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HomeMy WebLinkAbout07-6674IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION - LAW DEUTSCHE BANK NATIONAL CIVIL Division TRUST COMPANY AS TRUSTEE Case Number: b 7- G G 7 y ?,urif '7"._ PLAINTIFF VS JUSTIN D. CRIDER DEFENDANT CERTIFICATE OF LOCATION 1825 HUNTER DRIVE MECHANICSBURG, PA 17050 TOWNSHIP OF HAMPDEN PARCEL No: 10-14-0844-010 Type of Pleading Complaint in Mortgage Foreclosure Code and Classification: Filed on Behalf Of: Plaintiff Counsel of Record: Daniel J. Mancini, Esquire Attorney at Law 201 A Fairview Drive Monaca, PA 15061 (724) 72 4233 By: DANIEL J. MANCINI, ESQ. PA I.D. No. 39353 Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724)728-4233 mancini lawfirm(2.comcast.net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE PLAINTIFF VS JUSTIN D. CRIDER DEFENDANT CIVIL ACTION - LAW CASE NO MORTGAGE FORECLOSURE CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE 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. 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. Lawyer Referral Services, 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724)728-4233 manc ini l awfirm@comcast. net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE PLAINTIFF VS CIVIL ACTION - LAW CASE NO MORTGAGE FORECLOSURE JUSTIN D. CRIDER DEFENDANT 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 UNTI THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UKTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSUL N ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN T SUIT. Daniel J. Mancini, Esq. Daniel Mancini & Associates Daniel J. Mancini. Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca. PA 15061 (724)728-4233 manc i n i l awfi rmn co mcast. n et IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE PLAINTIFF VS CIVIL ACTION - LAW ?? CASE NO G Y- 4 L 7 Y 4- 4, ( 7;,.,•- MORTGAGE FORECLOSURE JUSTIN D. CRIDER DEFENDANT COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is: DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, whose address is c/o Mancini & Associates, 201 A Fairview Drive, Monaca, PA 15061. 2. Defendant JUSTIN D. CRIDER, whose last known address is 1825 HUNTER DRIVE, MECHANICSBURG, PA 17050. JUSTIN D. CRIDER is the mortgagor and the recorded owner of the mortgaged property hereinafter described. 3. On or about, SEPTEMBER 28, 2006, JUSTIN D. CRIDER borrowed $ 345,000.00 and in the enforcement of said debt executed and delivered a mortgage upon the premises hereinafter described to the lender MERS AS NOMINEE FOR INDYMAC BANK F.S.B. this mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County in Mortgage Record Book 1969, Page 585. This mortgage is incorporated herein by reference in accordance with Pa. R.C.P. 1019 (g).Your plaintiff, DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUTSEE is now the current owner of said mortgage, and the assignment evidencing this ownership will be sent for recording at a later date. 4. The land subject to the Mortgage is 1825 HUNTER DRIVE, MECHANICSBURG, PA 17050, and is more particularly described in Exhibit "A", which is attached hereof and part of this Complaint. 5. The Mortgage is in default because monthly payments of principal and interest upon said mortgage due JANUARY 1, 2007, and each month thereafter are due and unpaid, and by the terms of said Mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. Unpaid Principal Balance $ 344,630.87 Delinquent Balance, including Interest at $87.34 per diem $ 28,748.75 From 12/01/06 to 10/31/07 (based on contract rate of 9.25 %) Rec. Corp. Adv. $ 000.00 Escrow Advance $ 000.00 Accrued Late Charges $ 1,419.10 Bad CK Fees $ 00.00 Attorney's Fee Total $ 17.231.54 $ 392,030.26 * * Together with interest at the per diem rate noted above after JANUARY 1, 2007 and other charges and costs to date of Sheriff's Sale. The Attorney's Fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable, or that are actually incurred by Plaintiff. 6. No judgment has been entered upon said Mortgage in any jurisdiction. 7. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 or 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant on SEPTEMBER 25, 2007, via certified and regular mail, in accordance with the requirements of those acts. 8. Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. 9. The Defendant has either failed to meet the time limitations as set forth under the Combined Act 6/91 Notice or have been determined by the Pennsylvania Housing Finance Agency not to qualify for Mortgage Assistance. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure `IN REM' for the aforementioned total amount due together with interest at th rate of 9.25 % ($87.34 per diem), together with other charges and costs inc ling escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and s e of the property within described. Daniel J. Mancini, Esq. Attorney Bar: PA 39353 . Stewart Title Guaranty Company Commitment Number: 200608002ODSS SCHEDULE C PROPERTY DESCRIPTION The land referred to in this Commitment is described as follows: ALL THAT CERTAIN tract of land situate in Hampden Twp Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the middle of a Township Road known as Hunter Drive (T-600), which point is 1060 feet, more or less, West of the center line of LR21051, thence in a straight line South 6 degrees 30 minutes East, a distance of 325 feet to a point thence in a straight fine South 83 degrees 30 minutes West, a distance of 200 feet to a point; thence in a straight line North 6 degrees 30 minutes West, a distance of 325 feet to a point thence in a straight line North 831degrees 30 minutes East, a distance of 200 feet to a point at the center line of Hunter Drive, the place of BEGINNING. RESERVING and excepting on behalf of Allen W. Bittner and Evelyn I. Bittner, his wife, for themselves, their heirs, successors and assigns, om', the above-mentioned description a right of way over the northern 30 feet thereof, said 30 feet being measured perpendicularly to the said course of North 6 degrees 30 minutes West, said reservation being for the pu popes of ingress, egress and regress, same to exist in perpetuo; said right of way, as well as the description o the tract conveyed herein being shown on plan drawn by William B. Whitlock, Professional Engineer, and date November 12, 1970. It is the intention of the parties hereto that the Grantee shall have no obligation and liability to construct, improve, maintain and repair any street or road constructed in and upon the right of way herein reserved; and further the center line of any such street shall be a continuation of center line, bearing the tours of;South 83 degrees, 30 minutes West as it presently exists in said Hunter Drive. CONTAINING approximately 1 ALTA COMMKMOM Schedule C acres and having erected a one story dwelling. (2006080020DSS. PFD/2006080020OS St25) 8K 1969PGO55 9 Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724)728-4233 mancini lawfirmlacomcast. net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE PLAINTIFF VS JUSTIN D. CRIDER DEFENDANT CIVIL ACTION - LAW CASE NO MORTGAGE FORECLOSURE VERIFICATION Daniel J. Mancini, Esq., hereby states that he is the attorney for Plaintiff in this matter, that He is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Further, counsel submits that Plaintiff is outside the court's jurisdiction and verification cannot be obtained with the time allowed for filing the pleading. It is counsel's intention to substitute a verification from Plaintiff. Dated this 31St Day of October 2007 Daniel J. Mancini, Esq. Attorney Bar: Pa 39353 lk- kA -.1 7 - ? M t C-11 r ? - v =c 5 91 SHERIFF'S RETURN - NOT SERVED CASE NO: 2007-06674 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TR CO VS CRIDER JUSTIN D R. Thomas Kline , Sheriff , who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT to wit: CRIDER JUSTIN D but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE CRIDER JUSTIN D the within named DEFENDANT 1825 HUNTER DRIVE NOT SERVED , as to MECHANICSBURG, PA 17050 SERVICE STOPPED PER FAX FROM ATTORNEY Sheriff's Costs: So answer-e- Docketing 18.00 Service 9.60 Affidavit .00 Z R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 \? 37.60 MANCINI & ASSOCIATES `J-zz? '- 12j04/2007 Sworn and Subscribed to befo re me this day of , A. D. SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-06674 P Amended COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TR CO VS CRIDER JUSTIN D R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT CRIDER JUSTIN D but was unable to locate Him in his bailiwick ('nT,AT')T T TTTT C_ TTnrr Tt LV He therefore returns the the within named DEFENDANT 1825 HUNTER DRIVE MECHANICSBURG, PA 17050 GIVEN ADDRESS IS VACANT. Sheriff's Costs: Docketing Service Affidavit Surcharge is/?/off 18.00 9.60 .00 10.00 00 37.60 ( CRIDER JUSTIN D NOT FOUND , as to So answers : --:-' R. Thomas Kline Sheriff of Cumberland County MANCINI & ASSOCIATES 12/18/2007 Sworn and Subscribed to before me this day of A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION - LAW DEUTSCHE BANK NATIONAL CIVIL Division TRUST COMPANY AS TRUSTEE Case Number: 07.6674 Civil Term PLAINTIFF VS Type of Pleading Motion for Special Service in Mortgage Foreclosure JUSTIN D. CRIDER DEFENDANT CERTIFICATE OF LOCATION Code and Classification: Filed on Behalf Of: Plaintiff 1825 HUNTER DRIVE MECHANICSBURG, PA 17050 TOWNSHIP OF MIDDLE HAMPDEN PARCEL No: 10-14-0844-010 Counsel of Record: Daniel J. Mancini, Esquire Attorney at Law 201 A Fairview Drive Monaca, PA 15061 (724) 728 ? By: DANIEL J. MANCINI, ESQ. PA I.D. No. 39353 Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 mancinilawfirm(&-comcast. net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE PLAINTIFF VS CIVIL ACTION - LAW CASE NO: 07-6674 CIVIL TERM MORTGAGE FORECLOSURE JUSTIN D. CRIDER DEFENDANT MOTION FOR SPECIAL SERVICE ORDER PURSUANT TO PA.R.C.P. 410 & 430 AND NOW, comes Plaintiff, by and through its attorney, Daniel J. Mancini, and respectfully moves this Court pursuant to Pa.R.C.P. 410 & 430 for a Special Service Order, and in support thereof states the following: 1. Defendant, Justin D. Crider is the record owner of a property located at 1825 Hunter Drive, Mechanicsburg, PA 17050. Your Plaintiff has filed a Mortgage Foreclosure Action in the Court of Common Pleas, Cumberland County, Pennsylvania on November 2, 2007. 2. Personal Service of the Complaint was attempted on the Defendant, Justin D. Crider, by the Cumberland County Sheriffs Department. The Sheriffs Return, which is made part of this Motion, indicates that Service was attempted but not made due to the property being vacant. 3. I, Daniel J. Mancini, Esq., have conducted an investigation to determine the whereabouts of said Defendant as set forth in the attached Affidavit, which is incorporated herein, and the last known address that could be found for said Defendant is as follows: 1825 Hunter Drive, Mechanicsburg, PA 17050. WHEREFORE, Plaintiffs Attorney respectfully requests the Court to enter a Special Service Order directing service of Complaint of Mortgage Foreclosure upon Defendant Justin D. Crider as follows: Posting a copy of said Complaint upon the premises at 1825 Hunter Drive, Mechanicsburg, PA 17050. Mailing a copy of said Complaint by both Certified Mail, return receipt requested, and ordinary first class mail to said Defendant at 1825 Hunter Drive, Mechanicsburg, PA 17050, as provided by Rule 430. And any such other method, if any, as the court deems appropriate to give notice to the defendant. Daniel J. Mancini, Esquire Attomey for Plaintiff VERIFICATION I verify that the statements made in the foregoing Motion for Special Service Order are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. DANIEL J. MANCINI AND ASSOCIATES Date: January 4, 2008 By: 0, Daniel J. Mancini, Esquire Pittsburgh Bar # 39353 Attomey for Plaintiff 201 A Fairview Drive Monaca, PA 15061 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION - LAW DEUTSCHE BANK NATIONAL CIVIL Division TRUST COMPANY AS TRUSTEE Case Number: 07.6674 Civil Term PLAINTIFF VS JUSTIN D. CRIDER DEFENDANT CERTIFICATE OF LOCATION Type of Pleading Affidavit of Investigation in Support of Motion for Special Service in Mortgage Foreclosure Code and Classification: Filed on Behalf Of: Plaintiff 1825 HUNTER DRIVE MECHANICSBURG, PA 17050 TOWNSHIP OF MIDDLE HAMPDEN PARCEL No: 10-14-0844-010 Counsel of Record: Daniel J. Mancini, Esquire Attorney at Law 201 A Fairview Drive Monaca, PA 15061 2f? (724)7 ti By: DANIEL J. MANCINI, ESQ. PA I.D. No. 39353 Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 mancinilawfirmAcomcast.net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE PLAINTIFF VS CIVIL ACTION - LAW CASE NO: 07-6674 CIVIL TERM MORTGAGE FORECLOSURE JUSTIN D. CRIDER DEFENDANT GOOD FAITH INVESTIGATION AFFIDAVIT PURSUANT TO PA.R.C.P. 430 I, Daniel J. Mancini, Esq., attorney for Plaintiff, hereby deposes and states as follows: I have conducted an investigation to determine the whereabouts of Defendant Justin D. Crider by making inquiries of or examining the following sources and learned the following respective information regarding said Defendant's last known address: 1. Exhibit A: Cumberland County Sheriff Return of Service: The Deputy, on his Return, states that an attempt was made to serve the defendant with the complaint in mortgage foreclosure. The Deputy states the address is vacant. 2. Exhibit B: Request for Change of Address or Boxholder Information. On his return of said document, the Postmaster of Mechanicsburg Post Office, Mechanicsburg, PA 17055, verifies that the address is good, mail delivered. 3. Exhibit C: National Comprehensive Report of Debtor Discovery: This is a privacy secured database investigation of various databases of governmental agencies such as Department of Motor Vehicles, Social Security Administration, Bankruptcy and other Federal Courts, County Courts and Row Offices of Pennsylvania, and Voter Registration Rolls. It also provides a report based upon three separate National Credit Reporting Agencies. The data found through this search as of August 28, 2007, has identified the most current known address of Justin D. Crider as being: 1825 Hunter Drive, Mechanicsburg, PA 17050 In light of the investigation as set forth in this affidavit, Plaintiff believes that the Defendant is avoiding Service of the Complaint for Mortgage Foreclosure. I, Daniel J. Mancini, Esq., verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information, or belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unworn falsification to authorities. DANIEL J. MANC ASSOCIATES Date: January 4, 2008 By: Daniel J. Mancini, Esquire Pennsylvania Bar # 39353 Attorney for Plaintiff SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-06674 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TR CO VS CRIDER JUSTIN D A Amended R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT CRIDER JUSTIN D but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE , the within named DEFENDANT , CRIDER JUSTIN D 1825 HUNTER DRIVE , NOT FOUND , as to MECHANICSBURG, PA 17050 GIVEN ADDRESS IS VACANT. Sheriff's Costs: So answers Docketing 18.00 r' Service 9.60 Affidavit .00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 37.60 MANCINI & ASSOCIATES 12/18/2007 Sworn and Subscribed to before me this day of , A. D. 6 Mancini & Associates 201A Fairview Drive Monaca, PA 15o6i Phone (724) 728-4233 Fax(724)728-4239 mancinilawfirm@comcast.net Daniel J. Mancini, Esq. *Licensed in PA and FL Postmaster Date December 4, 2007 Mechanicsburg Post Office 702 E Simpson ST Mechanicsburg, PA 17055-9998 Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or the name and street address (if a boxholder) for the following: Name: Justin Crider Address: 1825 Hunter Drive Mechanicsburg PA 17050 NOTE: The name and last known address are required for change of address information. The name, if known, and post office box are required for boxholder information. The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii). There is no fee. for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester (e.g., process server, attorney, party representing himself): ATTORNEY 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se - except a corporation acting pro se must cite statute): N/A 3. The names of all known parties to the litigation: DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE 4. The court in which the case has been or will be heard: COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA - CIVIL DIVISION 5. The docket or other identifying number if one has been issues: 07-6674-Civil Term 6. The capacity in which this individual is to be served (e.g. defendant or witness): DEFENDANT WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). I certify-t+mt.the above information is true and that the address information is needed and will be used solely for service of legal process in connection with actual or prospective litigation. „ems'' ----- 201 A Fairview Drive, Signature Address DANIEL J. MANCINI, ESQUIRE Monaca, PA 15061 Printed Name City, State, ZIP Code FOR POST OFFICE USE ONLY - No change of address order on file. Not known at address given. - Moved, left no forwarding address. No such address. NEW ADDRESS or BOXHOLDER'S POSTMARK NAME AND STREET ADDRESS '1 Wis. S i r Page 1 of 2 cover , 11t,.... , R ::u t:, t4a. aoer . 'T;avling ! Help I My Account Logged in: DANIEL 7. MANCINI [LEVEL 3] €_ !! Locator Profile Report 08128/2007 - 11:28AM - Reference: None Entered Reference: Pone Entered Printer-friendly format Save Report Subject JUSTIN D CRIDER SSN 185-68-XXXX issued in Pennsylvania between 1988 and 1989 DOB 09/XX/1971 User supplied information Last Name: CRIDER First Name: JUSTIN Middle Initial: D SSN: 185-68-XXXX Address 1: 47 FLEISHER RD MARYSVILLE, PA 17053 Sections Available in Report Click on links to see detail Subject 1 Record Possible AKAs for Subject Possible Addresses Associated with Subject Phone Listings for Subject's Addresses Neighbor Listings for Subject's Addresses 2. Records 2 Records 4 Records 12 Records 11possible AKAs f- or Subject (2 Records) Top Name SSN Date Of Birth CRIDER, JUSTON D 185-68-XXXX CRIDER, JUSTIN 185-68-XXXX 09/XX/1971 Passible Addresses Associated with Subject (2 Records) Top Date Range Address/Phone Source 11/2006 - 12/2006 1825 HUNTER DR Consumer Bureau 1 MECHANICSBURG, PA 17050 Consumer Bureau 3 957-2415 04/1998 - 07/2001 47 FLEISHER RD Composite Info MARYSVILLE, PA 17053 Consumer Bureau 1 (717) 957-2415 Consumer Bureau 3 Phone Listings for Subject's Addresses (4 Records) Top https://www.debtordiscovery.com/at/GetReports_XP.asp?File=5TGH6DDSB l .HTM&OR... 8/28/2007 Page 2 of 2 1825 HUNTER DR MECHANICSBURG, PA 17050 Name: CRIDER JUSTIN D Phone: (717),_6.95-..4675 47 FLEISHER RD MARYSVILLE, PA 17053 Name: CRIDER RICHARD D Name: CRIDER DONNA M Name: CRIDER LAUREN Phone: (717) 957-2415 Hi V Phone: (717) 957-2415 [1 V Phone: (717) 957-2415 19 V Neighbor Listings for Subject's Addresses (12 Records) Top 1825 HUNTER DR MECHANICSBURG, PA 17050 WEIGEL ERIC S 1827 HUNTER DR {717) 7.3.2-5.6...74. WEIGEL BARBARA A 1827 HUNTER DR L1 (717)_73275674 WEIGEL SCOTT H 1829 HUNTER DR = a a`2 (717) 731,-1.103 WEIGEL TRACY A 1829 HUNTER DR [ (717)731-1103 GRIMES GERRY E 1821 HUNTER DR [ (7,17)732-6575 SCHEIBELHUT DOROTHY B 1820 HUNTER DR ' (717) 73278836 47 FLEISHER RD MARYSVILLE, PA 17053 ZIMMERS ROBERT C 50 FLEISHER RD (71.7)..957-4075 ZIMMERS DIANE M 50 FLEISHER RD ' (717) 957-4075 ROBENOLT CARYN S 35 FLEISHER RD (717).957-0093 ROBENOLT WILLIAM G 35 FLEISHER RD (717) _957-0093 WHITEHEAD JOHN 1 60 FLEISHER RD r7i (717) 957-2606 ZIMMERS AMY D 60 FLEISHER RD V (717}_95772606 *** Report section(s) with no matches: Possible Other Social Security Numbers Associated with Subject, Possible Other Records and Names Associated with Social Security Numbers, Possible Driver Licenses, Possible High Risk Address, Possible Hunting and Fishing Licenses, Possible Relatives, Other People Who Have Used the Same Address of the Subject, Possible Licensed Drivers At Subject's Addresses * Option Control Number: NNNN-CCLOCATE* *BOBWPSS410/02 5937686* * * * END OF REPORT* * * https://www.debtordiscovery.com/at/GetReports_XP.asp?File=5TGH6DDSB l .HTM&OR... 8/28/2007 Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 mancinilawfirm i-komcast.net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE PLAINTIFF VS CIVIL ACTION - LAW CASE NO: 07-6674 CIVIL TERM MORTGAGE FORECLOSURE JUSTIN D. CRIDER DEFENDANT MEMORANDUM IN SUPPORT OF MOTION FOR SPECIAL SERVICE ORDER Pursuant to Pa.R.C.P. 410 & 430 for a Special Service Order, when attempts of Personal Service are unsuccessful, in this case, the Process Server's Return indicates the home appears to be vacant, Rule 410 provides that a Special Service Order can be directed by the Judge by one or more of the following methods: • Publication as per provided by Pa R Civ P Rule 410(c) (1). • Posting a copy of the original process on the most public part of the property by Pa R Civ P Rule 410(c) (2). • Registered mail to the defendant's last known address by Pa R Civ P Rule 410(c) (3). • Such other methods, if any, as the court deems appropriate to give notice to the defendant by Pa R Civ P Rule 410(c) (4). Service of process by special order is the exception and not the rule and can only be ordered provided the requirements stated in the Rules have been met. L-- Daniel J. Mancini, Esquire IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION - LAW DEUTSCHE BANK NATIONAL CIVIL Division TRUST COMPANY AS TRUSTEE Case Number: 07.6674 Civil Term PLAINTIFF VS Type of Pleading Affidavit of Service to Defendant Of Motion for Special Service JUSTIN D. CRIDER DEFENDANT CERTIFICATE OF LOCATION Code and Classification: Filed on Behalf Of: Plaintiff 1825 HUNTER DRIVE MECHANICSBURG, PA 17050 TOWNSHIP OF MIDDLE HAMPDEN PARCEL No: 10-14-0844-010 Counsel of Record: Daniel J. Mancini, Esquire Attorney at Law 201 A Fairview Drive Monaca, PA 15061 (724)728-42 By: DANIEL J. MANCINI, ESQ. PA I.D. No. 39353 Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 mancinilawfirm(&comcast.nei IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE PLAINTIFF VS JUSTIN D. CRIDER DEFENDANT CIVIL ACTION - LAW CASE NO: 07-6674 CIVIL TERM MORTGAGE FORECLOSURE AFFIDAVIT OF SERVICE I, DANIEL J. MANCINI, ESQUIRE, attorney for Plaintiff in the above captioned action, deposes and says that on January 4, 2008 he did by ordinary mail addressed to Justin D. Crider at 1825 Hunter Drive, Mechanicsburg, PA 17050, deliver true and correct copies of the Motion for Alternative Service. Dated: January 4, 2008 Daniel J. Mancini, Esquire t?3 ^,' cr ? ?, ? ?? ?. cw ?' ? ? - ? r i ?'?. r-, 3 _.?_ i "..? ?'? i ' 1 ? i ?? ` l := ? P y? JAN 112008 p? IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE PLAINTIFF VS JUSTIN D. CRIDER DEFENDANT CIVIL ACTION - LAW CASE NO: 07-6674 CIVIL TERM MORTGAGE FORECLOSURE ORDER FOR SERVICE AND NOW, to wit, this 1o Mday of , 2008 upon consideration of the within Motion for Special Service and its supporting A idavit of Investigation, it appearing that a Good Faith Investigation and effort to locate the Defendant has been made by Plaintiff, it is hereby ORDERED that service of the Complaint be made upon Defendant JUSTIN D. CRIDER in the following manner: THAT a copy of the Complaint be posted on the premises at 1825 Hunter Drive, Mechanicsburg, PA 17050. THAT a copy of the Complaint be also sent via Certified Return Receipt Mail and ordinary first class mail to said Defendant at 1825 Hunter Drive, Mechanicsburg, PA 17050. P. ?. At -9- ? P AND FURTIVR, that in the event this case should be reduced to judgment and a Writ of Execution is issued, Service upon the Defendant at the above referenced address by Certified Return Receipt mail and ordinary mail and by posting a copy of the Notice of Sale or Sheriff's handbill in the most public part of the premises and by publication by Sheriff pursuant to Pennsylvania Rule of Civil Procedure 3129.2 (d). Service would be complete as described under the service of the Complaint. 9;:11e4 9I i' Cc R , 20 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION - LAW DEUTSCHE BANK NATIONAL CIVIL Division TRUST COMPANY AS TRUSTEE Case Number: 07.6674 Civil Term PLAINTIFF Type of Pleading VS Praecipe to Reinstate Complaint in Mortgage Foreclosure JUSTIN D. CRIDER DEFENDANT CERTIFICATE OF LOCATION 1825 HUNTER DRIVE MECHANICSBURG, PA 17050 TOWNSHIP OF MIDDLE HAMPDEN PARCEL No: 10-14-0844-010 Code and Classification: Filed on Behalf Of: Plaintiff Counsel of Record: Daniel J. Mancini, Esquire Attorney at Law 201 A Fairview Drive Monaca, PA 15061 (724) 72 By: DANIEL J. MANCINI, ESQ. PA I.D. No. 39353 Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 mancinilawfirmj comcast. net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE PLAINTIFF VS JUSTIN D. CRIDER DEFENDANT CIVIL ACTION - LAW CASE NO: 07-6674 CIVIL TERM MORTGAGE FORECLOSURE PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint for Mortgage Foreclosure in the above matter against defendant, Justin D. Crider. r DANIEL J. MANCINI, ESQUIRE ATTORNEY FOR PLAINTIFF N SHERIFF'S RETURN - REGULAR CASE NO: 2007-06674 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TR CO VS CRIDER JUSTIN D NOAH CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon _?_rr? _.r mTwT r the DEFENDANT , at 1405:00 HOURS, on the 14th day of February , 2008 at 1825 HUNTER DRIVE MECHANICSBURG, PA 17050 by handing to POSTED PROPERTY AT 1825 HUNTER DRIVE MECHANICSBURG a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: fi Docketing 18.00 ? Service 10.56 Posted 6.00 Surcharge 10.00 R. Thomas Kline 00 44.56 02/15/2008 DANIEL MANCINI Sworn and Subscibed to By: before me this day Deputy Sheriff of A.D. Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 mancinilawfirm!a comcast.net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE PLAINTIFF VS CIVIL ACTION - LAW CASE NO: 07-6674 CIVIL TERM MORTGAGE FORECLOSURE JUSTIN D. CRIDER DEFENDANT PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment, in rem, in favor of the Plaintiff, DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, c/o Daniel J. Mancini, Esquire, 201A Fairview Drive, Monaca, PA 15061, and against Defendant JUSTIN D. CRIDER, whose last known address is 1825 HUNTER DRIVE, MECHANICSBURG, PA 17050 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: Unpaid Principal Balance $ 344,630.87 Delinquent Balance, including Interest at $87.34 per diem $ 41,856.73 From 12/01/06 to 03/24/08 (based on contract rate of 9.25%) Rec. Corp. Adv. $ 000.00 Escrow Advance $ 000.00 Accrued Late Charges $ 1,986.74 Bad CK Fees $ 00.00 Attorney's Fee $ 17,231.54 Total $ 405,705.88 I hereby certify the (1) the addresses of the Plaintiff and Defendants are as/?h?wn above, and (2) notice has been given in accordance with Rule 237.1, copy attached. / / / Daniel J. Mancini, Esq. Attorney Bar No.: 39353 DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: 3 a 0 8 PRO HONOT "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." r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION - LAW DEUTSCHE BANK NATIONAL CIVIL Division TRUST COMPANY AS TRUSTEE Case Number: 07-6674 Civil Term PLAINTIFF VS JUSTIN D. CRIDER DEFENDANT Type of Pleading Mortgage Foreclosure Praecipe for Default Judgment Code and Classification: CERTIFICATE OF LOCATION 1825 HUNTER DRIVE MECHANICSBURG, PA 17050 TOWNSHIP OF MIDDLE HAMPDEN PARCEL No: 10-14-0844-010 Filed on Behalf Of: Plaintiff Counsel of Record: Daniel J. Mancini, Esquire Attorney at Law 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233, By: DANIEL J. MANCINI, ESQ. PA I.D. No. 39353 Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 mancinilawfirm,comcast.net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE PLAINTIFF VS CIVIL ACTION - LAW CASE NO: 07-6674 CIVIL TERM MORTGAGE FORECLOSURE JUSTIN D. CRIDER DEFENDANT AFFIDAVIT OF ACT 91 OF 1983 I, Daniel J. Mancini, Esquire, hereby affirm that I have compli with Act 6 and Act 91 of 1983, notice requirements in the above-captioned matte . Daniel J. Mancini, Esquire Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 mancini lawfirm??comcast.net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE PLAINTIFF VS CIVIL ACTION - LAW CASE NO: 07-6674 CIVIL TERM MORTGAGE FORECLOSURE JUSTIN D. CRIDER DEFENDANT AFFIDAVIT OF NAMES AND ADDRESSES OF OWNERS AND DEFENDANTS COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DANIEL J. MANCINI, Esq., being duly authorized to make this affidavit on behalf of the Plaintiff in the above action DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, being duly sworn according to law deposes and says that to the best of his knowledge, information and belief the owner of 1825 HUNTER DRIVE, MECHANICSBURG, PA 17050, the real property to be sold in the within execution and the defendants in the judgment are JUSTIN D. CRIDER, whose last known address 1825 HUNTER DRIVE, MECHANICSBURG, PA 17050 DATE: March 24, 2008 Attorney for Plaintiff DANIEL J. MANCINI, ESQUIRE Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 mancini lawfirrnLd)comcast.net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE PLAINTIFF VS CIVIL ACTION - LAW CASE NO: 07-6674 CIVIL TERM MORTGAGE FORECLOSURE JUSTIN D. CRIDER DEFENDANT AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Daniel J. Mancini, being duly sworn according to law, deposes and says that he is the attorney of record, for the above-named Plaintiff, that he makes this Affidavit on Plaintiff s behalf, and that the statements in this Affidavit are true to the best of his knowledge, information and belief. Defendant JUSTIN D. CRIDER is over 21 years of age. Defendant is not in the military service of the United States as contemplated by the Soldier's and Sailor's Civil Relief Act, as amended. This affidavit is made in connection with the judgment upon a note/firp mortgage secured upon the premises located at 1825 HUNTER DRIVE, MECHANICSBURV, P By: Daniel J. Mancini, Esq. Daniel Mancini & Associates Daniel J. Mancini. Esq.. PA Bar ID: 39353 201 A Fairview Drive Monaca. PA 15061 (724) 728-4233 man c in i l awfi rm:Crco m cast. net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE PLAINTIFF VS JUSTIN D. CRIDER DEFENDANT CIVIL ACTION - LAW CASE NO: 07-6674 CIVIL TERM MORTGAGE FORECLOSURE AFFIDAVIT OF SPECIAL SERVICE PURSUANT TO PA.R.C.P. 410 &430 follows: I, Daniel J. Mancini, attorney for Plaintiff, hereby depose and state as follows: Plaintiff or its agents has followed the Special Service Order, granted on January 18, 2008 as A. Copy of said notice was posted on mortgaged property at 1825 Hunter Drive, Mechanicsburg, PA 17050 on February 14, 2008; and B. Copy of said notice was mailed by Certified Mail, return receipt requested, and by ordinary first class mail to Defendant at 1825 Hunter Drive, Mechanicsburg, PA 17050 on February 19, 2008, Certificate of Mailing Receipt and Certified Mail Receipt attached. C. Complaint was properly published in both the Cumberland County Law Journal on February 15, 2008, as well as the Sentinel on February 8, 2008 (Proof of Publication Notices are attached). I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information, or belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Date: February 28, 2008 DANIE . MA I AND ASSOCIATES By: Daniel J. Mancini, s Attorney for Plaintiff JAN 112008 a? IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE PLAINTIFF VS JUSTIN D. CRIDER DEFENDANT CIVIL ACTION - LAW CASE NO: 07-6674 CIVIL TERM MORTGAGE FORECLOSURE ORDER FOR SERVICE AND NOW, to wit, this ?p day of "?'' , 2008 upon consideration of the within Motion for Special Service and its supporting J?idavit of Investigation, it appearing that a Good Faith Investigation and effort to locate the Defendant has been made by Plaintiff, it is hereby ORDERED that service of the Complaint be made upon Defendant JUSTIN D. CRIDER in the following manner: THAT a copy of the Complaint be posted on the premises at 1825 Hunter Drive, Mechanicsburg, PA 17050. THAT a copy of the Complaint be also sent via Certified Return Receipt Mail and ordinary first class mail to said Defendant at 1825 Hunter Drive, Mechanicsburg, PA 17050. n 441- AND FURTAR, that in the event this case should be reduced to judgment and a Writ of Execution is issued, Service upon the Defendant at the above referenced address by Certified Return Receipt mail and ordinary mail and by posting a copy of the Notice of Sale or Sheriff's handbill in the most public part of the premises and by publication by Sheriff pursuant to Pennsylvania Rule of Civil Procedure 3129.2 (d). Service would be complete as described under the service of the Complaint. { ? ,W ? n ': Yti?g IC1 ? Y ? Y SHERIFF'S RETURN - REGULAR CASE NO: 2007-06674 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TR CO VS CRIDER JUSTIN D NOAH CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CRIDER JUSTIN D the DEFENDANT , at 1405:00 HOURS, on the 14th day of February-, 2008 at 1825 HUNTER DRIVE MECHANICSBURG, PA 17050 by handing to POSTED PROPERTY AT 1825 HUNTER DRIVE MECHANICSBURG a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Posted Surcharge Sworn and Subscibed to before me this of So Answers: 18.00 10.56 ?v 6.00 10.00 R. Thomas Kline .00 44.56 02/15/2008 DANIEL MANCINI By. i day Deputy Sheriff A.D. L 1 , p I vided) -p 43 . 0 M -B Postage $ Certified Fee OO Return Receipt Fee (Endorsement Required) Postm Here C3 0 Restricted Delivery Fee (Endorsement Required) cc ..0 ru Total Postage & Fees r'l- Sent To {yl,( ? IM (? 5 Sfreef. APL N _ 11 PC Box No., ? i 1 _\r 1.{ { ? L 1 V V A 1 -- Ci 4 °- yo?q -- S ?l L _ :V? W ? ImpWiMMOMMUMMM A2 UN/ TED ST/JTES POSTAL SERV/CE® This Certificate of Mailin g provides Certificate of Mailing mps or evidence that mail has been pres to 77 This form may be used for domestic and inte ented USPS® From: rn ational mail. for mailing. Mancul i F ". & Ass ??ates ., awvieW i dve 0 N UNI?j (o r N S 9 `mp rn U ? •yr?n To: • A N V 0 -zf(?5trnark 3 y?' N T 40 ? 0 Om0 O 0 Q m mo..a i? ooo? rno m PS Form 3817, April 2007 PSN 7530-02-000-9065 m co O PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz February 15, 2008 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. r i4a Marie Coyne, SWORN TO AND SUBSCRIBED before me this 15 day of February, 2008 Notary NOTARIAL SEAL DEBORAH A COLLINS CARLISLE BORO t UMBERLAND COUNTY My Commission Expires Apr 28, 2p10 CUMBERLAND LAW JOURNAL NOTICE In the Court of Common Pleas of Cumberland County Commonwealth of Pennsylvania Civil Action-Law 07-6674 Civil Term DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE vs. JUSTIN D. CRIDER, MORTGAGOR and REAL OWNER, DEFENDANT NOTICE OF ACTION IN MORTGAGE FORECLOSURE TO: JUSTIN D. CRIDER, MORT- GAGOR and REAL OWNER, DE- FENDANT, whose last known address is 1825 Hunter Drive, Mechanicsburg, PA 17050. THIS FIRM IS A DEBT COLLEC- TOR ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT, ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PUR- POSE OF COLLECTING THE DEBT. You are hereby notified that Plain- tiff, DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, has filed a Mortgage Foreclosure Complaint endorsed with a Notice to Defend, against you in the Court of Common Pleas of,Cumberland County, Pennsylvania, docketed to 07-6674 Civil Term, wherein Plaintiff seeks to foreclose on the mortgage secured on your property located at 1825 Hunter Drive, Mechanicsburg, PA 17050, whereupon your property would be sold by the Sheriff of Cum- berland County. NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the notice above, 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 THE INFORMA- TION 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 RE- DUCED FEE OR NO FEE. Lawyer Referral Services 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 DANIEL J. MANCINI, ESQUIRE MANCINI & ASSOCIATES Attorneys for Plaintiff 201A Fairview Drive Monaca, PA 15061 (724) 728-4233 Feb. 15 11 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Troy Whitesel, Classified Advertising Manager, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): February 8, 2008 COPY OF NOTICE OF PUBLICATION IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION - LAW 07.6674 Civil Term NOTICE OF ACTION IN MORTGAGE FORECLOSURE DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE vs. JUSTIN D. CRIDER, MORTGAGOR and REAL OWNER, DEFENDANT TO: JUSTIN D. CRIDER, MORTGAGOR and REAL OWNER, DEFENDANT, whose last known address is 1825 Hunter Drive, Mechanicsburg, PA 17050. THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT, ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE OF COLLECTING THE DEBT. You are hereby notified that Plaintiff, DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, has filed a Mortgage Foreclosure Complaint endorsed with a Notice"to Defend, against you in the, Court of Common Pleas of Cumberland County, Pennsylvania,.docketed to 07-6674 Civil Term, wherein Plaintiff seeks to foreclose on the mortgage secured on your property located at 1825 Hunter Drive, Mechanicsburg, PA 17050, whereupon your property would' be sold by the Sheriff of Cumberland County. NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the notice above, you masttake action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and tiling 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 THE 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 Services, 32 South Bedford Street Carlisle, PA 17013 (717)249-3166 Daniel J. Mancini, Esquire Attorney for Plaintiff MANCINI i£ ASSOCIATES 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. N4C-? Sworn to and subscribed before me this 8th day of February 2008. ! 1 ILIAt Notary P is My commission expires: (?// lok COMMONWEALTH OF PENNSYLVANIA Notarial Seal Christina L. Wolle, Notary pUb6C Carlisle Boro, Cumberland County MY Commission E Ores Sept 1, 2008 Member, Pennsylvania AssOClation Of Notaries Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 mancinilawfirmncomcast.net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE PLAINTIFF VS JUSTIN D. CRIDER DEFENDANT TO: Justin D. Crider 1825 Hunter Drive Mechanicsburg, PA 17050 DATE OF NOTICE: March 11, 2008 TLTTQ FTDAR TC A CIVIL ACTION - LAW CASE NO: 07-6674 CIVIL TERM MORTGAGE FORECLOSURE Tinn'r COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS (OU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS 3, AND ANY INFORMATION OBTAINED FROM YOU WILL ?OSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE 'HIS CORRESPONDENCE IS NOT AND SHOULD NOT BE 1E AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS [LCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE se you have failed to enter a written appearance personally or by attorney your defenses or objections to the claims set forth against you. Unless you date of this notice, a Judgment may be entered against you without a operty or other important rights. You should take this notice to a lawyer yer or cannot afford one, go to or telephone the following office to find 0 rn 0 0 0 N 0 0 co LO z U) a n 00 N .a Q T ao M E `o LL U) n Lawyer Reference Service, 32 South Bedford Street Carlisle, PA 17013 717-249-3166 Daniel J. Mancini, Esquire Attorney for Plaintiff Cl) T: Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 mancinilawfirm!acomcast.net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE PLAINTIFF VS CIVIL ACTION - LAW CASE NO: 07-6674 CIVIL TERM MORTGAGE FORECLOSURE JUSTIN D. CRIDER DEFENDANT RULE 236 NOTICE OF DEFAULT To: Justin D. Crider 1825 Hunter Drive Mechanicsburg, PA 17050 You are hereby notified that the following Order, Decree or Judgment has been entered against you on _Ma=h 017 T aoo g A Judgment of Default in the amount of $ 405,705.88 plus costs. Pro onotary If you have any questions concerning the above, please contact: DANIEL J. MANCINI, ESQUIRE MANCINI & ASSOCIATES 201 A FAIRVIEW DRIVE MONACA, PA 15061 724-728-4233 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION - LAW DEUTSCHE BANK NATIONAL CIVIL Division TRUST COMPANY AS TRUSTEE Case Number: 07-6674 Civil Term PLAINTIFF VS Type of Pleading Mortgage Foreclosure Praecipe for Writ of Execution JUSTIN D. CRIDER DEFENDANT CERTIFICATE OF LOCATION Code and Classification: Filed on Behalf Of: Plaintiff 1825 HUNTER DRIVE MECHANICSBURG, PA 17050 TOWNSHIP OF MIDDLE HAMPDEN PARCEL No: 10-14-0844-010 Counsel of Record: Daniel J. Mancini, Esquire Attorney at Law 201 A Fairview Drive Monaca, PA 1506 (724) 728-4233 By: DANIEL J. MANCINI, ESQ. PA I.D. No. 39353 Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 mancinil awfirmkcomcast.net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE PLAINTIFF VS CIVIL ACTION - LAW CASE NO: 07-6674 CIVIL TERM MORTGAGE FORECLOSURE JUSTIN D. CRIDER DEFENDANT PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 To the Director of the Office of Prothonotary issue writ of execution in the above matter: Amount Due From 02/01/06 to date of sale (based on contract rate of 9.25%) Dated this 24`h Day of March 2008. $ 405,705.88 Daniel J. Mancini, Esq. Attorney Bar No.: 39353 Note: Property Description attached. 01-02 _ 00 ° 00 00 Od6"o0 Vat F V? '?f p H 'r• - .9a Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE PLAINTIFF VS CIVIL ACTION - LAW CASE NO: 07-6674 CIVIL TERM MORTGAGE FORECLOSURE JUSTIN D. CRIDER DEFENDANT AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, Plaintiff in the above action, by its attorney, Daniel J. Mancini, 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 1825 HUNTER DRIVE, MECHANICSBURG, PA 17050. 1. Name and address of Owner(s) or reputed Owner(s): Justin D. Crider 1825 Hunter Drive Mechanicsburg, PA 17050 Name and address of Defendant(s) in the judgment: Justin D. Crider 1825 Hunter Drive Mechanicsburg, PA 17050 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: (PLAINTIFF IN THIS CASE) DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE 7770 West Parmer Lane, Building D, First Floor, Austin, TX 78729 c/o Daniel J. Mancini, Esq. 201 A Fairview Drive, Monaca, Pa 15061 07-6674 CIVIL TERM RECORDED 3/27/2008 AMOUNT $405,705.88 Clayton W. Davidson, Esquire 100 Pine Street Harrisburg, PA 17108 2007-001914 RECORDED 2/16/2007 AMOUNT $195,387.74 INTEGRITY BANK 3345 Market Street Camp Hill, PA 17011 2007-001914 RECORDED 2/16/2007 AMOUNT $195,387.74 06-02 . J - .4i» 4. Name and address of the last recorded holder of every mortgage of record: NONE OTHER THAN PLAINTIFF IN THIS CASE 5. Name and address of every other person who has any record lien on the property: UNKNOWN Name and address of every other person who has any record interest in the property and whose interest may be affected by the Sale: Department of Revenue Inheritance Tax Division Strawberry Square Harrisburg, PA 17105 Department of Public Welfare TPL Casualty Unit Estate Recovery Program PO Box 8486 Willow Oak Building Harrisburg, PA 17105-8486 Bureau of Individual Taxes Inheritance Tax Division Dept. 280601 Harrisburg, PA 17128-0601 Cumberland County Domestic Relations P.O. Box 320 Carlisle, PA 17013 7. Name and address of every other person whom the Plaintiff has knowledge who has any interest in the property which may be affected by the Sale: UNKNOWN I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information or belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. `4904 relating to unworn falsification to authorities. Dated this 27a' Day of May 2008 "cirri, Esq. Bar No.: 39353 06-02 s ` - ,-? c__ . G? .a . :;?, ? 1 ? z y ; , ,,, ?? ? ? "; .= .k 7 ?. }' .. w y ? . ,J„ Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE PLAINTIFF VS CIVIL ACTION - LAW CASE NO: 07-6674 CIVIL TERM MORTGAGE FORECLOSURE JUSTIN D. CRIDER DEFENDANT NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: December 10, 2008 TIME: 10:00 a.m. LOCATION: Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. DWELLING KNOWN AS 1825 HUNTER DRIVE, MECHANICSBURG, PA 17050. ALL THAT CERTAIN fret of land situate in Hampden Twp Cumberland County, Pennsylvarra, bounded and described as fellows: BEGINNING at a point in the middle of a Township Road known as Hunter Drive (f-800), which point is 14 90 feet, more or leas, West of the center line of LR21051, fhenoe in a atreipttt line South 6 degrees 30 minutes East, s distance of 325 feet to a point thence In a straight line South 83 dogmas 30 minutes West, a distance of 200 feet to a point; this Ina straight line North 8 degrees 30 minutes West a distance of 325 feat to a point thence in a straight line Norlh 83 degrees 30 minutes East, a distance d 200 feet to a point at the c erftr One of Hunter Drive, the place of BEG TINNING. THE LOCATION of your property to be sold is: 1825 HUNTER DRIVE MECHANICSBURG, PA 17050 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO: 07-6674 CIVIL TERM THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property JUSTIN D. CRIDER A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, Pennsylvania, Cumberland County Courthouse. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Lawyer Referral Services, 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained fparn ?thewithi County Court House before presentation to the Court. / Esq. Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 7284233 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE PLAINTIFF VS JUSTIN D. CRIDER DEFENDANT CIVIL ACTION - LAW CASE NO: 07-6674 CIVIL TERM MORTGAGE FORECLOSURE LONG PROPERTY DESCRIPTION ALL THAT CERTAIN tract of land situate in Hampden TWp Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point In the middle of a Township Road known as Hunter Drive (T-600), which point is 1480 feet, more or less, West of the center line of LR21051, thence in a straight line South 6 degrees 34 minutes East, a distance of 325 feet to a point; thence in a straight line South 83 degrees 30 minutes West, a distance of 200 feet to a point; thence in a straight Nne North 6 degrees 30 minutes West, a distance of 325 feet to a point; thence in a straight line North 83 degrees 30 minutes East, a distance of 200 feet b a pant at the center line of Hunter Drive, the place of BEGINNING.. RESERVING and. excepting on behalf of Allen W. Butner and Evelyn I. Bittner, his wife, for themselves, their heirs, successors and assigns, from the above-mentioned description a right of way over the northem 30 feet thereof, said 30 feet being measured perpendicularly to the said course of North 6 degrees 34 minutes West, said reservation being for the purposes of ingress, egress and regress, same to exist in perpehro; said right of way, as well as the description of the tract conveyed herein being shown on plan drawn by Wham B. Whitlock, Professional Engineer, and dated November 12, 1970. It is the intention of the parties hereto that the Grantee shell have no obligation and liability b construct, improve, maintain and repair any street or road constructed in and upon the right of way herein reserved, and further the center line of any such street shall be a continuation of center line, bearing the course of South 83 degrees, 30 minutes Wry as it presently exists in said Hunter Drive. CONTAINING approximately 1.49 acres and having erected a one story dwelling. DWELLING KNOWN AS 1825 HUNTER DRIVE, MECHANICSBURG, PA 17050 IDENTIFIED as TAX/PARCEL ID#: 10-14-0844-010 in the Deed Registry Office of Cumberland County, Pennsylvania. iel . Mancini, Esquire Attorney for Plaintiff WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N007-6674 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, Plaintiff (s) From JUSTIN D. CRIDER (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 $405,705.88 L.L.$ 0.50 Interest from 2/01/06 to date of sale (based on contract rate of 9.25%) Atty's Comm % Atty Paid $248.76 Plaintiff Paid Date: 5/29/08 Due Prothy $2.00 Other Costs d' A Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: DANIEL J. MANCINI, ESQUIRE Address: DANIEL MANCINI & ASSOCIATES 201 A FAIRVIEW DRIVE MONACA, PA 15061 Attorney for: PLAINTIFF Telephone: 724-728-4233 Supreme Court ID No. 39353 . _ I Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar 1D: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE PLAINTIFF VS CIVIL ACTION - LAW CASE NO: 07-6674 CIVIL TERM MORTGAGE FORECLOSURE JUSTIN D. CRIDER DEFENDANT RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Aliquippa, Pennsylvania on November 5, 2008, a true and correct copy of Notice of Sale of Real Estate pursuant to PA R.C.P. 3129.1 to all lien holders of record by regular first class mail (Certificate of Mailing form in compliance with U.S. Postal Form 3817 is attached hereto as evidence), which mailing receipts are attached. Service addresses are as follows: Clayton W. Davidson, Esquire 100 Pine Street Harrisburg, PA 17108 INTEGRITY BANK 3345 Market Street Camp Hill, PA 17011 Department of Revenue Inheritance Tax Division Strawberry Square Harrisburg, PA 17105 Department of Public Welfare TPL Casualty Unit Estate Recovery Program PO Box 8486 Willow Oak Building Harrisburg, PA 17105-8486 Bureau of Individual Taxes Inheritance Tax Division Dept. 280601 Harrisburg, PA 17128-0601 Cumberland County Domestic Relations P.O. Box 320 Carlisle, PA 17013 Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, PA 17013 • - '6 Marie Huber 230 South Sporting Hill Road Mechanicsburg, PA 17050 N O v. T co z W 0 N O 00 W 83MC19 A3NJ AMMORMWA n 3 V 0 0 W O bo?? ib 0? no 00L.t00 "Moo A3... . T a ? .. g p S? 3 "a ;n 44 v CO ..1 V N h N k v co 5WW Oy?D b 0 W W z w 0 0 N O ? pQ Of U? T yy r7 ? 4 G? .? mR ? S 00 a - n cn ? o lY . :o a q 'S ? i 3t o did wGri? nil oft*' O0 ?aMOH A3Nlid .wry C. 1,5? ?ydy wr r '40z 0; d Sai,, so sty 00?,'L053MOH A3Nild w rl?t, 1-fj•. ?5<Jci 3 an 3 oo wa nR a • a nnV^^ 6m_ W' ?N ?$ C v ? ? Yr! .- ? (rT Q v m b b 0 O z Z U O N O I V. y O °v z z V W b N P Lh H 1) 'o 00.'!.0 S3MOf1 A3Nlld 0 006 g0 10 OM'W o aw®A! 0 9 If V4 'U x S3MOS A3Nlld bJVt JCi ,A c3 o ?3 n° mm till m< • aS oo d? 0 I _m n o o s 71 ?? 3 ?QA 64, m° a3 m y sm ' 3- 4? . 5 x.35 o ?M m n ` i ' !D f 00 Y 3 3 1 w 1965;. 8UU? Qot S3MO8 001 L o '"MO8 A3NAId 3! om c° ?m 3 ? I a$ • g3 o3 G 3 N /1/7 07 3 z ? QQ rm ?m n- a? 3m ?N ' 33 °3 O m_N v rD i a o r C a? 9- m - s ' 1 , Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE PLAINTIFF VS CIVIL ACTION - LAW CASE NO: 07-6674 CIVIL TERM MORTGAGE FORECLOSURE JUSTIN D. CRIDER DEFENDANT NOTICE PURSUANT TO PA. R.C.P. 3129 Notice is hereby given to the following parties who hold one or more mortgage, judgment or tax liens or any claim against the real estate of 1825 HUNTER DRIVE, MECHANICSBURG, PA 17050. Clayton W. Davidson, Esquire 100 Pine Street Harrisburg, PA 17108 2007-001914 RECORDED 2/16/2007 AMOUNT $195,387.74 INTEGRITY BANK 3345 Market Street Camp Hill, PA 17011 2007-001914 RECORDED 2/16/2007 AMOUNT $77,077.00 Department of Revenue Inheritance Tax Division Strawberry Square Harrisburg, PA 17105 Department of Public Welfare TPL Casualty Unit Estate Recovery Program PO Box 8486 Willow Oak Building Harrisburg, PA 17105-8486 Bureau of Individual Taxes Inheritance Tax Division Dept. 280601 Harrisburg, PA 17128-0601 Cumberland County Domestic Relations P.O. Box 320 Carlisle, PA 17013 Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, PA 17013 YEAR 2007 AMOUNT $3,306.18 _ _j6 Marie Huber 230 South Sporting Hill Road Mechanicsburg, PA 17050 You are hereby notified that on December 10, 2008 at 10:00 A.M. Prevailing time, by virtue of a Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, on the judgment of, DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, the Sheriff of Cumberland County, Pennsylvania will expose at Public Sale at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013, the real estate of JUSTIN D. CRIDER, known and numbered as 1825 HUNTER DRIVE, MECHANICSBURG, PA 17050, Cumberland County. A description of said real estate is hereto attached. You are further notified that a Schedule of Distribution of Proposed Distribution will be filed by the Sheriff of Cumberland County within thirty (30) days, and distribution will be made in accordance with the Schedule unless exceptions are filed thereto within ten (10) days thereafter. You are further notified that the lien you hold sale and that you have an opportunity to protect Sale youy . the said real estate will be divested by the if any, by being notified of said Sheriff's DATE: November 5, 2008 By: Mini, Esq. Plaintiff w Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE PLAINTIFF VS CIVIL ACTION -- LAW CASE NO: 07-6674 CIVIL TERM MORTGAGE FORECLOSURE JUSTIN D. CRIDER DEFENDANT AMENDED AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, Plaintiff in the above action, by its attorney, Daniel J. Mancini, 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 1825 HUNTER DRIVE, MECHANICSBURG, PA 17050. Name and address of Owner(s) or reputed Owner(s): Justin D. Crider 1825 Hunter Drive Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: Justin D. Crider 1825 Hunter Drive Mechanicsburg, PA 17050 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: (PLAINTIFF IN THIS CASE) DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE 7770 West Partner Lane, Building D, First Floor, Austin, TX 78729 c/o Daniel J. Mancini, Esq. 201A Fairview Drive, Monaca, Pa 15061 07-6674 CIVIL TERM RECORDED 3/27/2008 AMOUNT $405,705.88 Clayton W. Davidson, Esquire 100 Pine Street Harrisburg, PA 17108 2007-001914 RECORDED 2/16/2007 AMOUNT $195,387.74 INTEGRITY BANK 3345 Market Street Camp Hill, PA 17011 2007-001914 RECORDED 2/16/2007 AMOUNT $77,077.00 06-02 4. Name and address of the last recorded holder of every mortgage of record: NONE OTHER THAN PLAINTIFF IN THIS CASE 5. Name and address of every other person who has any record lien on the property: UNKNOWN Name and address of every other person who has any record interest in the property and whose interest may be affected by the Sale: Department of Revenue Inheritance Tax Division Strawberry Square Harrisburg, PA 17105 Department of Public Welfare TPL Casualty Unit Estate Recovery Program PO Box 8486 Willow Oak Building Harrisburg, PA 17105-8486 Bureau of Individual Taxes Inheritance Tax Division Dept. 280601 Harrisburg, PA 17128-0601 Cumberland County Domestic Relations P.O. Box 320 Carlisle, PA 17013 Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, PA 17013 YEAR 2007 AMOUNT $3,306.18 Marie Huber 230 South Sporting Hill Road Mechanicsburg, PA 17050 Name and address of every other person whom the Plaintiff has knowledge who has any interest in the property which may be affected by the Sale: UNKNOWN I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information or belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. `4904 relating to unswom falsification to authorities. Dated this 5TH Day of November 2008 06-02 huomey tsar No.: 39353 LONG PROPERTY DESCRIPTION ALL THAT CERTAIN tract of land situate In Hampden Twp Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point In the middle of a Township Road known as Hunter Drive (T-800), which point is 1080 feet, more or fens, West of the center line of LR21051, thence in a straight line South 6 degrees 30 minutes East, a distance of 325 feet to a point; thence In a straight line South 83 degrees 30 minutes West, a distance of 200 feet to a point; thence in a straight line North 6 degrees 30 minutes West, a distance of 325 feet to a point; thence In a straight line North 83 degrees 30 minutes East, a distance of 200 feet m a point at the center line of Hunter Drive, the place of BEGINNING. RESERVING and excepting on behalf of Allen W. Bittner and Evelyn I. Butner, his wife, for themselves, their heirs, successors and assigns, from the above-mentioned description a right of way over the northern 30 feet thereof, said 30 feet being measured perpendicularly to the said course of North 8 degrees 30 minutes West, said reservation being for the purposes of ingress, egress and nagress, same to exist in perpetuo; said right of way, as well as the description of the tract conveyed herein being shown on plan drawn by William B. Whitlock, Professional Engineer, and dated November 12, 1970. It is the Intention of the parties hereto that the Grantee shall have no obligation and liability b construct, improve, maintain and repair any street or rued constructed in and upon the right of way herein reserved; and further the center line of any such street shall be a continuation of center Iine, bearing the course of South a3 degrees, 30 minutes West, as it presently exists in said Hunter Drive. CONTAINING approximately 1.49 acres and having erected a one story dwelling. DWELLING KNOWN AS 1825 HUNTER DRIVE, MECHANICSBURG, PA 17050 IDENTIFIED as TAX/PARCEL ID#: 10-14-0844-010 in the Deed Registry Office of Cumberland County, Pennsylvania. ?, - ?-, r.?.. s r -? . Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE PLAINTIFF VS JUSTIN D. CRIDER DEFENDANT CIVIL ACTION - LAW CASE NO: 07-6674 CIVIL TERM MORTGAGE FORECLOSURE RETURN OF SERVICE I hereby certify that a true and correct copy of Notice of Sale of Real Estate pursuant to PA R.C.P. 3129 was sent to the Defendant, JUSTIN D. CRIDER, at their respective address which is 1825 HUNTER DRIVE, MECHANICSBURG, PA 17050. The Notice of Sheriff's sale was sent by Certified / Registered Mail, which I deposited in the U.S. Mails at Aliquippa, Pennsylvania on November 5, 2008. In addition to the Notice set forth above, a Notice of Sale was also sent to the Defendant via Regular First Class Mail on November 5, 2008. A copy of C It to M ing is attached also. By Daniel J. ni, sq. Attorney for Plaintiff 1 - ?a E ?E U€ LL 41 T 9 0 0 M N A a n o° N L co a i r' r vD el? c ?,lcs Pqp `9 -'PITNEY 9OWFS 00 X00 9 4NOV 0 t cn? d T m Z m"' ? LL LL LL am LL zm e6 U m ¢c Oc .20 E E ?? o z ism QW ~ m ? `o lro 029E QEQQ EOOO OfiTT 9001. t? 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 Home Equity Mortgage Loan Trust Tr is the grantee the same having been sold to said grantee on the 4 day of February A.D., 2009, under and by virtue of a writ Execution issued on the 29 day of May, A.D., 2008, out of the Court of Common Pleas of said County as of Civil Term, 2007 Number 6674, at the suit of Deutsche Bank Natl Trust Co Trustee against Justin D Crider is duly o? d (0 1 recorded as Instrument Number .5 IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of Mm-cl , A.D. a'lpv q Rec rder of Deeds co..:T e County, „ .,r"„ PA P A-1 444S W EAO(04 VM Fast idiOA06y 06 Jdfr. s r o Deutsche Bank National Trust Company as In the Court of Common Pleas of Trustee Cumberland County, Pennsylvania VS Writ No. 2007-6674 Civil Term Justin D. Crider Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that on August 20, 2008 at 1838 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Justin D. Crider by posting the premises located at 1825 Hunter Drive, Mechanicsburg, Cumberland County, Pennsylvania pursuant to order of court with the said true and correct copy of the same. Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on October 9, 2008 at 1055 hours, she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Justin D. Crider, located at 1825 Hunter Drive, Mechanicsburg, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Justin D. Crider, by regular mail to his last known address of 1825 Hunter Drive, Mechanicsburg, PA 17050. This letter was mailed under the date of October 6, 2008 and never returned to the Sheriffs 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, Cumberland County, Pennsylvania on February 4, 2009 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Daniel Mancini, on behalf of Deutsche Bank National Trust Company as Trustee of Home Equity Mortgage Loan Asset Backed Trust Series INABS 2006-E, Home Equity Mortgage Loan Asset-Backed Certificates Series 2006-E Under the Pooling and Servicing Agreement Dated December 1, 2006. It being the highest bid and best price received for the same, Deutsche Bank National Trust Company as Trustee of Home Equity Mortgage Loan Asset Backed Trust Series INABS 2006-E, Home Equity Mortgage Loan Asset-Backed Certificates Series 2006-E Under the Pooling and Servicing Agreement Dated December 1, 2006 of 7770 West Parmer Lane, Building D, 1" Floor, Austin, TX 78729, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $1,145.95. Sheriffs Costs: Docketing $30.00 Poundage 22.08 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 48.00 Auctioneer 10.00 Law Library .50 Prothonotary 2.00 Mileage 22.00 Levy 15.00 Surcharge 20.00 Postpone Sale 20.00 Posting Law Journal 6.00 419.00 Patriot News 411.95 0 Share of Bills 14.92 Co - Distribution of Proceeds 25.00 .. ) Sheriffs Deed 49.50 ?? $ 1,145.95 t q ??G < CA- ; 9 1 aw . 4I ? , i U ?/'?! J?? ` _ ! 3±1 „? I __ , 14 Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE PLAINTIFF VS JUSTIN D. CRIDER DEFENDANT CIVIL ACTION - LAW CASE NO: 07-6674 CIVIL TERM MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, Plaintiff in the above action, by its attorney, Daniel J. Mancini, 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 1825 HUNTER DRIVE, MECHANICSBURG, PA 17050. Name and address of Owner(s) or reputed Owner(s): Justin D. Crider 1825 Hunter Drive Mechanicsburg, PA 17050 Name and address of Defendant(s) in the judgment: Justin D. Crider 1825 Hunter Drive Mechanicsburg, PA 17050 Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: (PLAINTIFF IN THIS CASE) DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE 7770 West Parmer Lane, Building D, First Floor, Austin, TX 78729 c/o Daniel J. Mancini, Esq. 201 A Fairview Drive, Monaca, Pa 15061 07-6674 CIVIL TERM RECORDED 3/27/2008 AMOUNT $405,705.88 Clayton W. Davidson, Esquire 100 Pine Street Harrisburg, PA 17108 2007-001914 RECORDED 2/16/2007 AMOUNT $195,387.74 INTEGRITY BANK 3345 Market Street Camp Hill, PA 17011 2007-001914 RECORDED 2/16/2007 AMOUNT $195,387.74 06-02 ' 4• Name and address of the last recorded holder of every mortgage of record: NONE OTHER THAN PLAINTIFF IN THIS CASE Name and address of every other person who has any record lien on the property: UNKNOWN Name and address of every other person who has any record interest in the property and whose interest may be affected by the Sale: Department of Revenue Inheritance Tax Division Strawberry Square Harrisburg, PA 17105 Department of Public Welfare TPL Casualty Unit Estate Recovery Program PO Box 8486 Willow Oak Building Harrisburg, PA 17105-8486 Bureau of Individual Taxes Inheritance Tax Division Dept. 280601 Harrisburg, PA 17128-0601 Cumberland County Domestic Relations P.O. Box 320 Carlisle, PA 17013 Name and address of every other person whom the Plaintiff has knowledge who has any interest in the property which may be affected by the Sale: UNKNOWN I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information or belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. `4904 relating to unworn falsification to authorities. Dated this 27th Day of May 2008 rancini, Esq. Bar No.: 39353 06-02 Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE PLAINTIFF VS CIVIL ACTION - LAW CASE NO: 07-6674 CIVIL TERM MORTGAGE FORECLOSURE JUSTIN D. CRIDER DEFENDANT NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff s Sale of Real Property (real estate) will be held: DATE: December 10, 2008 TIME: 10:00 a.m. LOCATION: Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. DWELLING KNOWN AS 1825 HUNTER DRIVE, MECHANICSBURG, PA 17050. ALL THAT CERTAIN tract of land situate in Hampden Twp Cumberland County, Pennsylverra, bounded and detoodbed as tdlows: BEGINNING at a point in the middle of a Towship Road known as Hunter Drive (f-800), which point is 11160 feet, more or less, Weet of the center line of t.R21051, thence in a straight ins South a degrees 30 minutes East, a distance of 325 test 1D a point thence in a straight tine Souulh 83 degrees 30 minutes West, a distance of 200 feat to a point: thence in a su*ht tine North 8 degrees 30 minutes West; a distance of 325 feet to a point Owm in a straight line North 83 Wgrm 30 minutes East, a dlstenoe d 200 feet to a point st the center line of Hunter drive, the place of BEGINNING. THE LOCATION of your property to be sold is: 1825 HUNTER DRIVE MECHANICSBURG, PA 17050 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO: 07-6674 CIVIL TERM THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property JUSTIN D. CRIDER A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, Pennsylvania, Cumberland County Courthouse. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Lawyer Referral Services, 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained fro he wi in County Court House before presentation to the Court. a 'el ncini, Esq. Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE PLAINTIFF VS JUSTIN D. CRIDER DEFENDANT CIVIL ACTION - LAW CASE NO: 07-6674 CIVIL TERM MORTGAGE FORECLOSURE LONG PROPERTY DESCRIPTION ALL THAT CERTAIN Iraat of land situate In Hampden Twp Cumbertard County, Pennsylvania, bounded and described as k4ms: BEGINNING A a point in the middle of a Township Road known as Hunter Drive (T-6W), which point is 1090 feet, more or less, West of the center line of LR21051, thence in a straight I" South 6 degrees 30 minutes East, a distance of 325 feet to a point; thence In a straight line South 83 degrees 30 minutes West, a distance of 200 feet to a point; thence in a streight line North 6 degrees 30 minutes West, a distance of 325 feet to a pow thence In a straight line North 83 degrees 30 minutes East, a distance of 200 feet to a point at the center tine of Hunter Drive, the place of BEGINNING. RESERVING and excepting on behalf of Allen W. Butner and Evelyn 1. Butner, his wife, for themselves, their heMrs, suooessors and assigns, from the above-mentioned description a right of may over the northon 30 That thereof, sold 30 feet being measured perpendicularly to the said course of North 9 degrees 30 minutes West, said reservation being for the purposes of koass, egress and regrew, same to exist in perpehra said right of way, as wall as the description of the tract conveyed herein being shown on plan drawn by Wiliam B. Whitlock, Proliessional Engineer, and dated November 12, 1970. It is the intention of the parties hereto that the Grantee shall have no obligalian and liability b construct, improve, maintain and repair any street or road constructed In and upon the right of way herein roverved, and further the center line of any such street shall be a continuation of center line, bearing the course of South 83 degrees, 30 minutes West as it presently exists in said Hunter Drive. CONTAINING approximately 1.49 acres and having erected a one story dwelling. DWELLING KNOWN AS 1825 HUNTER DRIVE, MECHANICSBURG, PA 17050 IDENTIFIED as TAX/PARCEL ID#: 10-14-0844-010 i e eed Registry Office of Cumberland County, Pennsylvania. Paw Mancini, Esquire Attorney for Plaintiff WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N007-6674 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, Plaintiff (s) From JUSTIN D. CRIDER (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 $405,705.88 L.L.$ 0.50 Interest from 2/01/06 to date of sale (based on contract rate of 9.25%) Atty's Comm % Due Prothy $2.00 Atty Paid $248.76 Other Costs Plaintiff Paid Date: 5/29/08 Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: DANIEL J. MANCINI, ESQUIRE Address: DANIEL MANCINI & ASSOCIATES 201 A FAIRVIEW DRIVE MONACA, PA 15061 Attorney for: PLAINTIFF Telephone: 724-7284233 Supreme Court ID No. 39353 Jueadias al. Asa tea-H V XTIY)Ogp 80OZ `S I IsnonV : azrQ .uIQ.IQq pajoloduooui aouaiajai sixp Aq pue I" siq YM poig «V„ I!q!gxa uo paq!nsap XIInj a,ioui S.ingso=goaW `•ja ja#unH SZ8 t sie paaagwnu put, umouN Vd 94unoo pueljagwno `digsumoZ uapduiuH ui palmis fq iado id -Ivo i aqj ui isa ialui s,r wpuajap aill uodn painal JJuaus aii 80OZ `S I IsnSnV up £0# ales 0114SH IRON 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 31, November 7 and November 14, 2008 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Coyne, Editor SWORN TO AND SUBSCRIBED before me this 4 day of November, 2008 , Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO. CUMBERLAND COUNTY My Commission Expires Apr 28. 2010 REAL RWATZ BALE NO. 3 Writ No. 2007-6674 Civil Deutsche Bank National Trust Company as Trustee VS. Justin D. Crider Atty.: Daniel J. Mancini LONG PROPERTY DESCRIPTION ALL THAT CERTAIN tract of land situate in Hampden Twp Cumberland County, Pennsylvania bounded and described as follows: BEGINNING at a point in the middle of a Township Road known as Hunter Drive (T-600), which point is 1060 feet more or less, West of the center line of LR21051, thence in a straight line South 6 degrees 30 minutes East, a distance of 325 feet to a point; thence in a straight line South 83 degrees 30 minutes West a distance 200 feet to a point; thence in a straight line North 6 degrees 30 minutes West, a distance of 325 feet to a point; thence in a straight line North 83 degrees 30 minutes East, a distance of 2W feet to a point at the of BEGINNING. RESERVING and excepting on be- half of Allen W. Bttner and Evelyn I. Bittner, his wife, for themselves their heirs, successors and assigns, from the above-mentioned description a right of way over the northern 30 feet thereof, said 30 feet being measured perpendicularly to the said course of North 6 degrees 30 minutes West, said reservation being for the pur- poses of ingress, egress and regress, same to exist in perpetuo; said right of way, as well as the description of the tract conveyed herein being shown on plan drawn by William B Whittock, Professional Engineer, and dated November 12, 1970. It is the in- tention of the parties hereto that the Grantee shall have no obligation and liability to construct, improve, main- tain and repair any street or road constructed in and upon the right of way herein reserved; and further the center line of any such street shall be a continuation of center line, bearing the course of South 83 degrees, 30 minutes West, as it presently exists in said Hunter Drive. CONTAINING approximately 1.49 acres and having erected a one story dwelling. DWELLING KNOWN AS 1825 HUNTER DRIVE, MECHANICSBURG, PA 17050. IDENTIFIED as TAX/ PARCEL ID#: 10-14-0844-010 in the Deed Registry Office of Cumberland County, Penn- sylvania. _ ..._..< the Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE cue paftiot Hews Now you know 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 Joseph A. Dennison, being duly swom according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 10/29/08 .1 to akd,rs(aWfibed before me this P5 cjdyjbf jwovember, 2008 A.D. Notary 11/05/08 11112108 COMMONWEALTH OF PENNSYLVANIA NctarM Ssel Sherrie L Kk~, NOb" Public cxy of HwftMg: Da iphin county My Conrrftw EVM Nov. 25, 2011 Member. Pennsylvenle AsweleUon of Noferies Real Estate Sale No. 3 Writ No. 2007-0674 CMI Term Deutsche Bank National Trust Company as Trustee VS Justin D. Crider Attorney Daniel J. Mancini LEGAL DESCRiproN ALL. THAT CERTAIN tract of land situate in Hampden Twp _Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the middle of a Township Road known as Hunter Drive (-6iM), which point is t060 feet, more or less, West of the center line of LR21051, thence in a straight line South b degrees 30 minutes East, a distance of 325 feet to a point; thence in a straight line South 83 degrees 30 minutes West, a distance of 200 feet to a point; thence in a straight line ?fadispoiatd meina 83 degas 10 XqkC" Nes:1 a diSW=•of 200 feet 10 a point at ft eenWr fine offer }hive, the place of BEGINNING. RESERVING and excepting on behalf of Allen W. Bittner and Evelyn 1. Bitmer, his wife, for themselves, their heirs, successors and assigns, from the above-menfioned description a right of way over the northern 30 feet thereof, said 30 feet being measured perpendicularly to the said course of North 6 degrees 30 minutes West, said reservation being for the purposes of ingress, egress and regress,' same to exist in perpetuo; said right of way, as well as the description of the tract conveyed herein being shown on plan drawn by William R Whittock, Professional Engineer, and dated November 12, 1970. It is the intention of the parties hereto that )he Grantee shall have no obligation and liability to construct, improve, maintain and repair any street or road constructed in and upon the right of way herein reserved; and further the center line of any such street shall be a continuation of center' line, bearing the course of South 83 degrees, 30 minutes West, as it presently exists in said Hunter Drive. CONTAINING approximately 1.49 acres and having erected a one story dwelling. DWELLING KNOWN AS 1825 HUNTER DRIVE, iWCHANICSBURG, PA 17050 IDENTIFIED as TAXIPARCEL ID#: 10.14- 0844010 in the Deed Registry Office of Cumberland County, Pennsylvania.