylvania, more particularly described as
follows:
BEGINNING at a set railroad spike in the centerline of PA Traffic Route 174 (Walnut Bottom
Road) at common corner of Lots 1 and 2 on the herein referred to subdivision plan; thence along
common boundary line of Lots 1 and 2, which is also the easterly most boundary of Parcel 1 A,
South thirty-seven (37) degrees twenty-four (24) minutes fifty-five (55) seconds East, ninety-six
and fifty-seven hundredths (96.57) feet to a set iron pin; thence continuing by same, South forty-
five (45) degrees forty-nine (49) minutes twenty-five (25) seconds East, one hundred eighteen
and thirty hundredths (118.30) feet to a set iron pin in line of land now or formerly of Ronald A.
Baker; thence along line of land now or formerly of Ronald A. Baker, South forty-nine (49)
degrees zero (00) minutes zero (00) seconds West, thirty-nine and thirty-two hundredths (39.32)
feet to a point; thence continuing by the same, South forty-nine (49) degrees zero (00) minutes
zero (00) seconds West, fifty and zero hundredths (50.00) feet to a point at corner of land now or
formerly of Randy K. Boyer; thence along line of land now or formerly of Randy K. Boyer,
North forty-three (43) degrees fifteen (15) minutes two (02) seconds West, two hundred thirteen
and thirty-seven hundredths (213.37) feet to a point in the centerline of Walnut Bottom Road;
thence along the centerline of Walnut Bottom Road, North forty-six (46) degrees fifty-seven (57)
minutes thirty-one (31) seconds East, fifty and zero hundredths (50.00) feet to a point; thence
continuing by same, North forty-nine (49) degrees fifty-seven (57) minutes zero (00) seconds
File #: 159750
East, forty-three and eighty-three hundredths (43.83) feet to the set railroad spike, the point and
place of BEGINNING.
CONTAINING a total area of 18,793 square feet (0.431 acres).
BEING known and designated as Lot No. 1 on a subdivision plan entitled'Survey for Mary O.
Bowers' prepared by Steven P. Wolfe, Professional Land Surveyor, dated 4/11/90, which
subdivision plan has been approved by the appropriate municipal authorities as and for a
subdivision plan and is recorded in the office of the Recorder of Deeds in and for Cumberland
County, Pennsylvania in Plan Book 69, Page 36.
BEING the same premises which Bonnie Swartz and Harold Bowers, Sr., co-Executors of the
Last Will and Testament of Mary O. Bowers, by their deed dated May 10, 1995, and recorded in
Cumberland County, Pennsylvania Deed Book 122, Page 408, granted and conveyed unto Randy
V. Singleton, a single man, Grantor herein.
PARCEL#: 41-31-2230-064
PROPERTY BEING: 141 EAST MAIN STREET
File #: 159750
VERIFICATION
FRANCIS S. HALLINAN, ESQUIRE hereby states that he is attorney for
Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the court and/or the
verification could not be obtained within the time allowed for the filing of the pleading,
that he is authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that
the statements made in the foregoing Civil Action in Mortgage Foreclosure are based
upon information supplied by Plaintiff and are true and correct to the best of its
knowledge, information and belief. Furthermore, counsel intends to substitute a
verification from Plaintiff upon receipt.
The undersigned understands that this statement is made subject to the penalties
of 18 Pa.C.S. Sec. 4904 relating to unsworn falsifications to authorities.
Francis S. Hallinan, Esquire
Attorney for Plaintiff
DATE: , I
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SHERIFF'S RETURN - REGULAR
'''CASE NO: 2007-04881 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
STAMBAUGH RICHARD A ET AL
RICHARD SMITH
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
STAMBAUGH RICHARD A the
DEFENDANT at 1027:00 HOURS, on the 22nd day of August 2007
at 141 EAST MAIN STREET
WALNUT BOTTOM, PA 17266
KRISTINA STAMBAUGH, WIFE
by handing to
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
Sworn and Subscibed to
before me this
of
So Answers:
18.0 0 !%51-~'~~ ~'~%~
12.48
.00
10.00 R. Thomas Kline
.00
40.48 08/23/2007
PHELAN HALLINAN SC EG
By:
day De uty Sheriff
A.D.
SHERIFF'S RETURN - REGULAR
`CASE NO: 2007-04881 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
STAMBAUGH RICHARD A ET AL
RICHARD SMITH
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
STAMBAUGH KRISTINA M
was served upon
the
DEFENDANT at 1027:00 HOURS, on the 22nd day of August 2007
at 141 EAST MAIN STREET
WALNUT BOTTOM, PA 17266
VT]T G+T TTTT C~TTMT]TTTP!V
by handing to
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
Sworn and Subscibed to
before me this
So Answers:
6.00 ~~
.00
10.00 R. Thomas Kline
.00
16.00 08/23/2007
PHELAN HALLINAN MI
day eputy Sheriff
of A.D.
., PHELAN HALLINAN &SCHMIEG, L.L.P.
By: DANIEL G. SCHMIEG
Identification No. 62205
Attorney for Plaintiff
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPHIA, PA 19103-1814
X215) 563-7000
DEUTSCHE BANK NATIONAL TRUST
COMPANY AS TRUSTEE UNDER THE POOLING
AND SERVICING AGREEMENT DATED AS OF
SEPTEMBER 1, 2005, GSAMP TRUST 2005-
WMC1
4828 LOOP CENTRAL DRIVE
HOUSTON, TX 77081-2226
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 07-4881 CIVIL TERM
Plaintiff,
v.
RICHARD A. STAMBAUGH ,
141 EAST MAIN STREET ,
WALNUT BOTTOM, PA 17266 .
KRISTINA M. STAMBAUGH
141 EAST MAIN STREET
WALNUT BOTTOM, PA 17266
Defendant(s).
PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter an in rem judgment in favor of the Plaintiff and against RICHARD A.
STAMBAUGH and KRISTINA M. STAMBAUGH, Defendant(s) for failure to file an Answer to
Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged
premises, and assess Plaintiffs damages as follows:
As set forth in Complaint
Interest from 08/17/07 to 09/25/07
TOTAL
$109,736.58
$784.40
$110,520.98
I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and
(2) that notice has been given in accordance with Rule 237.1, copy attached.
1 SC~J ,
ANIEL G. SCHMIEG, ES IRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED.
DATE: io oa o~ / ~ ~. ,~
P O PROTHY
159750
t PHELAN HALLINAN & SCHMIEG, LLP
By: Lawrence T. Phelan, Esq., Id. No. 32227 ATTORNEY FOR PLAINTIFF
Francis S. Hallinan, Esq., Id. No. 62695
Daniel G. Schmieg, Esq., Id. No. 62205
Philadelphia, PA 19103
(215) 563-7000
DEUTSCHE BANK NATIONAL TRUST COMPANY :COURT OF COMMON PLEAS
AS TRUSTEE UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS OF :CIVIL DIVISION
SEPTEMBER 1, 2005, GSAMP TRUST 2005-WMC1
Plaintiff :CUMBERLAND COUNTY
Vs.
RICHARD A. STAMBAUGH
KRISTINA M. STAMBAUGH
Defendants
TO: KRISTINA M. STAMBAUGH
141 EAST MAIN STREET
WALNUT BOTTOM, PA 17266
DATE OF NOTICE: SEPTEMBER 12, 2007
NO. 07-4881-CIVIL TERM
.~..
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO
YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY
INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE
PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND
SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS
ENFORCEMENT OF LIEN AGAINST PROPERTY.
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE
DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,
GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH
INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A
REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(800)990-9108
.(~-- ---~ S • ..,
F NCIS S. HALLINAN, ESQUIRE
Attorneys for Plaintiff
M PHELAN HALLINAN & SCHMIEG, LLP
By: Lawrence T. Phelan, Esq., Id. No. 32227 ATTORNEY FOR PLAINTIFF
Francis S. Hallinan, Esq., Id. No. 62695
Daniel G. Schmieg, Esq., Id. No. 62205
Philadelphia, PA 19103
X215) 563-7000
DEUTSCHE BANK NATIONAL TRUST COMPANY :COURT OF COMMON PLEAS
AS TRUSTEE UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS OF :CIVIL DIVISION
SEPTEMBER 1, 2005, GSAMP TRUST 2005-WMC1
Plaintiff :CUMBERLAND COUNTY
Vs.
RICHARD A. STAMBAUGH
KRISTINA M. STAMBAUGH
Defendants
TO: RICHARD A. STAMBAUGH
141 EAST MAIN STREET
WALNUT BOTTOM, PA 17266
DATE OF NOTICE: SEPTEMBER 12, 2007
NO. 07-4881-CIVIL TERM
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THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO
YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY
INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE
PREVIOUSLY RECETVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND
SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS
ENFORCEMENT OF LIEN AGAINST PROPERTY.
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE
DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,
GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH
INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A
REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(800)990-9108
F NCIS S. HALL AN, ESQUIRE
Attorneys for Plaintiff
PHELAN HALLINAN &SCHMIEG, L.L.P.
By: DANIEL G. SCHMIEG
Identification No. 62205
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
DEUTSCHE BANK NATIONAL TRUST
COMPANY AS TRUSTEE UNDER THE POOLING
AND SERVICING AGREEMENT DATED AS OF
SEPTEMBER 1, 2005, GSAMP TRUST 2005-
WMC1
4828 LOOP CENTRAL DRIVE
Plaintiff,
v.
RICHARD A. STAMBAUGH
KRISTINA M. STAMBAUGH
Defendant(s).
ATTORNEY FOR PLAINTIFF
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
. CIVIL DIVISION
N0.07-4881 CIVIL TERM
VERIFICATION OF NON-MILITARY SERVICE
DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in
the above-captioned matter, and that on information and belief, he has knowledge of the following facts,
to wit:
(a) that the defendant(s) is/are not in the Military or Naval Service of the United States
or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress
of 1940, as amended.
(b) that defendant RICHARD A. STAMBAUGH is over 18 years of age and resides at
141 EAST MAIN STREET, WALNUT BOTTOM, PA 17266 .
(c) that defendant KRISTINA M. STAMBAUGH is over 18 years of age, and resides at
141 EAST MAIN STREET, WALNUT BOTTOM, PA 17266.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
I
DANIEL G. SCHMIEG, ESQUIRE
Attorney for Plaintiff
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(Rule of Civil Procedure No. 236) -Revised
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
DEUTSCHE BANK NATIONAL TRUST
COMPANY AS TRUSTEE UNDER THE POOLING CUMBERLAND COUNTY
AND SERVICING AGREEMENT DATED AS OF COURT OF COMMON PLEAS
SEPTEMBER 1, 2005, GSAMP TRUST 2005-
WMC1 CIVIL DIVISION
4828 LOOP CENTRAL DRIVE
NO. 07-4881 CIVIL TERM
Plaintiff,
v.
RICHARD A. STAMBAUGH
KRISTINA M. STAMBAUGH
Defendant(s).
Notice is given that a Judgment in the above-captioned matter has been entered against you on
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By' AlC~i
If you have any questions concerning this matter, please contact:
i
DANIEL G. SCHMIEG, ESQU~'tE
Attorney for Plaintiff
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN
BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD
NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN
AGAINST PROPERTY.**
~ 1
4
PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P. 3180-3183
DEUTSCHE BANK NATIONAL TRUST
COMPANY AS TRUSTEE UNDER THE POOLING
AND SERVICING AGREEMENT DATED AS OF
SEPTEMBER 1, 2005, GSAMP TRUST 2005- No. 07-4881 CIVIL TERM
WMC1 .
Plaintiff, .
v.
RICHARD A. STAMBAUGH
KRISTINA M. STAMBAUGH
Defendant(s).
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due $110,520.98
Interest from 09126/07 to MARCH 5, 2008 $2,943.54 and Costs
(per diem -$18.17)
Add'1 Costs $2 106.50
TOTAL $115,571.02
~~ /I . o ~ ,
I3AT~IIEL G. SCHMIEG, ESQUIRE
One Penn Center at Suburban Station
1617 John F. Kennedy Boulevard, Suite 1400
Philadelphia, PA 19103-1814
Attorney for Plaintiff
Note: Please attach description of property.No.
IMPORTANT NOTICE: This property is sold at the direction of the
plaintiff. It_ may not be sold in the absence of a representative of
the plaintiff at the Sheriff`s Sale. The sale must be postponed or
stayed in the event that a representative of the plaintiff is not
present at the sale.
159750
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LEGAL DESCRIPTION
ALL the following described real estate lying and being situate in the Village of Walnut Bottom,
South Newton Township, Cumberland County, Pennsylvania, more particularly described as
follows:
BEGINNING at a set railroad spike in the centerline of PA Traffic Route 174 (Walnut Bottom
Road) at common corner of Lots 1 and 2 on the herein referred to subdivision plan; thence along
common boundary line of Lots 1 and 2, which is also the easterly most boundary of Parcel lA,
South thirty-seven (37) degrees twenty-four (24) minutes fifty-five (55) seconds East, ninety-six
and fifty-seven hundredths (96.57) feet to a set iron pin; thence continuing by same, South forty-
five (45) degrees forty-nine (49) minutes twenty-five (25) seconds East, one hundred eighteen and
thirty hundredths (118.30) feet to a set iron pin in line of land now or formerly of Ronald A.
Baker; thence along line of land now or formerly of Ronald A. Baker, South forty-nine (49)
degrees zero (00) minutes zero (00) seconds West, thirty-nine and thirty-two hundredths (39.32)
feet to a point; thence continuing by the same, South forty-nine (49) degrees zero (00) minutes zero
(00) seconds West, fifty and zero hundredths (50.00) feet to a point at corner of land now or
formerly of Randy K. Boyer; thence along line of land now or formerly of Randy K. Boyer, North
forty-three (43) degrees fifteen (15) minutes two (02) seconds West, two hundred thirteen and
thirty-seven hundredths (213.37) feet to a point in the centerline of Walnut Bottom Road; thence
along the centerline of Walnut Bottom Road, North forty-six (46) degrees fifty-seven (57) minutes
thirty-one (31) seconds East, fifty and zero hundredths (50.00) feet to a point; thence continuing
by same, North forty-nine (49) degrees fifty-seven (57) minutes zero (00) seconds East, forty-three
and eighty-three hundredths (43.83) feet to the set railroad spike, the point and place of
BEGINNING.
CONTAINING a total area of 18,793 square feet (0.431 acres).
BEING known and designated as Lot No. 1 on a subdivision plan entitled 'Survey for Mary O.
Bowers' prepared by Steven P. Wolfe, Professional Land Surveyor, dated 4/11/90, which
subdivision plan has been approved by the appropriate municipal authorities as and for a
subdivision plan and is recorded in the office of the Recorder of Deeds in and for Cumberland
County, Pennsylvania in Plan Book 69, Page 36.
BEING the same premises which Bonnie Swartz and Harold Bowers, Sr., co-Executors of the Last
Will and 'Testament of Mary O. Bowers, by their deed dated May 10,1995, and recorded in
Cumberland County, Pennsylvania Deed Book 122, Page 408, granted and conveyed unto Randy
V. Singleton, a single man, Grantor herein.
TITLE TO SAID PREMISES IS VESTED IN Richard A. Stambaugh and Kristina M.
Stambaugh, husband and wife, by Deed from Randy V. Singleton, dated 06/30/2005, recorded
07/Ob/2045, in Deed Book 2b9, page 3862.
' PHELAN HALLINAN &SCHMIEG, L.L.P.
By: DANIEL G. SCHMIEG
Identification No. 62205
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
DEUTSCHE BANK NATIONAL TRUST
COMPANY AS TRUSTEE UNDER THE POOLING
AND SERVICING AGREEMENT DATED AS OF
SEPTEMBER 1, 2005, GSAMP TRUST 2005-
WMC1
Plaintiff,
v.
RICHARD A. STAMBAUGH
KRISTINA M. STAMBAUGH
Defendant(s).
ATTORNEY FOR PLAINTIFF
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 07-4881 CIVIL TERM
CERTIFICATION
DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in
the above-captioned matter, and that the premises are not subject to the provisions of Act 91
because it is:
() an FHA mortgage
() non-owner occupied
() vacant
(X) Act 91 procedures have been fulfilled
This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
IEL G. SCHMIEG, ESQUI
Attorney for Plaintiff
C7
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DEUTSCHE BANK NATIONAL TRUST
COMPANY AS TRUSTEE UNDER THE POOLING
AND SERVICING AGREEMENT DATED AS OF
SEPTEMBER 1, 2005, GSAMP TRUST 2005-
WMC1
Plaintiff,
v.
RICHARD A. STAMBAUGH
KRISTINA M. STAMBAUGH
Defendant(s).
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
N0.07-4881 CIVIL TERM
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. l)
DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE UNDER THE POOLING
AND SERVICING AGREEMENT .DATED AS OF SEPTEMBER 1.2005, GSAMP TRUST 2005-
WMC1, Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as
of the date the Praecipe for the Writ of Execution was filed the following information concerning the
real property located at ,141 EAST MAIN STREET, WALNUT BOTTOM, PA 17266 .
1. Name and address of Owner(s) or reputed Owner(s):
Name
RICHARD A. STAMBAUGH
KRISTINA M. STAMBAUGH
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
141 EAST MAIN STREET
WALNUT BOTTOM, PA 17266
141 EAST MAIN STREET
WALNUT BOTTOM, PA 17266
2. Name and address of Defendant(s) in the judgment:
Same as above
3. Name and last known address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
Name Last Known Address (if address cannot be
reasonably ascertained, please indicate)
UNEMPLOYMENT COMPENSATION FUND 16TH FLOOR, L&I BUILDING
HARRISBURG, PA 17121
4. Name and address of last recorded holder of every mortgage of record:
Name Last Known Address (if address cannot be
reasonably ascertained, please indicate)
MERS AS A NOMINEE FOR WMC MORTGAGE CORP. P.O. BOX 54089
LOS ANGELES, 90054-0089
MERS AS A NOMINEE FOR WMC MORTGAGE CORP. P.O. BOX 2206
FLINT, MI 48501-2026
5. Name and address of every other person who has any record lien on the property:
Name Last Known Address (if address cannot be
reasonably ascertained, please indicate)
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
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in
the property which may be affected by the sale:
Name
TenantlOccupant
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
141 EAST MAIN STREET
WALNUT BOTTOM, PA 17266
Domestic Relations of Cumberland County
Commonwealth of Pennsylvania
Department of Welfare
13 North Hanover Street
Carlisle, PA 17013
PO Box 2675
Harrisburg, PA 17105
Commonwealth of Pennsylvania 6'" Floor, Strawberry Sq., Dept 28061
Bureau of Individual Tax, Inheritance Tax Division Harrisburg, PA 17128
Internal Revenue Service
Federated Investors Tower
13TH Floor, Suite 1300
1001 Liberty Avenue,
Pittsburgh, PA 15222
Department of Public, Welfare TPL Casualty Unit, P.O. Box 8486
Estate Recovery Program Willow Oak Building
Harrisburg, PA 17105
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.
~/~ .
September 28, 2007 L//
DATE DANIEL G. SCHMIEG, E UIRE
Attorney for Plaintiff
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DEUTSCHE BANK NATIONAL TRUST
COMPANY AS TRUSTEE UNDER THE POOLING
AND SERVICING AGREEMENT DATED AS OF
SEPTEMBER 1, 2005, GSAMP TRUST 2005- 4
WMC1
Plaintiff,
v.
RICHARD A. STAMBAUGH
KRISTINA M. STAMBAUGH
Defendant(s).
CUMBERLAND COUNTY
No. 07-4881 CIVIL TERM ~
September 25, 2007
TO: RICHARD A. STAMBAUGH
141 EAST MAIN STREET
WALNUT BOTTOM, PA 17266
KRISTINA M. STAMBAUGH
141 EAST MAIN STREET
WALNUT BOTTOM, PA 17266
* *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN
BANKRUPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE
AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.
Your house (real estate) at ,141 EAST MAIN STREET, WALNUT BOTTOM, PA 17266, is
scheduled to be sold at the Sheriffs Sale on MARCH 5, 2008'at 10:00 a.m. in the Cumberland County
Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $110,520.98
obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE UNDER THE
POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 2005, GSAMP
TRUST 2005-WMC1 (the mortgagee) against you. In the event the sale is continued, an announcement
will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3.
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 the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may
call: (215) 563-7000.
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.
4. You may need an attorney to assert your rights. The sooner you contact one, the more
chance you will have of stopping the sale. (See notice on page two on how to obtain an
attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may
find out the price bid by calling (215) 563-7000.
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 (717) 240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have 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 of 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 the distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold
in the absence of a representative of the plaintiff at the Sheriff s Sale. The sale must be
postponed or stayed in the event that a representative of the plaintiff is not present at the sale.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
LEGAL DESCRIPTION
ALL the following described real estate lying and being situate in the Village of Walnut Bottom,
South Newton Township, Cumberland County, Pennsylvania, more particularly described as
follows:
BEGINNING at a set railroad spike in the centerline of PA Traffic Route 174 (Walnut Bottom
Road) at common corner of Lots 1 and 2 on the herein referred to subdivision plan; thence along
common boundary line of Lots 1 and 2, which is also the easterly most boundary of Parcel lA,
South thirty-seven (37) degrees twenty-four (24) minutes fifty-five (55) seconds East, ninety-six
and fifty-seven hundredths (96.57) feet to a set iron pin; thence continuing by same, South forty-
five (45) degrees forty-nine (49) minutes twenty-five (25) seconds East, one hundred eighteen and
thirty hundredths (118.30) feet to a set iron pin in line of land now or formerly of Ronald A.
Baker; thence along line of land now or formerly of Ronald A. Baker, South forty-nine (49)
degrees zero (00) minutes zero (00) seconds West, thirty-nine and thirty-two hundredths (39.32)
feet to a point; thence continuing by the same, South forty-nine (49) degrees zero (00) minutes zero
(00) seconds West, fifty and zero hundredths (50.00) feet to a point at corner of land now or
formerly of Randy K. Boyer; thence along line of land now or formerly of Randy K. Boyer, North
forty-three (43) degrees fifteen (15) minutes two (02) seconds West, two hundred thirteen and
thirty-seven hundredths (213.37) feet to a point in the centerline of Walnut Bottom Road; thence
along the centerline of Walnut Bottom Road, North forty-six (46) degrees fifty-seven (57) minutes
thirty-one (31) seconds East, fifty and zero hundredths (50.00) feet to a point; thence continuing
by same, North forty-nine (49) degrees fifty-seven (57) minutes zero (00) seconds East, forty-three
and eighty-three hundredths (43.83) feet to the set railroad spike, the point and place of
BEGINNING.
CONTAINING a total area of 18,793 square feet (0.431 acres).
BEING known and designated as Lot No. 1 on a subdivision plan entitled'Survey for Mary O.
Bowers' prepared by Steven P. Wolfe, Professional Land Surveyor, dated 4/11/90, which
subdivision plan has been approved by the appropriate municipal authorities as and for a
subdivision plan and is recorded in the office of the Recorder of Deeds in and for Cumberland
County, Pennsylvania in Plan Book 69, Page 36.
BEING the same premises which Bonnie Swartz and Harold Bowers, Sr., co-Executors of the Last
Will and Testament of Mary O. Bowers, by their deed dated May 10,1995, and recorded in
Cumberland County, Pennsylvania Deed Book 122, Page 408, granted and conveyed unto Randy
V. Singleton, a single man, Grantor herein.
TITLE TO SAID PREMISES IS VESTED IN Richard A. Stambaugh and Kristina M.
Stambaugh, husband and wife, by Deed from Randy V. Singleton, dated 06/30/2005, recorded
07/06/2005, in Deed Book 269, page 3862.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-4881 Civil
CIVIL ACTION -LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY as
Trustee under the Pooling and Servicing Agreement Dated As of 9/01/05, GSAMP TRUST 2005-
WMCl, Plaintiff (s)
From RICHARD A. STAMBAUGH & KRISTINA M. STAMBAUGH
(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 $110,520.98
L.L. $.50
Interest from 9/26/07 to 3/05/08 (per diem - $18.17) -- $2,943.54 and Costs
Atty's Comm
Atty Paid $175.48
Plaintiff Paid
Date: 10-02-07
(Seal)
Due Prothy $2.00
Other Costs $2,106.50
Is~ Ct,u.~.a ~.
-tis R. Long, Prothonot (~
BY~ ~~ILL ll
Deputy
REQUESTING PARTY:
Name DANIEL G. SCHMIEG, ESQUIRE
Address: PHELAN HALLINAN &SCHMIEG, LLP
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F KENNEDY BLVD, SUITE 1400
PHILADELPHIA, PA 19103-1814
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court ID No. 62205
10/09/2007 14:22 FRX
Law Offices
PHELAN HALLINAN & SCHMIEG, LLP
One Penn Center at Suburban Station
1617 John F. Kennedy Boulevard
Suite 1400
Philadelphia, PA 19103-18x4
Christine.Scho Efle~feslnh e•CO.m_
C~uistine Schoffler
Judgment Department, Ext. 1286
October 9, 2007
Office of the Sheriff
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
ATTENTION: JODY
Representing Lenders in
Pennsylvania and New Jersey
FAX: 717-240-6397
lte: DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE
UNDER THE POOLING AND SERVrCING AGREEMENT DATED
AS OF SEPTEMBER 1, 2005, GSAMP TRUST 2005-WMC1
v. RICHARD A. STAMBAUGH AND KRISTINA M. STAMBAUGH
Premises: 141 EAST MAIN STREET, WALNUT BOTTOM, PA 17266
Dear Jody:
Please STAY the Sheriffs Sale of the above referenced property, which is scheduled
for MARCH 5, 2008.
The sum of $6216.10 was received in consideration for the stay.
Very truly yours,
CQS
Christine Schoffler
For Phelan Hallman & Schfftieg, LLP
~wi/vvi
eturned to the Prothonotary on 11/01/07
deposit returned to Attorney
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-4881 Civil
CIVIL ACTION -LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY as
Trustee under the Pooling and Servicing Agreement Dated As of 9/01/05, GSAMP TRUST 2005-
WMC1, Plaintiff (s)
From RICHARD A. STAMBAUGH & KRISTINA M. STAMBAUGH
(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 $110,520.98
L.L. $.50
Interest from 9/26/07 to 3/05/08 (per diem - $18.17) -- $2,943.54 and Costs
Atty's Comm
Atty Paid $175.48
Plaintiff Paid
Date: 10-02-07
(Seal)
Due Prothy $2.00
Other Costs $2,106.50
C~.~t.S.
C is R. Long, Prothono
By:
Deputy
REQUESTING PARTY:
Name DANIEL G. SCHMIEG, ESQUIRE
Address: PHELAN HALLINAN & SCHMIEG, LLP
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F KENNEDY BLVD, SUITE 1400
PHILADELPHIA, PA 19103-1814
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court ID No. 62205