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07-7143
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank Trust Company :COURT OF COMMON PLEAS Americas (f/k/a Bankers Trust :CIVIL DIVISION Company), as Trustee by Residential Funding Company, :Cumberland County LLC f/k/a Residential Funding Corporation, Attorney-in-fact 4828 Loop Central Drive Houston, TX 77081-2226 Plaintiff V. Kristy M. Bitting 205 Willow Mill Park Road : NO. -'f A?3 clc?t'c MechaPA 17050 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED.IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEKANDA A UN ABOGADO IMIEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: National City Mortgage Company d/b/a Accubanc Mortgage Assignments of Record to: Deutsche Bank Trust Company Americas (f/k/a Bankers Trust Company), as Trustee by Residential Funding Company, LLC f/k/a Residential Funding Corporation, Attorney-in- fact Recording Date: 4/25/05 Book: 716 Page: 4791 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed.. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the mortgage being foreclosed is as follows: MORTGAGED PREMISES: 205 Willow Mill Park Road MUNICIPALITY/TOWNSHIP/BOROUGH: Silver Spring Township COUNTY: Cumberland DATE EXECUTED: 3/8/04 DATE RECORDED: 3/24/04 BOOK: 1857 PAGE: 4966 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 11/20/07: Principal of debt due $115,516.30 Unpaid Interest at 6.50% from 1/1/07 to 11/20/07 (the per diem interest accruing on this debt is $20.57 and that sum should be added each day after 11/20/07) 6,664.68 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $259.21 and that sum should be added on the first of each month after 11/20/07) 1,889.21 Late Charges (monthly late charge of $37.80 should be added in accordance with the terms of the note each month after 11/20/07) 93.65 Attorneys Fees (anticipated and actual to 5% of principal) 5,775.82 TOTAL $130,544.66 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $130,544.66 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 ALL THAT CERTAthr tract of lard with the improvements thereon erected. situate on the southeast side of WMm Nil Park Drive. Sliver Spring Township. Cumberland County. Permayivania, being Lot No. 57 and Lot No. 58 'allow MIR Puck' recorded in Plan Book 3. Page 7, bounded and described in ec=dance with a Plan of Survey by Whitlock and Hartman, dated Mey 7, 1981 and bearing Fie No. WM-81.41 N. 8: No. 666, as follows, to wit: BEGINNING at an Iron gin on fhe southwl side of WRlow MUM Paris Drive (30 foot wide right of way) at a corner of Lot No. 59 of the above mentioned Pion of Lacs, said point being 51.71 feet out of the southeast comer of Willow 1411 Park Drive and a 20 foot wide right of way; thence extending from sold beginning point and along Willow MRI Park Drive, South 77 degrees 23 rninutes 00 seconds East 103A2 feet to an iron On found at Lot No. 56 of the above mentioned Pion of Lots; thence extending along some South 2 degrees 10 minutes 00 seconds East 96.67 feat to an Iron pin found at property now or formerly of Aldie Sti!tler, thence extending along same and along Lot No. 95, South 96 degrees 07 minutes 53 seconds West 100.0+4 feet (shown in prior deed as South 87 degrees 50 minutes 00 seconds Wes! 100.00 feet) to an iron pin at Lot No. 59 aforementioned; thence extending along some NoM 2 degrees 10 minutes M seconds West 126.1)3 feel to the first mentioned iron pin and place of BEGINNING. Parcel #38-16-1072-008 Litton Loan Servicing LP P.O. Box 9010 Temecula, CA 92589-9010 Send Payments To: Litton Loan Servicing LP Attn: Cash Management Department P.O. Bca 4387 Houston, TX T7210-4387 Send Correspondence To: Litton Loan Servicing LP Attn: Customer Assistance Response Team 4828 Loop Central Drive Houston, TX 77081 7113 8257 1472 5001 8240 KRISTY BITTING 205 WILLOW MILL PARK RD MECHANICSBURG, PA 17050 PRESORT First-Class Mail U.S. Postage and Fees Paid W SO 20071016-80 DmdAct EXHIBIT A 0 Litton Loan Servicin' 4828 Loop Central Drive Houston, TX 77081 Telephone (800) 999-8501 Fax (713) 966-8906 www.httonloan.com 10116/2007 KRISTY BITTING Sent Via Certified Mail 205 WILLOW MILL PARK RD 7313 8257 1472 5001 8240 MECHANICSBURG, PA 17050 ACT 91 NOTICE TAir-Clu-JACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official Notice that the mortgage on your home is In default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached panes. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help save your home. This Notice explains how the proaram works. To see if HEMAP can help you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 34 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with von when you meet with the Counseling Agency. Agency ton-free at {8001342-2397 Persons with impaired hearing can call 17171780-1869. This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR MNIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION ]NMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDI IIR SU HIPOTECA. L HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDERISERVICER: Kristy Bitting 205 Willow Mill Park Rd Mechanicsburg, PA 17050 14504575 Contact Litton Loan Servicing LP Litton Loan Servicing LP HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT'J, YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT 30 DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT," EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of designated consumer credit counseling ggercies for the county in which the property is Io=d are set forth the end of this Notice. It is only necessary to schedule one "face-to-face" meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign, and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your "face-to-face" meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME E%E%MDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have Sled bankruptcy, you can stil apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT Bring it up to date.) NATURE OF THE DEFAULT - The MORTGAGE debt held by the :above lender on your property located at: 205 Willow Mill Park Rd IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 3/1/2007 through 10/1/2007 at $1,015.00 totaling $8,121.00 Other charges Late charges $189.00 Deferred late charges $0.00 NSF charges $0.00 Deferred NSF charges $25.00 Suspense balance $606•00 TOTAL AMOUNT DUE AS OF THIS DATE $7,729.58 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: Cure the default. HOW TO CURE THE DEFAULT - You may acre the default within THIRTY (30) DAYS of the date of this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $7,729.58 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check, certified check, or money order made payable and sent to: Litton Loan Servicing LP Attention: Cash Management Department P.O. Box 4387 Houston, TX 77210-4387 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fee that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you care the default within the THIRTY (30) DAY period, you wiU not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not aired the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any lain or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale, and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth In this Notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SH R1f'S SALE DATE - It is estimated that the earliest date that such Sheriff's Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A Notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. Name of Lender: LITTON LOAN SERVICING LP Address: 4828 Loop Central Drive, Houston, TX 77081 Phone Number: (800) 999-8501 Fax Number: (713) 966-8906 Contact Person: Default Administration Department EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end you ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - Under the terms of your mortgage and note, it may be possible to sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY Acorn Housing Adams County Interfaith 14 S. 13th Street Housing Authority Harrisburg, PA 17104 40 E High Street 717.213.0150 Gettysburg, PA 17325 717.334.1518 Community Action Loveship, Inc. Commission of Captial 2320 North 51h Street Region Harrisburg, PA 17110 1514 Derry Street 717.232.2207 Harrisburg, PA 17104 717.232.9757 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 ^2't V E R I F I C A T I O N Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. a ? ?J L... na C J ra N Cl O -n TTI OE/) SHERIFF'S RETURN - REGULAR CASE NO: 2007-07143 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK TRUST COMPANY VS BITTING KRISTY M SHAWN HARRISON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon RTTTING KRISTY M the DEFENDANT , at 1611:00 HOURS, on the 27th day of December , 2007 at 205 WILLOW MILL PARK ROAD MECHANICSBURG, PA 17050 KRISTY BITTING by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge IA OS 18.00 25.92 .00 10.00 .00 5 3. 9 2 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 12/28/2007 UDREN LAW OFFI By: eputy Sheriff of A. D. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings*udren.com Deutsche Bank Trust Company Americas € COURT OF COMMON PLEAS (f/k/a Bankers Trust Company), as Trustee by CIVIL DIVISION Residential Funding Company, LLC f/k/a CUMBERLAND COUNTY Residential Funding Corporation, Attorney- in-fact Plaintiff V. Kristy M. Bitting Defendant ' NO. 07-7143 PRAECIPE TO CORRECT TYPOGRAPHICAL ERROR IN COMPLAINT IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly correct a typographical error in the caption to list Defendant's address as follows: 205 Willow Mill Park Road, Mechanicsburg, PA 17050 Respectfully submitted, UDREN LAW OFFICES, P.C. BY: , MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE -1?OUIS A. SIMONI, ESQUIRE Attorneys for Plaintiff s UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings*udren.com Deutsche Bank Trust Company Americas € COURT OF COMMON PLEAS (f/k/a Bankers Trust Company), as Trustee by CIVIL DIVISION Residential Funding Company, LLC f/k/a CUMBERLAND COUNTY Residential Funding Corporation, Attorney- in-fact Plaintiff V. Kristy M. Bitting Defendant NO. 07-7143 CERTIFICATE OF SERVICE I, the undersigned, hereby certify that I have served true and correct copies of the Praecipe to Correct Typographical Error in Complaint in Mortgage Foreclosure upon the following person named herein at their last known address or their attorney of record. xxxxxx Regular First Class Mail Date Served: August 1$, 2008 TO: Kristy M. Bitting 205 Willow Mill Park Road Mechanicsburg, PA 17050 Defendant UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE --LOUIS A. SIMONI, ESQUIRE Attorneys for Plaintiff Co i) Fr i kx) L _! rY . 14. UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQU' - ID #04302 - ID #45362 - ID #34576 - ID #75860 IRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank Trust Company Americas (f/k/a Bankers Trust Company), as Trustee by Residential Funding Company, LLC f/k/a Residential Funding Corporation, Attorney-in-fact 4828 Loop Central Drive Houston, TX 77081-2226 Plaintiff v. i Kristy M. Bitting 205 Willow Mill Park Road Mechanicsburg, PA 17050 Defendant (s) COURT OF COM CIVIL DIVISI Cumberland C MORTGAGE NO. 07-7143 C. PRAECIPE FOR JUDGMENT FOR FAI TO THE PROTHONOTARY: FOR PLAINTIFF PLEAS ty URE Lvil Term TO Kindly enter judgment in favor of the Plai tiff and against the Defendant(s) Kristy M. Bitting for failure to file an Answer to Plaintiff's Complaint within 20 days from serv'ce thereof and for foreclosure and sale of the mortgaged premises, a d assess Plaintiff's damages as follows: As set forth in Complaint $130, 44.66 Interest Per Complaint 9, 91.94 From 11/21/07 to 2/5/09 Late charges per Complaint 29.20 From 11/21/07 to 2/5/09 Escrow payment per Complaint 3 88.15 From 11/21/07 to 2/5/09 TOTAL 4. I hereby certify that (1) the addresses of the P aintiff and Defendant are as shown above, and (2) that notice has been g ven in accordance with Rule 237.1, a copy of which is attached hereto. UDREN LAW OFFICES, P.C. BY At orneys for MARK J. UDREN, STUART WINNEG, LORRAINE DOYLE ALAN M. MINATO CHANDRA M. ARK DAMAGES ARE HEREBY ASSESSED AS DATE : z / L') '06 f INDICATED / "- C PRO PROTHY ESQUIRE ESQUIRE ESQUIRE ESQUIRE MA, ESQUIRE Lt.1 U5 N UDREN LAW OFFICES, P.C. X BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620' 856-669-5400 pleadingeoudren.com Deutsche Bank Trust Company :COURT OF CO Americas (f/k/a Bankers Trust :CIVIL DIVIS Company), as Trustee by Residential Funding Company, :Cumberland LLC f/k/a Residential Funding Corporation, Attorney-in-fact 4828 Loop Central Drive Houston, TX 77081-2226 Plaintiff V. Rristy M. Bitting 205 Willow Mill Park Road Mechancisburg, PA 17050 Defendant(s) NO. COMPLAINT IN MORTGAGE FO YOU HAVE BEEN SUED IN COURT. If you wish to claims set forth in the following pages, you within twenty (20) days after this Complaint and by entering a written appearance personally o filing in writing with the Court your defenses o: claims set forth against you. You are warned t do so the case may proceed without you and entered against you by the Court without furt7 money claimed in the Complaint or for any othe requested by the Plaintiff. You may lose mor other rights important to you. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT 01 HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT H YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFF: PROVIDE YOU WITH INFORMATION ABOUT AGENCIES TE SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE LAWYERS REFERRAL SERVICE Cumberland County Bar Associati 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 FOR PLAINTIFF ? O PLEAS M :. N S ty y> ? _ „ ? ? Y etu??"-7? efend against the must take action. Jotice are served, by attorney and objections to the at if you fail to judgment may be r.notice for any claim or relief ry or property or . IF YOU DO NOT IRTH BELOW. THIS CNG A LAWYER. IF MAY ' BE ABLE TO MAY OFFER LEGAL NO FEE. SHERIFF'S RETURN - REGULARI CASE NO: 2007-07143 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK TRUST COMPANY VS BITTING KRISTY M SHAWN HARRISON , Sheriff or Deput Cumberland County,Pennsylvania, who being duly s says, the within COMPLAINT - MORT FORE was s BITTING KRISTY M Sheriff of rn according to law, upon DEFENDANT , at 1611:00 HOURS, on the 27th da of December 2007 at 205 WILLOW MILL PARK ROAD MECHANICSBURG, PA 17050 by handi g to KRISTY BITTING a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 25.92 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 53.92 12/28/2007 UDREN LAW OFFI Sworn and Subscibed to By: before me this day of , A.D. r the n UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 F]aAnna +dr n nm Deutsche Bank Trust Company Americas (f/k/a Bankers Trust Comany) , s Trustee by Residential Funding Compan , a Residential Funding Corporation, A?tne -in-fact Plaintiff v. e Kristy M. Bitting Defendant(s) TO: Kristy M. Bitting 205 Willow Mill Park Road Mechanicsburg, PA 17050 DATE of Notice: August 21, 2008 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH TH' OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. U] TEN DAYS FROM THE DATE OF THIS NOTICE A JUDGMENT MAY WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR 0' RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT 0 HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYE: AFFORD TO HIRE A LAWYER THIS OFFICE MAY BE ABLE TO P: INFORMATION ABOUT AGENHES THAT MAY OFFER LEGAL SERVIAT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Associati 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA A UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION EL NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR P SENTENCIA EN SU CONTRA USTED PUEDE PERDER BIENES Y 0 IMPORTANTES. DEBE LU' AR ESTA NOTIFICACION A UN ABOG USTED NO TIENE ABOGADO O SI NO TIENE DINERO SUFICIEN VAYA EN PERSONA 0 LLAMb POR TELEFONO A LA OFICINA CU ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Associatii 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTIC' DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT INFORMATION OBTAINED WILL BE USED FOR,„THAT PURPOSE. %7-v-ma[rk -J- Laren, Esquire Stuart Winneg, Esquire Lorraine Doyle, Esquire Alan M. Minato, Esquire Chandra M. Arkema, Esquire Louis A. Simoni, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-36 ATTORNEY FOR PLAINTIFF OF COMMON PLEAS DIVISION land County . 07-7143 Civil Term WRITTEN APPEARANCE COURT YOUR DEFENSES 'LESS YOU ACT WITHIN BE ENTERED AGAINST YOU HER IMPORTANT 'CE. IF YOU DO NOT BELOW. THIS OFFICE IF YOU CANNOT .OVIDE YOU WITH DES TO ELIGIBLE PERSONS MADO LA ACCION ON DEBIDA DENTRO DE IBUNAL PODRA, SIN BA ALGUNA DICTAR S DERECHO?, IMMEDIATAMENTE SI PARA TAL SERVICIO, DIRECCION SE NSEGUIR ASSISTENCIA ACT, THIS LAW FIRM IS 1 COLLECT A DEBT. ANY C cn ? C1 Ci- ` LA.- Y7 cl, C=P Z) f C= A C`J UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank Trust Company Americas (f/k/a Bankers Trust Company), as Trustee by Residential Funding Company, LLC f/k/a Residential Funding Corporation, Attorney-in-fact Plaintiff V. Kristy M. Bitting Defendant(s) I ATTORNEY FOR PLAINTIFF COURT OF CO ON PLEAS CIVIL DIVISI N Cumberland C unty MORTGAGE FOR CLOSURE NO. 07-7143 AFFIDAVIT OF NON-MILITARY S STATE OF NEW JERSEY COUNTY OF CAMDEN THE UNDERSIGNED being duly sworn, deposes averments herein are based upon investigation maintained by us either as Plaintiff or as sex, Plaintiff herein and that the above Defendani Military or Naval Service of the United States of I as defined in the Servicemembers' Civil Relief Aci Stat. 2835; 2003 Enacted H.R. 100), and that the residence and employment of each Defendant are Defendant: Kristy M. Bitting Age: Over 18 Residence: As captioned abov Employment: Unknown /'Z` Sworn to and subscribed before me this 5th day February 2009. N tary Public' Title: ATTOR Company: UDREN vil Term CE nd says that the made and records icing agent of the (s) are not in the nerica or its Allies (108 P.L. 189; 117 age and last known as follows: FOR PLAINTIFF OFFICES, P.C. CARA STEAKS NMP"OFlEWOM + 6fttbPk%10A5=3 C`?3 ff L.C) 7? C CT 'r. LIJ 0: 1 Lt © N UDREN LAW OFFICES, P.C. ATT MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER Ill WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingstudren.com Deutsche Bank Trust Company :COURT OF COW Americas (f/k/a Bankers Trust :CIVIL DIVISI( Company), as Trustee by :Cumberland Cc Residential Funding Company, LLC f/k/a Residential Funding :MORTGAGE FORT Corporation, Attorney-in-fact Plaintiff V. Kristy M. Bitting Defendant(s) FOR PLAINTIFF ('J ti PLEAS w , tY OSURE c? C-) c NO. 07-7143 Civil Term TO: Kristy M. Bitting 205 Willow Mill Park Road Mechanicsburg, PA 17050 NOTICE Pursuant to Rule 236 of the Supreme Court of hereby notified that a Judgment has been ente above proceeding as indicated below. X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbi Judgment on Verdict msylvania, you are against you in the P1 Lary tion Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTI ATTORNEY PLEASE CALL: At this telephone number: 856-669- UDPM LAW OFFICES, P. C. MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQU - ID #04302 - ID #45362 - ID #34576 - ID #75860 LRE - ID #203437 WOODCREST CORPORATE CENTER 11L WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 . pleadinasOudren.com Deutsche Bank Trust Company Americas (f/k/a Bankers Trust Company), as Trustee by Residential Funding Company, LLC f/k/a Residential Funding Corporation, Attorney-in-fact 4828 Loop Central Drive Houston, TX 77081-2226 Plaintiff V. Kristy M. Bitting 205 Willow Mill Park Road Mechanicsburg, PA 17050 Defendant (s) COURT OF CONS CIVIL DIVISh Cumberland G MORTGAGE ATTORNEY FOR PLAINTIFF PLEAS ty CLOSURE NO. 07-7143 Civil Term PRAECIPE FOR JUDGMENT FOR FAILURE TO TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) Kristy M. Bitting for failure to file an Answer to Plaintiff's Complaint within 20 days from se ice thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $13C,544.66 Interest Per Complaint ,091.94 From 11/21/07 to 2/5/09 Late charges per Complaint 529.20 From 11/21/07 to 2/5/09 Escrow payment per Complaint 888.15 From 11/21/07 to 2/5/09 TOTAL 1. I hereby certify that (1) the addresses of the are as shown above, and (2) that notice has been Rule 237.1, a copy of which is attached hereto. UDREN LAW BY At orneys for MARK J. UDREN STUART WINNEG LORRAINE DOYL ALAN M. MINAT CHANDRA M. AR 'laintiff and Defendant iven in accordance with CES, P. C. ESQUIRE ESQUIRE , ESQUIRE , ESQUIRE EMA, ESQUIRE DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE : UDREN LAW OFFICES, P.C. ATTI MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank Trust Company :COURT OF COMM Americas (f/k/a Bankers Trust :CIVIL DIVISIO Company), as Trustee by :Cumberland Co Residential Funding Company, LLC f/k/a Residential Funding :MORTGAGE FORE Corporation, Attorney-in-fact Plaintiff V. Kristy M. Bitting :NO. 07-7143 C Defendant(s) PRAECIPE FOR WRIT OF EXECUT TO THE PROTHONOTARY: FOR PLAINTIFF PLEAS ty vil Term Please issue Writ of Execution in the above matter: Amount due Interest From 2/6/09 to Date of Sale June 10, 2009 Ongoing Per Diem of 20.57 to actual date of sale including if sale i held at a later date (Costs to be added) $ $144,074.52 2,571.25 UDREN LAW OFFICE,,5, P.C. BY• Att r e s MARK J. UD STUART WIN LORRAINE D ALAN M. MI CHANDRA M. f, ESQUIRE ESQUIRE .E, ESQUIRE 0, ESQUIRE ;KEMA, ESQUIRE Lr) {71t LA- ? s e CV c? v 4 Cd s'a O 4 U CJ 0 tis UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 .CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-.5400 .com Deutsche Bank Trust Company Americas (f/k/a Bankers Trust Company), as Trustee by Residential Funding Company, LLC f/k/a Residential Funding Corporation, Attorney-in-fact Plaintiff v. Kristy M. Bitting Defendant(s) ATT RNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE ' NO. 07-7143 Civil Term WRIT OF EXECUTION TO THE SHERIFF OF Cumberland COUNTY: To satisfy the judgment, interest.and cost matter, you are directed to levy upon and sell described property: 205 Willow Mill Park Road Mechanicsburg, PA 17050 SEE LEGAL DESCRIPTION ATTACHED Amount due Interest From 2/6/09 to Date of Sale June 10, 2009 Ongoing Per Diem of 20.57 to actual date of sale including if sale held at a later date (Costs to be added) :s in the above the following $144,074.52 2,571.25 thonotary By erk Date COURT OF COMMON PLEAS NO. 07-7143 Civil Term Deutsche Bank Trust Company Americas (f/k/a Bankers Trust Company), as Trustee by Residential Funding Company, LLC f/k/a Residential Funding Corporation, Attorney-in-fact VS. Kristy M. Bitting WRIT OF EXECUTION REAL DEBT $ 144,074.52 INTEREST $ 2,571.25 from 2/6/09 to Date of Sale June 10, 2009 Ongoing Per Diem of 20.57 to actual date of sale including if sale is held at a later date COSTS PAID: PROTHY $ SHERIFF $ STATUTORY $ COSTS DUE PROTHY. $ PREMISES TO BE SOLD: 205 Willow Mill Park Road M c anicsburg, PA 17050 UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 (856) 669-5400 pleadings@udren.com UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank Trust Company Americas (f/k/a Bankers Trust Company), as Trustee by Residential Funding Company, LLC f/k/a Residential Funding Corporation, Attorney-in-fact Plaintiff V. COURT OF COM CIVIL DIVISI Cumberland C MORTGAGE FORE Kristy M. Bitting €NO. 07-7143 Defendant(s) CERTIFICATE TO THE SHERIFF I HEREBY CERTIFY THAT: FOR PLAINTIFF N PLEAS my LOSURE vil Term I. The judgment entered in the above matter is based n an Action: A. In Assumpsit (Contract) B. In Trespass (Accident) X C. In Mortgage Foreclosure D. On a Note accompanying a purchase mone mortgage and the property being exposed to sale is the ortgaged property. II. The Defendant(s) own the property being exposed to sale as: X A. An individual B. Tenants by Entireties C. Joint Tenants with right of survivo D. A partnership E. Tenants in Common F. A corporation III. The Defendant(s) is (are): X A. Resident in the Commonwealth of Pennsy vania B. Not resident in the Commonwealth of Pe nsylvania C. If more than one Defendant and either or B above is not applicable, state which Defendant is r sident of the Commonwealth of Pennsylvania. Resident: UDREN LAW BY: ( / U, _(/I w Attorneys fo: MARK J. UDRE: STUART WINNER LORRAINE DOY: ALAN M. MINA CHANDRA M. A ICES, P.C. Plaintiff ESQUIRE ESQUIRE E, ESQUIRE D, ESQUIRE KEMA, ESQUIRE ?.. ,?' ?; ? ?? c `? LL. L77Lr ? I-, ? + ? l t.. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank Trust Company :COURT OF COMMON PLEAS Americas (f/k/a Bankers Trust :CIVIL DIVISIO Company), as Trustee by :Cumberland Co my Residential Funding Company, LLC f/k/a Residential Funding :MORTGAGE FORE LOSURE Corporation, Attorney-in-fact Plaintiff V. Kristy M. Bitting ::NO. 07-7143 C'vil Term Defendant (s) C E R T I F I C A T E I hereby state that as the attorney for above-captioned matter and that the premises the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( X ) Act 91 procedures have bee ( ) Over 24 months delinquent. Plaintiff in the not subject to fulfilled. This certification is made subject to the Penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. By. Attorneys fo MARK J. UDRE: STUART WINNE, LORRAINE DOY: ALAN M. MINA' CHANDRA M. A Plaintiff ESQUIRE ESQUIRE E, ESQUIRE O, ESQUIRE KEMA, ESQUIRE s... ION Ci- ml L` Y y LU cn . lS.. ? _) L? N 4? f UDREN LAW OFFICES, P.C. ATT RNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank Trust Company :COURT OF COMM N PLEAS Americas (f/k/a Bankers Trust :CIVIL DIVISIO Company), as Trustee by :Cumberland Co my Residential Funding Company, LLC f/k/a Residential Funding :MORTGAGE FORE LOSURE Corporation, Attorney-in-fact Plaintiff V. Kristy M. Bitting :NO. 07-7143 C'vil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 312$.1 Deutsche Bank Trust Company Americas (f/k/a Ba Company), as Trustee by Residential Funding Co Residential Funding Corporation, Attorney-in-f the above action, by its attorney, Mark J. Udr forth as of the date the Praecipe for the Writ filed the following information concerning the located at: 205 Willow Mill Park Road, Mechan 1. Name and address of Owner(s) or reputed Name Address Kristy M. Bitting 205 Willow Mill Mechanicsburg, P 2. Name and address of Defendant(s) in the jud Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor a record lien on the real property to be sold: Name Address ers Trust any, LLC f/k/a t, Plaintiff in ESQ., sets f Execution was eal property sburg, PA 17050 (s) : rk Road 17050 t: se judgment is None j 4. Name and address of the last recorded holder of every mortgage of record: Name Address Deutsche Bank 4828 Loop Centra Drive Trust Company Americas Houston,.TX 7708 -2226 (f/k/a Bankers Trust Company), as Trustee by Residential Funding Company, LLC f/k/a Residential Funding Corporation, Attorney-in-fact 5. Name and address of on the property: Name None Address 6. Name and address of every other person who as any record interest in the property and whose interest ma be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Sq. Carlisle, PA 170,3 Domestic Relations Section 13 N. Hanover St. Carlisle, PA 170 3 Commonwealth of PA, Bureau of Compli nce, PO Box 281230 Department of Revenue Harrisburg, PA 1 128-1230 7. Name and address of every other person of w om the plaintiff has knowledge who has any interest in the prop rty which may be affected by the sale: Name Address Tenants/Occupants 205 Willow Mill P rk Road Mechanicsburg, P 17050 I verify that the statements made in this affid vit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements her in are made subject to the penalties of 18 Pa.C.S. sec. 490 relating to unsworn falsification to authorities. DATED: February 5, 2009 N BY : U ((/1 Attorneys fo MARK J. UDRE: STUART WINNE LORRAINE DOY ALAN M. MINA CHANDRA M. A every other person who 4as any record lien CES, P. C. Plaintiff ESQUIRE ESQUIRE E, ESQUIRE 0, ESQUIRE KEMA, ESQUIRE C_ u l j r.1_ L.L._ CI-4 0 I UDREX LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF 14ARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 ]?ORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 C'HANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank Trust Company :COURT OF CO N PLEAS Americas (f/k/a Bankers Trust :CIVIL DIVISIO Company), as Trustee by :Cumberland Co my Residential Funding Company, LLC f/k/a Residential Funding Corporation, Attorney-in-fact :NO. 07-7143 C'vil Term Plaintiff V. Kristy M. Bitting Defendant(s) TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Kristy M. Bitting PROPERTY: 205 Willow Mill Park Road, Mechanicsburg, PA 17050 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled t be sold at the Cumberland County Sheriff's Sale on June 10, 2009, at 10:00 A.M., at the Commissioners Hearing Room, 2nd Floor, Co rthouse, Carlisle, PA. Our records indicate that you may hold a m rtgage or judgment on the property which will be extinguished by he sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with t e schedule unless exceptions are filed thereto within 10 days afte the filing of the schedule. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank Trust Company 'COURT OF COMM N PLEAS Americas (f/k/a Bankers Trust `CIVIL DIVISIO Company), as Trustee by :Cumberland Co my Residential Funding Company, LLC f/k/a Residential Funding :MORTGAGE FORE LOSURE Corporation, Attorney-in-fact Plaintiff V. Kristy M. Bitting :NO. 07-7143 C vil Term Defendant(s) TO: Kristy M. Bitting 205 willow Mill Park Road Mechanicsburg, PA 17050 Your house (real estate) at 205 Willow Mill Pa: Mechanicsburg, PA 17050 is scheduled to be soli Sale on June 10, 2009, at 10:00 A.M. in the Coi Room, 2nd Floor, Courthouse, Carlisle, PA, to judgment of $144,074.52, obtained by Plaintiff mortgagee) against you. If the sale is postpo: will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take k Road at the Sheriff's issioners Hearing force the court bove (the d, the property 1. The sale will be cancelled if you pay to the mortg gee the back payment, late charges, costs and reasonable attorney's fees To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petit'on asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale fo good cause. 3. You may also be able to stop the sale through othe legal proceedings. You may need an attorney to assert your rights. T e sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid y calling 856-669- 5400. 2. You may be able to petition the Court to se aside the sale if the bid price was grossly inadequate compared to the value f your property. 3. The sale will go through only if the buyer ays the Sheriff the full amount due in the sale. To find out if this has h ppened, you may call 856-669-5400. 4. If the amount due from the Buyer is not pai to the Sheriff, you will remain the owner of the property as if the sale ne er happened. 5. You have the right to remain in the propert until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict yo . 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bi for your house will be filed by the Sheriff within 30 days after the sale. his schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reason why the proposed distribution is wrong) are filed with the Sheriff withi ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF Y LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFI FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 DO NOT HAVE A LISTED BELOW TO L LO -? ' c LLJ ` LL I ??i f LA- Li- c-..? C-4 ALL THAT CERTAN tract of land with the improvpments thereon erected, situate on thi Willow Nil Park Drive, Silver Spring Township, Cumberlortd County, 0amsylvenia, being No. 58 "Willow Mill Park" recorded in..Plan Book 3, Page 7, bounded and described in acxx>rc Survey by WhiNack and Hartman, dated May 7, 1981 and bearing File ko. WM41-41 N: B. to exit: BEGINNING at an Iron pin on the southeast side of Willow Milt Park Drive (30 foot wide right of Lot No. 59 of the above mentioned Plan of Lots, said point being 51.71 feet east of the Willow Mil Park Drive' and a 20 foot wide right of way; thence extending from said boom Willow Mill Park Drive, South 77 degrees 23 minutes 00 seconds East 103A2 feet to an k No. 58 of the above mentioned Plan of Lots; thence esclsndkhg along same South 2 doge seconds East 96.67 feet to an iron pin found at-property now or fonmeriy of,Aldie Stiller; thei some and along Lot No. 95, South 96 degrees 07 minutes 53 ownds West 100.04 feet (shr South 87 degrees 60 minutes 00 seconds West 100.00 feet) to an hW pin at Lot No. 58 afar extending along same North 2 degrees 10 minutes 00 seconds West 126.03 feel to the firs) and place of BEGINNING. Parcel #38-16-1072-008 BEING KNOWN AS: 205 Willow Mill Park Road 17050 PROPERTY ID NO.: 38-16-1072-008 TITLE TO SAID PREMISES IS VESTED IN KRISTY M. WOMAN BY DEED FROM JEREMIAH J. DEARDORFF AND KR JOINT TENANTS WITH RIGHT OF SURVIVORSHIP DATES 3/24/2004 IN DEED BOOK 262 PAGE 878. southeast side of ot No. 57 and Lot trice with a Plan d lo. on, as follows, of way) at a comer southeast corner of 19 point and along m On found at Lot bus 10 minutes 00 ce extending along wn in prior dead as imentioned; thence mentioned Iron pin Mechanicsburg, PA BITTING, A SINGLE STY M. BITTING, AS. 3/8/2004 RECORDED WRIT OF EXECUTION and/or ATTACHMENTI COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N007-71 Civil L ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK TRUST Plaintiff (s) From KRISTY M. BITTING (1) You are directed to levy upon the property of the defendant (s)and to sell DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the ga paying any debt to or for the account of the defendant (s) and from delivering a (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is of anyone other than a named garnishee, you are directed to notify him/her that garnishee and is enjoined as above stated. Amount Due$144,074.52 L.L.$.50 Interest FROM 2/6/09 TO DATE OF SALE JUNE 10, 2009 - ONGOING ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LAT Atty's Comm % Due Prothy $2.00 Atty Paid $172.92 Other Costs Plaintiff Paid Date: FEBRAURY 9, 2009 PANY AMERICAS E LEGAL in the possession shee(s) is enjoined from property of the defendant in the possession has been added as a R DIEM OF $20.57 TO DATE - $2,571.25 Long, (Seal) REQUESTING PARTY: Name CHANDRA M. ARKEMA, ESQ. Address: UDREN LAW OFFICES, P.C., 111 WOODCREST ROAD, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 203437 By: ,200, CHERRY HILL, UDREN,LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF DARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKENA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank Trust Company COURT OF COMMON PLEAS Americas (f/k/a Bankers Trust :CIVIL DIVISION Company), as Trustee by € Cumberland County Residential Funding Company, LLC f/k/a Residential Funding Corporation, Attorney-in-fact Plaintiff V. Kristy M. Bitting NO. 07-7143 Civil Term Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by order of Court, then proof of compliance with said order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: April 15, 2009 UDREN LAW OFFICES, P.C. ( Attorneys f r laintiff MARK J. UDR ESQUIRE STUART WINNEG, LORRAINE DOYLE; ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank Trust Company :COURT OF COMMON PLEAS Americas (f/k/a Bankers Trust :CIVIL DIVISION Company), as Trustee by :Cumberland County Residential Funding Company, LLC f/k/a Residential.Funding :MORTGAGE FORECLOSURE Corporation,. Attorney-in-fact Plaintiff V. Kristy M. Bitting ::NO. 07-7143 Civil Term Defendant(s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Deutsche Bank Trust Company Americas (f/k/a Bankers Trust Company), as Trustee by Residential Funding Company, LLC f/k/a Residential Funding Corporation, Attorney-in-fact, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 205 Willow Mill Park Road, Mechanicsburg, PA 17050 1. Name and address of Owner(s) or reputed Owner(s): Name Address Kristy M. Bitting 205 Willow Mill Park Road Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Penn Waste, Inc. P.O. Box 3066 88 Brickyard Road, York, PA 17402 4. Name and address of the last recorded holder of every mortgage of record: Name Address Deutsche Bank 4828 Loop Central Drive Trust Company Americas Houston, TX 77081-2226 (f/k/a Bankers Trust Company), as Trustee by Residential Funding Company, LLC f/k/a Residential Funding Corporation, Attorney-in-fact 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Sq., Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue 13 N. Hanover St. Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 205 Willow Mill Park Road Mechanicsburg, PA 17050 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: April 15, 2009 UDREN LAW OF ES, P.C. Y: At e s for P intiff MARK J. MR-EN, E SQUIR2' STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE -1D #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank Trust Company Americas COURT OF COMMON PLEAS (f/k/a Bankers Trust Company), as € CIVIL DIVISION Trustee by Residential Funding = Cumberland County Company, LLC f/k/a Residential Funding Corporation, Attorney-in-fact Plaintiff € NO. 07-7143 Civil Term V. Kristy M. Bitting Defendant(s) TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Kristy M. Bitting PROPERTY: 205 Willow Mill Park Road, Mechanicsburg, PA 17050 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on June 10. 2009, at 10:00 A.M., at the Commissioners Hearing Room, 2ND Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EMIS1TA ay v+ co o 'U W ? o t!1 c. Z o n 6c o QQ m m 4 n W W m } W c to ono o w i o z W W C o O ' n m ? ? ? v ? t ? 3 o lk m m ? ? 3 0 3 im O O ? Q - 0- O N '? m t D Nj < ® ? m O ?_• w a 3.? a m ? G O N - - , O O tNT O ry W m V `$ m . „ mm ? 33 ? n gwC ?,2 a 7 m m Ot NO?K m v 3 c ? ? 7 m g R ? N C O O Q O g'm 5 ? -5s p1 lfa? m' we X. 7 ?, u` 7 G w?o$3 1. o m o 1.3 ?- $ oQQ 0 ? ? d U w c ? m m z r_. p p N a N CD ¢ y 7 L ? fD ? i .D? w O??Ov? moc?o ??y0OR'i 'Z Y? "0 C, N O W ? ? om?pi n p C ?? g-vN?c C)- o v+ 9 O p` ? o I y O U d ?3t18t2??9 vatted Fro c O800r ` AG a... C s )0G m i cc m LG p 0 O ? n a CA ry .r O % (P r Z0 10 c2 n Z?5 T. n q? Co c n m o°d N to "' m 9 v c. ? ? C -t7 w -1 Worm y '? m? Wm? ? o m 7 2 ?D D H b ow?mo ? p pp 3 -o N N pp ?? 9 ? NG W °-?? m W r n o "It C3 VE% (D 0 3Zr o „ C.. C r1 7 ` •?N•- y Wr 4 f D N n y a ?9 a 9 D NC T ;D :L3 y a T cn W 3 N I N .Q T W C• c o? .n 0 3 0 ? W N 40) w urpi ? ? ? W N ?? 0. O m cao m ?. o v, m cb' ? z cx .01 z m a M 47 b m R= ?38?2 3. o o. Aa3j >> m wN U H US o ? 8' m Q3 3 ? a pg? W . a6'k- -°C R' R !"n?s 99-'o?"R c R ? o m0A W 3, N 3 j ail a m _d m Oo?m i N og??w3 d3R 2? O ? N ?_ y 3d d m ? n w N ryj l?4 D n m N °p ?.?u ov o J? g N m ? O CID O O? ?y i 016H26519216 a $01.100 03125!2009 = Mailed From 08003 US poSTAGE 7-1 1 to a =gym a? m CDa o ? W -' rn no -0 'a O 60 CD 0 > ? G 7r°?p? ° p iOm w z ? my nZ ? D•< X ? _ m l -c n 4:h CD ? -4 NO n N ? r M ?o? m w to Coto- CL C '? (3 m• 0 a o a CL m 0 0? n ? y C) ro a a N W 00 0 rn ? 7 N co N ? W L ?. ? o C3 cl ;0 1 H W 91 N f~D C tT G 7 }?. ag ? ? o c 2n ,?. ?? m 3 CL c7D ??pp W N (p X1 y 3 0 G N ??pp T r!J ?_ d tQ Q N cN N mS N N N ;? ,Zr F1LFG[ CE- ° STAY c P77-:7 :; 2 10L9 M,AY -- Ii F M 2* ?, 3 In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2007-7143 Civil Term Deutsche Bank Trust Company Americas (f/k/a Bankers Trust Company) as Trustee by Residential Funding Company, LLC f/k/a Residential Funding Corporation Attorney- in- Fact Vs Kristy M. Bitting Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on February 21, 2009 at 1301 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: Kristy M. Bitting, by making known unto Kristy M. Biting, personally, at, 205 Willow Mill Park Road, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on April 4, 2009 at 0803 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Kristy M. Bitting, located at, 205 Willow Mill Park Road, 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: Kristy M. Bitting, by regular mail to her last known address of, 205 Willow Mill Park Road, Mechanicsburg, PA 17013. This letter was mailed under the date of April 6, 2009 and never returned to the Sheriffs Office R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Docketing 30.00 Poundage 18.88 Posting Bills 15.00 Advertising 15.00 Law Library .50 Prothonotary 2.00 Milage 18.00 Levy 15.00 Surcharge 20.00 Law Journal 419.00 Patriot News 354.06 Share of Bills 15.43 Post Pone Sale So Aiisw .S" R. Thomas Kline, Sheriff By Real Estate Coordinator F(i ELF-D ,E or- 40.00 962.87 2009 0C*T 12 A MI 11: 12 a „-v f" ck-I 7,z y3/ r UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. VDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank Trust Company :COURT OF COMMON PLEAS Americas (f/k/a Bankers Trust 'CIVIL DIVISION Company), as Trustee by =Cumberland County Residential Funding Company, LLC f/k/a Residential Funding :MORTGAGE FORECLOSURE Corporation, Attorney-in-fact Plaintiff V. Kristy M. Bitting NO. 07-7143 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Deutsche Bank Trust Company Americas (f/k/a Bankers Trust Company), as Trustee by Residential Funding Company, LLC f/k/a Residential Funding Corporation, Attorney-in-fact, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ.of Execution was filed the following information concerning the real property located at: 205 Willow Mill Park Road, Mechanicsburg, PA 17050 1. Name and address of Owner(s) or reputed Owner(s): Name Address Kristy M. Bitting 205 Willow Mill Park Road Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of of record: Name Address Deutsche Bank 4828 Loop central Drive Trust Company Americas Houston,.TX 77081-2226 (f/k/a Bankers Trust Company), as Trustee by Residential Funding Company, LLC f/k/a Residential Funding Corporation, Attorney-in-fact 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Sq., Carlisle, PA 17013 13 N. Hanover St. Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 205 Willow Mill Park Road Mechanicsburg, PA 17050 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: February 5, 2009 UDREr?LAW ,OFFICES, PPJ.C. Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE the last recorded holder of every mortgage MRIEN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J.-UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank Trust Company :COURT OF COMMON PLEAS Americas (f/k/a Bankers Trust ;CIVIL DIVISION Company), as Trustee by :Cumberland County Residential Funding Company, LLC f/k/a Residential Funding :MORTGAGE FORECLOSURE Corporation, Attorney-in-fact Plaintiff V. Kristy M. Bitting :NO. 07-7143 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Kristy M. Bitting 205 Willow Mill Park Road Mechanicsburg, PA 17050 Your house (real estate) at 205 Willow Mill Park Road Mechanicsburg, PA 17050 is scheduled to be sold at the Sheriff's Sale on June 10, 2009, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $144,074.52, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ALL THAT CERTAIN tract of land with the knpmvpmenls thereon erected, Bit ate on the southeast skit of Willow mil Park Drove, Sliver Spring Township, Cumberlend County, Pennsytvanla, being Lot No. 57 and Lot No. 58 "Willow Milt Park' recorded in Plan Book 3, Page 7, bounded and described in accordance with a Plan of Survey by Whitlock and Hartman, dated May 7, 1981 and beefing Fit No. WM-81-41 N. B. No. 686, as follows, to writ: BEGINNING at an iron pin on the southeast We of Willow MI Park Drive (30 foot wide right of way) at a comer of Lot No. 59 of the above mentioned Plan of Lots, said point being 51.71 feet east of the southeast comer of Willow Mitt Park Drive and a 20 foot wide right of way; thence extending from said begiming point and along Willow Mill Perk Drive, South 77 degrees 23 minutes 00 seconds East 103A2 feet to an iron pin found at Lot No. 56 of the above mentioned Plan of Lots; thence exttnding along same South 2 degrees 10 minutes 00 seconds East 96.67 feet to an Iron pin found at property now or formerly of Aldle Stiller. thence extending along some and along Lot No. 95, South 96 degrees 07 minutes 53 seconds West 100.04 feat (shown in prior dead as South 87 degrees 50 minutes 00 seconds West 100.00 feet) to an kon pin at Lot No. 59 aforementioned; thence extending along same North 2 degrees 10 minutes 00 seconds West 126.03 feel to the first mentioned Iron pin and place of BEGINNING. Parcel #38-16-1072-008 BEING KNOWN AS: 205 Willow Mill Park Road, Mechanicsburg, PA 17050 PROPERTY ID NO.: 38-16-1072-008 TITLE TO SAID PREMISES IS VESTED IN KRISTY M. BITTING, A SINGLE WOMAN BY DEED FROM JEREMIAH J. DEARDORFF AND KRISTY M. BITTING, AS JOINT TENANTS WITH RIGHT OF SURVIVORSHIP DATED 3/8/2004 RECORDED 3/24/2004 IN DEED BOOK 262 PAGE 878. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N007-7143 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK TRUST COMPANY AMERICAS Plaintiff (s) From KRISTY M. BITTING (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$144,074.52 L.L.$.50 Interest FROM 2/6/09 TO DATE OF SALE JUNE 10, 2009 - ONGOING PER DIEM OF $20.57 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $2,571.25 Atty's Comm % Arty Paid $172.92 Plaintiff Paid Due Prothy $2.00 Other Costs Date: FEBRAURY 9, 2009 (Seal) Curti R. Long, Pr notary By: Deputy REQUESTING PARTY: Name CHANDRA M. ARKEMA, ESQ. Address: UDREN LAW OFFICES, P.C., 111 WOODCREST ROAD, SUITE 200, CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 203437 -t Real Estate Sale # 33 On February 12, 2009 the Sheriff levied upon the defendant's interest in the real property situated in Silver Spring Township, Cumberland County, PA Known and numbered as 205 Willow Mill Park Road Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 12, 2009 ' &oS4-L- b I Z d Z i 93J 600Z 0 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: May 1, May 8, and May 15, 2009 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place ai d character of publication are true. is Marie Coyne, Edito SWO TO AND SUBSCRIBED before me this 15 day of May. 2009 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 REAL ESTATE SALE NO. 33 Writ No. 2007-7143 Civil Deutsche Bank Trust Company Americas (f/k/a Bankers Trust Company) as Trustee by Residential Funding Company LLC f/k/a Residential Punding Corporation, Attorney-in-fact vs. Kristy M. Bitting Atty.: Chandra M. Arkema ALL THAT CERTAIN tract of land with the improvements thereon erect- ed, situate on the southeast side of Willow Mill Park Drive, Silver Spring Township, Cumberland County, Pennsylvania, being Lot No. 57 and Lot No. 58 "Willow Mill Park" recorded in Plan Book 3, Page 7, bounded and described in accordance with a Plan of Survey by Whittock and Hartman, dated May 7, 1981 and bearing File No. WM-81-41 N. B. No. 686, as fol- lows, to wit: BEGINNING at an iron pin on the southeast side of Willow Mill Park Drive (30 foot wide right of way) at a corner of Lot No. 59 of the above mentioned Plan of Lots, said point being 51.71 feet east of the southeast comer of Willow Mill Park Drive and a 20 foot wide right of way; thence extending from said beginning point and along Willow Mill Park Drive, South 77 degrees 23 minutes 00 seconds East 103.42 feet to an iron pin found at Lot No. 56 of the above mentioned Plan of Lots; thence ex- tending along same South 2 degrees 10 minutes 00 seconds East 96.67 feet to an iron pin found at prop- erty now or formerly of Aldie Stiffer; thence extending along same and along Lot No. 95, South 96 degrees 07 minutes 53 seconds West 100.04 feet (shown in prior deed as South 87 degrees 50 minutes 00 seconds West 100.00 feet) to an iron pin at Lot No. 59 aforementioned; thence extending along same North 2 degrees 10 min- utes 00 seconds West 126.03 feet to the first mentioned iron pin and place of BEGINNING. Parcel #38-16-1072-008. BEING KNOWN AS: 205 Willow Mill Park Road, Mechanicsburg, PA 17050. PROPERTY ID NO.: 38-16-1072- 008. TITLE TO SAID PREMISES IS VESTED IN Kristy M. Bitting, a single woman by deed from Jeremiah J. Deardorff' and Kristy M. Bitting, as joint tenants with right of survivor- ship dated 3/8/2004 recorded 3/ 24/2004 in Deed Book 262 Page 878. The Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 the Patr1*otwXtws Now you know 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 sworn 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: 04/24/09 05/01/09 05/08/09 to and cribed before met s d y of May, 2009 A.D. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seel Sherrie L- Kisner, Notary PL4*0 E*h16 kw. 25.2(M I ?pw, Penwvania ASSOdWOn of Notarles Real Estate Sale No. 33 Writ No. 2007-7143 Civil Term Deutsche Bank Trust Company Americas (f/k/a Bankers Trust Company), as Trustee by Residential Funding Company LLC MIA Residential Funding Corporation, Attorney-In-fact VS Kristy M. Bitting Attorney Chandra M. Arkema LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected, situate on the southeast side of Willow Mill Park Drive, Silver Spring Township, Cumberland County, Pennsylvania, being Lot No. 57 and Lot No. 58 "Willow Mill Park" recorded in Plan Book 3, Page 7, bounded and described in accordance with a Plan of Survey by Whittock and Hartman, dated May 7, 1981 and bearing File No. WM- 8141 N. B. No. 686, as follows to wit: BEGINNING at an iron pin on the southeast side of Willow Mill Park Drive (30 foot wide right of way) at a comer of Lot No. 59 of the above mentioned Plan of Lots, said point being 51.71 feet east of the southeast comer of Willow Mill Park Drive and a 20 foot wide dghkof way; thence extending from said beginning point and along Willow Mill Park Drive, South 77 degrees 23 minutes 00 seconds East 103.42 feet to an iron pin found at Lot No. 58 of the above mentioned Plan of Lots; thence extending along same South 2 degrees 10 minutes 00 seconds East %.67 feet to an iron pin found at property now or formerly of Aldie Stifler; thence extending along the same and along Lot No. 95, South % degrees 07 minutes 53 seconds West 100.04 feet (shown in prior deed as South 87 degrees 50 minutes 00 seconds West 100.00 feet) to an iron pin at Lot No. 59 aforementioned; thence extending along same North 2 degrees 10 minutes 00 seconds West 126.03 feet to the first mentioned iron pin and place of BEGINNING. Pacel # 38-16-1072-008 BEING KNOWN AS: 205 Willow Mill Park Road, Mechanicsburg, PA 17050 PROPERTY ID NO.: 38-16-1072-008 TITLE TO SAID PREMISES IS VESTED'IN KRISTY M. BITTING, A SINGLE WOMAN BY DEED FROM JEREMIAH J. DEARDORFF AND KRISTY M. BITTING, AS JOINT TENANTS WITH RIGHT OF SURVIVORSHIP DATED 3/8/2004 RECORDED 3/24/2004 IN DEED BOOK 262 PAGE 878. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM KAYES, ESQUIRE - ID #86408 MARGUERITE THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank Trust Company :COURT OF COMMON PLEAS Americas (f/k/a Bankers Trust :CIVIL DIVISION Company), as Trustee by ::Cumberland County Residential Funding Company, LLC f/k/a Residential Funding Corporation, Attorney-in-fact NO. 07-7143 Civil Term 4828 Loop Central Drive Houston, TX 77081-2226 Plaintiff V. Kristy M. Bitting 205 Willow Mill Park Road Mechanicsburg, PA 17050 Defendant(s) SUGGESTION OF BANKRUPTCY To the Prothonotary: Kindly note on the record that the above Defendant, Kristy M. Bitting has filed Chapter 13 Bankruptcy in the Middle District of Pennsylvania on July 31st 2009, Bankruptcy Case No. 09-05942. UDREN LA4j OFFICES,/P.C. BY: Attorneys for P& n 'ff MARK J. UDREN, E Q RE STUART WINNEG, E UIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM KAYES, ESQUIRE MARGUERITE THOMAS, ESQUIRE RLED-FICF OF THE PROTHONOTARY 2009 OCT 29 PM 3= 2 ! PEN SYWAN A UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com ATTORNEY FOR PLAINTIFF Deutsche Bank Trust Company :COURT OF COMMON PLEAS Americas (f/k/a Bankers Trust :CIVIL DIVISION Company), as Trustee by :Cumberland County Residential Funding Company, LLC f/k/a Residential Funding :MORTGAGE FORECLOSURE Corporation, Attorney-in-fact Plaintiff V. Zdr± -n - W n7 - _.• N CD Kristy M. Bitting :NO. 07-7143 Civil Term Defendant(s) PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due $144,074.52 Interest From 2/6/09 9,914.74 to Date of Sale June 2, 2010 Ongoing Per Diem of 20.57 to actual date of sale including if sale is held at a later date (Costs to be added) 6 Qo P D 11"y 63.4 C8F ?s. 5D .. 4.00 " M.oo 1,157. 09 P6 AM UDR N QJr'E4CES , P. c. BY: Attorney-4-Loe Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE .-3. S A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE U.00 buE co ?j2?'a.3 IO5 IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: Kristy Michelle Bitting, Debtor(s) CHAPTER 7 CASE NO. 1-09-bk-05942-MDF Litton Loan Servicing as Servicer for Deutsche Bank Trust Company Americas, as Trustee, for certificate holders of Bear Stearns Asset Backed Securities, Inc. Asset Backed Certificates, Series 2004-QS8., Movant, VS. Kristy Michelle Bitting, Leon P. Haller Trustee Respondent. ORDER GRANTING MOTION FOR RELIEF FROM AUTOMATIC STAY Upon consideration of the Motion of Litton Loan Servicing as Servicer for Deutsche Bank Trust Company Americas, as Trustee, for certificate holders of Bear Stearns Asset Backed Securities, Inc. Asset Backed Certificates, Series 2004-QS8. for Relief from Automatic Stay, it is hereby ORDERED AND DECREED THAT: The 11 U.S.C. §362 Automatic Stay is hereby modified with respect to premises: 205 Willow Mill Park Road Mechanicsburg, PA 17050 as to allow the Movant to foreclose on its mortgage and allow the purchaser of said premises at Sheriffs Sale (or purchaser's assignee) to take any legal action for enforcement of its right to possession of said premises; and it is further ORDERED THAT: The relief granted by this order shall survive the conversion of this Case 1:09-bk-05942-MDF Doc 46 Filed 01/05/10 Entered 01/05/10 10:43:08 Desc Main Document Page 1 of 2 bankruptcy case to a case under any other Chapter of the Bankruptcy Code; and it is further ORDERED THAT: The relief granted by this order shall be effective immediately and shall not be subject to the ten day period set forth in Bankruptcy Rule 4001(a)(3). III the C Court. APe= tl hr- rkwum,w) 1% ?TisT `te axGf Rt?? xt tr.P?? r?ruJ fidi1d W ttur crr r?? d ar Dated: January 5, 2010 Case 1:09-bk-05942-MDF Doc 46 Filed 01/05/10 Entered 01/05/10 10:43:08 Desc Main Document Page 2 of 2 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank Trust Company :COURT OF COMMON PLEAS Americas (f/k/a Bankers Trust :CIVIL DIVISION Company), as Trustee by :Cumberland County Residential Funding Company, LLC f/k/a Residential Funding :MORTGAGE FORECLOSURE C? ° -+-? _ n - N t3 n-y rn tfr Corporation, Attorney-in-fact Plaintiff V. Kristy M. Bitting NO. 07-7143 Civil Term Defendant(s) CERTIFICATE TO THE SHERIFF I HEREBY CERTIFY THAT: I. The judgment entered in the above matter is based on an Action: A. In Assumpsit (Contract) B. In Trespass (Accident) X C. In Mortgage Foreclosure D. On a Note accompanying a purchase money mortgage and the property being exposed to sale is the mortgaged property. Ii. The Defendant(s) own the property being exposed to sale as: X A. An individual B. Tenants by Entireties C. Joint Tenants with right of survivorship D. A partnership E. Tenants in Common F. A corporation III. The Defendant(s) is (are): X A. Resident in the Commonwealth of Pennsylvania B. Not resident in the Commonwealth of Pennsylvania C. If more than one Defendant and either A or B above is not applicable, state which Defendant is resident of the Commonwealth of Pennsylvania. Resident: UD EN CES, P.C. BY: AttornWr Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE -- @ S A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE UDREN LAW OFFICES, P.C. ATTORNEY MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 WOODCREST CORPORATE CENTER FOR PLAINTIFF 111 WOODCREST ROAD, SUITE 200 C? CHERRY HILL, NJ 08003-3620 Fc 856-669-5400 pleadings@udren.com Deutsche Bank Trust Company :COURT OF COMMON PLEAS°~'_- Americas (f/k/a Bankers Trust :CIVIL DIVISION Company), as Trustee by :Cumberland County `?-- Residential Funding Company, LLC f/k/a Residential Funding :MORTGAGE FORECLOSURE Corporation, Attorney-in-fact Plaintiff V. Kristy M. Bitting ':NO. 07-7143 Civil Term Defendant (s) C E R T I F I C A T E N 0 -n rn N N ct: La rn I hereby state that as the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: An FHA insured mortgage Non-owner occupied Vacant ( X ) Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDR N L E' ES, P. C. BY: Attotifo Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE --E ' S A. S IMONI , ESQUIRE ADAM L. KAYES, ESQUIRE UDREN LAW OFFICES, P.C. ATTORNEY MARK J. UDREN, ESQUIRE - ID #04302 y STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com FOR PLAINTIFF Deutsche Bank Trust Company ;COURT OF COMMON PLEAS Americas (f/k/a Bankers Trust :CIVIL DIVISION Company), as Trustee by :Cumberland County Residential Funding Company, LLC f/k/a Residential Funding :MORTGAGE FORECLOSURE Corporation, Attorney-in-fact Plaintiff V. Kristy M. Bitting :NO. 07-7143 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 N _ C o ' ?. .., , M , - N 0 ? ,y 4-M Deutsche Bank Trust Company Americas (f/k/a Bankers Trust Company), as Trustee by Residential Funding Company, LLC f/k/a Residential Funding Corporation, Attorney-in-fact, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 205 Willow Mill Park Road, Mechanicsburg, PA 17050 1. Name and address of Owner(s) or reputed Owner(s): Name Address Kristy M. Bitting 205 Willow Mill Park Road Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Penn Waste, Inc. PO Box 3066 88 Brickyard Rd. York, PA 17402 4. Name and address of the last recorded holder of every mortgage of record: Name Address Deutsche Bank 4828 Loop Central Drive Trust Company Americas Houston, TX 77081-2226 (f/k/a Bankers Trust Company), as Trustee by Residential Funding Company, LLC f/k/a Residential Funding Corporation, Attorney-in-fact 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Sq., Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue 13 N. Hanover St. Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 205 Willow Mill Park Road Mechanicsburg, PA 17050 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: January 21, 2010 UDRE LA ?F,)c, P. C. BY: Atto for aintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE -4y6i&IS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank Trust Company :COURT OF COMMON PLEAS Americas (f/k/a Bankers Trust :CIVIL DIVISION Company), as Trustee by :Cumberland County Residential Funding Company, LLC f/k/a Residential Funding :MORTGAGE FORECLOSURE Corporation, Attorney-in-fact Plaintiff V. Kristy M. Bitting :NO. 07-7143 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Kristy M. Bitting 205 Willow Mill Park Road Mechanicsburg, PA 17050 Your house (real estate) at 205 Willow Mill Park Road Mechanicsburg, PA 17050 is scheduled to be sold at the Sheriff's Sale on June 2, 2010, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $144,074.52, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause: 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-7143 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK TRUST COMPANY AMERICAS (f/k/a BANKERS TRUST COMPANY), as Trustee by RESIDENTIAL FUNDING COMPANY, LLC f/k/a RESIDENTIAL FUNDING CORPORATION, Plaintiff (s) From KRISTY M. BITTING (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 $144,074.52 L.L. Interest from 2/6/09 to 6/2/10 - ongoing per diem of $20.57 to actual date of sale including if sale is held at a later date -- $9,914.74 Atty's Comm % Due Prothy $2.00 Atty Paid $1,157.29 Other Costs Plaintiff Paid Date: 2/11/10 David D. Buell, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: LOUIS A. SIMONI, ESQUIRE Address: UDREN LAW OFFICES, PC WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 200869 FILE UDREN LAW OFFICES, P.C. ATTORNEY 'F'OR PIA, IFF MARK J. UDREN, ESQUIRE - ID #04302 Ze?Q§s A;' F'i ?? .9 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ;Y. v,, ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadings@udren.com Deutsche Bank Trust Company ;COURT OF COMMON PLEAS Americas (f/k/a Bankers Trust ;CIVIL DIVISION Company), as Trustee by :Cumberland County Residential Funding Company, LLC f/k/a Residential Funding Corporation, Attorney-in-fact :NO. 07-7143 Civil Term Plaintiff V. Kristy M. Bitting Defendant(s) MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, moves this Honorable Court for an order directing service of the Notice of Sale upon Defendant(s), Kristy M Bitting by regular mail and certified mail, and by posting the mortgaged premises and in support thereof avers the following: 1. Process was unable to be served at the then last known address of said Defendant(s) at 205 Willow Mill Park Road Mechanicsburg, PA 17050, which is the mortgaged premises. A copy of the Return of Service is attached hereto as Exhibit "A". 2. Pursuant to Pa.R.C.P. 430, Plaintiff made a Good Faith Investigation, the report thereof being attached hereto as Exhibit 11 g 11 . 3. Said investigation was unable to determine an alternate address for said Defendant(s). 4. The last known address of Defendant(s) is as set forth in the attached Exhibits. WHEREFORE, Plaintiff prays and respectfully requests that this Honorable Court enter an Order pursuant to Pa.R.C.P. 430 directing service of the Notice of Sale upon said Defendant(s), Kristy M Bitting by regular mail and certified mail, and by posting the mortgaged premises. UDRE CES, P. C. BY: Attorney r Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE *"LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE Apr. 23. 2010 11:46AM Apr 28 2010 11:47am 1`083/803 No. 81.19 P. 3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff yts a[ ?umbrN Jody S Smith ?¢G 04 ' ' k ". Chief Deputy Edward L Schorpp r._, Solicitor MICE OF THE SeER)FF Douts" Bank Trust Company Case Number vs. Kristy M Bitting 2007-7143 SHERIFF'S RETURN OF SERVICE 04/0112010 06:57 PM - Shawn Karrison, Deputy Sheriff, who being duly sworn according to law, states that on April 1, 2010 at 1854 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Kristy M. Siding, located at 205 Willow Mill Park Road, Mechanicsburg, Cumberland County, Pennsylvania according to law. 04/01/2010 06:57 PM • Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit Kristy Bitting, but was unable to locate her in his bailiwick. He therefore retums the within Real Estate Writ, Notice of Sale and Description as N ND as to the defendant, Kristy Bitting, defendant moved and did not leave a forwarding address. property is va nt. SHERIFF COST: S898A2 SO ANSWERS, April 28, 2010 RON R ANDERSON, SHERIFF EXHIBIT A lc) Ca"ySime s mr. rormar,,nr. A TIOINX3 Page 1 of 2 PLAYERS NATIONAL LOCATOR AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number: 07110270-1 Attorney Firm: Mark J Udren & Associates Case Number: Subject: Kristy Michelle Bitting AXA: Kristy M Bitting Last Known Address: 205 Willow Mill Park Road Mechanicsburg, PA 17050 Sandra Krekeler, being duly sworn according to law, deposes and says: 1. 1 am employed in the capacity of Location Specialist for Players National Locator. 2. On April 22, 20101 conducted an investigation into the whereabouts of the above named defendant(s). The results of my investigation are as follows: CREDIT INFORMATION A. SOCIAL SECURITY NUMBER(S): 174-64-)o= B. EMPLOYMENT SEARCH: We were unable to verify current employment for Kristy Michelle Bitting. C. INQUIRY OF CREDITORS: Creditors indicated the last reported address for Kristy Michelle Bitting is 205 Willow Mill Park Road, Mechanicsburg, PA 17050 with no valid home number. INQUIRY OF TELEPHONE COMPANY A. DIRECTORY ASSISTANCE SEARCH: Directory assistance had no listing for Kristy Michelle Bitting. We called (717) 877-4937 and spoke with Kristy on her cell phone who stated she is living at 205 Willow Mill Park Road, Mechanicsburg, PA 17050. INQUIRY OF NEIGHBORS We were unable to contact any neighbors to confirm any other information for Kristy Michelle Bitting. INQUIRY OF POST OFFICE A. NATIONAL ADDRESS UPDATE: As of April 21, 2010, the National Change of Address (NCOA) has no change for Kristy Michelle Bitting from 205 Wilow Mill Park Road, Mechanicsburg, PA 17050. MOTOR VEHICLE REGISTRATION EXHIBIT B A. MOTOR VEHICLE & DMV OFFICE: We were unable to verify current drivers license information for Kristy Michelle Bitting. Page 2 of 2 OTHER INQUIRIES A. DEATH RECORDS: As of April 21, 2010, the Social Security Administration has no death record on file for Kristy Michelle Bitting and/or A.K.A.s under the social security number(s) provided. B. PUBLIC LICENSES (PILOT, REAL ESTATE, ETC.): None found. C. COUNTY VOTER REGISTRATION: We were unable to confirm a listing with the County Voters Registration Office. ADDITIONAL INFORMATION ON SUBJECT A. DATE OF BIRTH: Kristy - January 1975 AFFIANT Sandra Kristine M. Scott, Notary Public , 2 S t. Louis Coungr, Sfete of Missouri Subscribed r to fore me 7111P4 /j; My Commission Expires 9/2/2010 Commissron Number 08428865 ,. 11*4" Players National Locator, 14444 Manchester Road, Manchester, MO 63011 Phone: (636) 230-9922 Fax: (636) 230-0558 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadings@udren.com Deutsche Bank Trust Company ?COURT OF COMMON PLEAS Americas (f/k/a Bankers Trust ':CIVIL DIVISION Company), as Trustee by :Cumberland County Residential Funding Company, LLC f/k/a Residential Funding Corporation, Attorney-in-fact NO. 07-7143 Civil Term Plaintiff V. Kristy M. Bitting Defendant(s) MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule the plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. NOTE: A sheriff's return of "not found" or the fact that a defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). Notice of intended adoption mailed to last known address requires a "good faith effort" to discover the correct address. Adoption of Walker, 468 Pa. 165, 360 A2d 603 (1976). An illustration of a good faith effort to locate the defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and employers of the defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As set forth in the Return of Service marked Exhibit "A", the Sheriff and/or Process Server has been unable to serve the Notice of Sale. A good faith effort to discover the whereabouts of the Defendant(s) has been made as evidenced by the attached Affidavit of Good Faith Investigation marked Exhibit "B". WHEREFORE, Plaintiff prays and respectfully requests service of the Notice of Sale upon Defendant(s) by regular mail and certified mail, and by posting the mortgaged premises. UDF.Rl-'ICES, P. C. BY: Attorneys or Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE VERIFICATION The undersigned hereby states that he/she is the Attorney for the Plaintiff in this action, that he/she is authorized to take this Verification, and that the statements made in the foregoing MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Sec 4904 relating to unsworn falsification to authorities. Date: May 4, 2010 UDRW-L&W,-QFFI1JES, P. C. BY: Attor ys Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE -heUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadings@udren.com Deutsche Bank Trust Company 'COURT OF COMMON PLEAS Americas (f/k/a Bankers Trust :CIVIL DIVISION Company), as Trustee by ":Cumberland County Residential Funding Company, LLC f/k/a Residential Funding Corporation, Attorney-in-fact :NO. 07-7143 Civil Term Plaintiff V. Kristy M. Bitting Defendant (s) CERTIFICATE OF SERVICE I, hereby certify that I have served true and correct copies of the attached Motion For Special Service upon the following person(s) named herein at their last known address or their attorney of record by: Regular First Class Mail Date Served: May 4, 2010 TO: Kristy M. Bitting 205 Willow Mill Park Road Mechanicsburg, PA 17050 UDR W ICES, P.C. BY: Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ZOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE MAY 0 6 2010(„ IN THE COURT OF COMMON PLEAS OF CU10ZRLAND COUNTY CIVIL DIVISION Deutsche Bank Trust Company Americas (f/k/a Bankers Trust Company), as Trustee by Residential Funding Company, €NO. 07-7143 Civil Term LLC f/k/a Residential Funding Corporation, Attorney-in-fact Plaintiff ' ` r'n V. J Kristy M. Bitting Defendant (s) O R D E R ` AND NOW, this - day of /`7©L ` 2010, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale and all subsequent pleadings on Defendant(s), Kristy M Bitting, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Notice of Sale and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant(s), Kristy M Bitting at 205 Willow Mill Park Road Mechanicsburg, PA 17050 and by posting the mortgaged premises located at 205 Willow Mill Park Road Mechanicsburg, PA 17050. BY THE COURT: J. eo??Y S UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com ATTORNEY FOR PLAINTIFF Deutsche Bank Trust Company :COURT OF COMMON PLEAS Americas (f/k/a Bankers Trust :CIVIL DIVISION Company), as Trustee by =Cumberland County Residential Funding Company, LLC f/k/a Residential Funding Corporation, Attorney-in-fact Plaintiff V. Kristy M. Bitting :NO. 07-7143 Civil Term Defendant (s) VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER n c' G p The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter he mailed a true and correct copy of the Notice of Sale to Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: DATE MAILED: May 17, 2010 Kristy M. Bitting 205 Willow Mill Park Road Mechanicsburg, PA 17050 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: May 17, 2010 UDREN W ES, P.C. BY: Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE 4OUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE MAY 0 6 2010(,, IM TIM COU" OF COM= PLZAS OF CTA18aRLl1UD COUNTY CIVIL DIVISION Deutsche Bank Trust Company Americas (f/k/a Bankers Trust Company), as Trustee by Residential Funding Company, €NO. 07-7143 Civil Term LLC f/k/a Residential Funding o .? Corporation, Attorney-in-fact ° T Plaintiff ` V. r^` O t`7 Kristy M. Bitting Defendant (s) A C? rn 0 R D E R i AND Now, this d day of 1'1'7,oL `7 2010, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDE3RSD that service of the Notice of Sale and all subsequent pleadings on Defendant(s), Kristy M Bitting, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Notice of Sale and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant(s), Kristy M Bitting at 205 Willow Mill Park Road Mechanicsburg, PA 17050 and by posting the mortgaged premises located at 205 Willow Mill Park Road Mechanicsburg, PA 17050. BY THE COURT: J. copy „???, r H O N o bi P4 H wze rt N O - CJ' E to H rt r y bw FJ ti J 7i' r 00 a n M I. J J O O C v O n 2 v p ? z m -q A Om Dm °zP ru ru .? -- Er Q' g G un USE • _ CO w r G' O OsdWFes _ O. O Poatmedc ..?.?..?.? C3' O Fletum Fleoelpt Fee 2 V more ? 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J d a m m a??° ;(1 z mo???3 m to y_ a 3 W O- 3. ? w o e C, ? v ?p m N Tn J J ?o__s O d n m m N -.. O N s ~ « UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 P Plaintiff v. Kristy M. Bitting Defendant(s) c~ o '~ , _ o ~ ; ~ r'r~ j^~i T _ [ ~ 4 C~" _ i ~r l ~ ~. ~. ' ' ~' ~ ..... '~ ..~,rr Cor oration Attorney-in-fact €NO. 07-7143 Civil Term ATTORNEY FOR PLAINTIFF Deutsche Bank Trust Company :COURT OF COMMON PLEAS Americas (f/k/a Bankers Trust :CIVIL DIVISION Company), as Trustee by :Cumberland County Residential Funding Company, LLC f/k/a Residential Funding PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: June 1, 2010 Q STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE ~' CHANDRA M. ARKEMA, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE UDREN LAW OFFICES, P.C. Attorneys f Plaintiff -~S UIRE 1 w ~ ' MAY 0 6 20100, IN T8E COIIRT OF CO'~iOM PL8~18 OF CUl~E RL~-ND COUNTY CIVIL DIVISION Deutsche Bank Trust Company Americas (f/k/a Bankers Trust Company) ,- as Trustee by , Residential Funding Company, NO. 07-7143 Civil Term LLC f/k/a Residential Funding ~ N ° ~::~ T Corporation, Attorney-in-fact ~ -v ~. ~ Plaintiff ~ ~, ~" -'~ "^ r ~_ ~ ~ Kristy M. Bitting ~%t t ~ ~~~` ~ f Defendant (s) :3} ' ' c t* '~ ORDER AND NOW, this ~ " day of ~oL ~ 2010, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale and all subsequent pleadings on Defendant(s), Kristy M Bitting, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Notice of Sale and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant(s), Kristy M Bitting at 205 Willow Mill Park Road Mechanicsburg, PA 17050 and by posting the mortgaged premises located Mechanicsburg, PA 17050. at 205 Willow Mill Park Road BY THE COURT: J. e ,~~~, °~r fArbM, 5~~0~ ~~ Deutsche Bank Trust Company Americas, et. al., Plaintiff(s) vs. kristy AI. Billings, et. al., Defendant(s) UDREN I.A«' OFFICES Ms. Henni Crommarty ~ 111 R'oodcrest Rd.. Ste. 200 Cherry Ilill, NJ 08003-3620 I Service of Process by ._... ~ APS International, Ltd. ~~._ 1-800-3~8-7171 APS I;i•t6AP~TIOYAt. ~ APS International Plaza - - ~ 7800 Clenroy Rd. ~.~ _,~ Minneapolis, AIN 35439-3122 APS File #: 103300-0001 AFFIDAVIT OF SERVICE -- Individual Sen•ice of Process on: -Krist?• M. Bitting, by posting Court Casc No. 07-71 A3 Civil Term State of: ss. County o Name of Sen•er: ,undersigned, being duly sworn. deposes and says that at the time of service. s/he was of legal age attd was not a party to this action: D:ete/Time of Service: that ott the ~~day of /_~~ u - ,`. 20~Q___, at r! ~ 'clock ,~M Place of Service: at 205 Nillow 111i1i Park Road _ ~ , in hlechanicsbur>c, PA 17050 ___._ ~_ _~ Documents Served: fire undersigned served the documents described as: Notice of Sherif!'s Stele of Reai Property a•/Order Service of Process on: A true and correct copy of the aforesaid document(s) tivas served on: Kristy Iyt. Bitting, by posting Person Served, and Method of Service• -- By personally delivering them into the hands of the person to be served. • ~ By delivering them into the hands of ~~~L~~ . a person of suitable age, who verified, or who upon questioning stated, that he/she resides with Kristy M. Bitting, by posting at the place of service. and whose relationship to the person is: Description of Person The person receiving documents is described as follows: Receiving Documents: Sex ;Skin Color ;Hair Color ;Facial Hair Approx. Age ;Approx. Height ;Approx. Weight To the best of my knowledge and belief. said person was not engaged in the US Military at the time of service. Signature of Server: Undersigned declares under penally of perjury ~ s d a sworn to before me is that t fo got g is rue and correct. ay o , 20 `o igna e o r ~E'ub _ (ommi apircs) APS International, Ltd. COMMONWEALTH OF PENNSYLVANIA Notarial Seal M. Michelle Guyton, Notary Public Cadlsle Boro, Cumberlana County My Commission Expires July 1, 2012 ember, Pennsylvania Association of Notari~ ,UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank Trust Company Americas (f/k/a Bankers Trust Company), as Trustee by Residential Funding Company, LLC f/k/a Residential Funding Corporation, Attorney-in-fact Plaintiff v. Kristy M. Bitting COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 07-7143 Civil Term Defendant(s) G ~, t r. ~ frtl * ;:.~ . ;x:. y-r- -~a j ~ (.,ll C.:i tt... _,' S ' ' ~ ~: r :~ 4-- - ;-~, ~~ C~ -- _~:t f, , ~,' c .F ~.. ,-c c..~ AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached. hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: June 10, 2010 UDREN LAW OFFICES, P.C. ,/ Attorneys or Plaintiff {----iu" ~'n `7. UDREN, ESQ,IITRF'-`~ STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE 'f CHANDRA M. ARKEMA, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE ATTORNEY FOR PLAINTIFF UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. M~NATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank Trust Company Americas (f/k!a Bankers Trust Company), as Trustee by Residential Funding Company, LLC f/k/a Residential Funding Corporation, Attorney-in-fact Plaintiff v. Kristy M. Bitting Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON CIVIL DIVISION Cumberland County PLEAS NO. 07-7143 Civil Term TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Kristy M. Bitting PROPERTY: 205 Willow Mill Park Road, Mechanicsburg, PA 17050 improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on June 2, 2010, at 10:00 A.M., in the Commissioners Hearing Room, 2ND Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the safe. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. 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N U1 ~ N O n ry O j N _ ~ ~ _. 3 m ° a (p N r* . cn o m ° ~/~ IBI A y O ~d a o- „ m o~mcmim m o N UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 .pleadings@udrea.com ATTORNEY FOR PLAINTIFF Deutsche Bank Trust Company :COURT OF COMMON PLEAS Americas (f/k/a Bankers Trust :CIVIL DIVISION Company), as Trustee by :Cumberland County Residential Funding Company, LLC f/k/a Residential Funding Corporation, Attorney-in-fact Plaintiff v. 6 Kristy M. Bitting o ~ G ~ -t ~ "C71 ?- ~ '~ r =NO. 07-7143 Civil Term Defendant(s) VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter he mailed a true and correct copy of the Notice of Sale to Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: DATE MAILED: May 17, 2010 Kristy M. Bitting 205 Willow Mill Park Road Mechanicsburg, PA 17050 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: May 17, 2010 ~~i f ( )) `'.'/ UDREN ES, P.C. BY: Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ~dUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE EXHiB1T B MaY o s 20~0~, . ~ IN THS COURT OF CONaLON PL$AS OF CUN88RT•~**n COUNTY CIVIL DIVISIOIQ Deutsche Bank Trust Company Americas (f/k/a Bankers Trust Company).,- as Trustee by Residential Funding Company, LLC f/k/a Residential Funding Corporation, Attorney-in-fact Plaintiff v. Kristy M. Bitting Defendant(s) N0. 07-7143 Civil Term Q R D E R N a ;~ o -n 'C- ~ .::. ` l ~ ~ ~~ 'Ji.:'.: ~! ~ '~ ~ <- ~~ ' - > . ~Tt a ~~ .~._ ,.-, ~ ~,, a c.; AND NOW, this ~ " day of ~®L ~ 2010, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale and all subsequent pleadings on Defendant(s), Kristy M Bitting, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Notice of Sale and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant(s), Kristy M Bitting at 205 Willow Mill Park Road Mechanicsburg, PA 17050 and by posting the mortgaged premises located at 205 Willow Mill Park Raad Mechanicsburg, PA 17050. BY THE COIIRT: J. eo ,~~~, Pr ~. ~• 5l io~ ~d _~,,,,,,n BXHtBIT B r i r I r n ~1 ,. J J .~ H O t~D o -~i ~ ~ m a ~ ~* ~ ~• K n ~ 3 m o ~ ~ ~ K ~ r- c:a w rt N trt -~ r- td ~ ~ row Nn J e~ O N '~ o O W a s .~ ~ ru ru . ~ • . • ~ ~~ D- v- ,~~ p O mu7 ~~~ ~~ ~', ~ ~~ ~1 ~ Postage ~ p p Certlfled Fee _ ~ ~~ p p ~~ p ~ p ~ ) Return Receipt Fee ~ ~ V Postmadc Here ~'~ p I p (Endorsement Required) p' p Reatrlaed Delivery Fee o ~ (Endorsement Required) ~~^ p ' p .^ .~ n.l ~ n.l ~~ p i p Total Postage 8 Fees ~~. m m enf o ---- tom' r~ Kristy M. 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N ~ 0 ~ ~ ~_ v c 3 ~ m ~ mo~~~o3 ~ y N C ~. ~ 'n ~~ d o~ a~i ~° ~ m ~ N ~ - ~ ~~~o E HI IT . UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF -[) c ~:; ~n• r4 ~~; ~. rJ: ~v 0 0 c.._ 1 CJO ,~ _~ -~ Rl iS Deutsche Bank Trust Company :COURT OF COMMON PLEAS ~~~; Americas (f/k/a Bankers Trust :CIVIL DIVISION Company), as Trustee by :Cumberland County Residential Funding Company, LLC f/k/a Residential Funding Corporation, Attorney-in-fact €NO. 07-7143 Civil Term Plaintiff v. Kristy M. Bitting Defendant (s) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: s> cry Kindly file the attached Proofs of Service with regard to the captioned matter. Date: June 1, 2010 UDREN LAW OFFICES, P.C. :=.~ r~-~ '~ Attorneys fg~Plaintiff ~ d;--£~QUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE rC-OO~`~a - MaY o s 20~0~, . s IN THg COIIRT OF COON PL8Pi8 OF COl~gRLJ~IiD COQNTY CIVIL DIVISION Deutsche Bank Trust Company Americas (f/k/a Bankers Trust Company),,- as Trustee by Residential Funding Company, LLC f/k/a Residential Funding Corporation, Attorney-in-fact Plaintiff v. Kristy M. Bitting Defendant(s) NO. 07-7143 Civil Term Q R D E R ('~ _( C N .C~' ~.~1 ~ ~'~ o ~ ~ ~ _ ` `~ ~ _: ~" -'[ '7y r t--~ ._ Ai .'.: ~~, " ~ ~-'T- L} ~~ ~c ~> a .t_ ~~ ~ Mfr AND NOW, this ~ " day of ~BL ~ , 2010, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale and all subsequent pleadings on Defendant(s), Kristy M Bitting, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Notice of Sale and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant(s), Kristy M Bitting at 205 Willow Mill Park Road Mechanicsburg, PA 17050 and by posting the mortgaged premises located at 205 Willow Mill Park Road Mechanicsburg, PA 17050. BY THE COURT: J. ~l ~^b~,r ~ ~• s~~.,~o,. j~~~ _.." - 1 ~XHIBI~" ~ Deu'sche Bank Trust Company Americas, et. al., Plaintiff(s) vs. Kristy AI. Sittings, et. al., Defendant(s) UDREN LA~V OFFICES 1~1s. Henni Crommarty ~ t 11 VVoodcrest Rd.. Ste. 200 Cherry 1[i11, NJ 08003-3620 I Servict of Process by ~~~, ~ APS International, Ltd. ~: ''~ 1-800-328-7171 ~ - ,1pg t~p•fER:~7IOVA(, ,APS International Plaza 7800 Gienroy Rd. `~,~ ~_~ ~IinneaQotis, s\ir 35439-3122 APS Fite ~: t03200-0001 AFFIDAVIT OF SERVICE -- Individual Sen•ice of Process on: -Krist}• M. Bitting, by posting Court Case No. 07-7143 Civil Term State of: ss. County o : Name of Sen•er: ,undersigned. being duly sworn. deposes and says that at the time of service. sJhe was of legal age attd was not a party to this action: DatelTime of Service: that on ilte day of . 20~Q_. at ~~ 'clock ,~M Piece of Service: Documents Served: Service of Process on: Person Served, and Method of Service: at 205~Villowl<Ii1lParkRoad +~ . in htechanicsburR,PA 17050~~_ .~. the undersigned served the documents described as: Notice of Sheriff s Strle of Rea! Property w/Order A true and correct copy of the aforesaid document(s) was served on: Kristy M. Bitting, by posting _~ By personally delivering them into the hands~of the person to be served, Sy delivering them into the hands of Y_/a~,~~7i-l~~ . a person of suitable age, who verified, or who upon questioning stated, that helshe resides with Kristy M. Bitting, by posting at the place of service, and whose relationship to the person is: Description of Person The person receiving documents is described as follows: Receiving Documents: Sex ; Skitt Color ;Hair Color ;Facial Hair Approx. Age ;Approx. Height ;Approx. Weight To the best of my knowledge and belief. said person was not engaged in the US Military at the time of service. Signature of Server: Undersigned declares under penalty of perjury ~ s d a sworn to before me is that t fo goi g is rue and correct. ay o , 20 r(~ igna e o r ~ ~~Pub _ (ommi apircs) APS International, Ltd. COMMONWEALTH OF PENNSYLVANIA Notarial Seal M. Michelle Guyton, Notary Public Carlisle Boro, Cumberlana County My Commission Expires July 1, 2012 Member, Pennsylvania Association of Notar+~ ~~H1B1T B SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor i . . -'~I LED u t 4 l t I FE -7 r31 ?t. 7 ?j'qcY?V,fi:??; .? Deutsche Bank Trust Company Case Number vs. Kristy M Bitting 2007-7143 SHERIFF'S RETURN OF SERVICE 04/01/2010 06:57 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on April 1, 2010 at 1854 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Kristy M. Bitting, located at 205 Willow Mill Park Road, Mechanicsburg, Cumberland County, Pennsylvania according to law. 04/01/2010 06:57 PM - Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Kristy Bitting, but was unable to locate her in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale and Description as NOT FOUND as to the defendant, Kristy Bitting, defendant moved and did not leave a forwarding address property is vacant. 05/18/2010 Property sale postponed to 7/7/2010. 07/07/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on July 7, 2010 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Mark J. Udren, on behalf of Deutsche Bank Trust Company et. al., of, 4828 Loop Central Drive, Houston, TX 77081, being the buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of $ SHERIFF COST: $1,010.36 SO ANSWERS, K°CX?- February 04, 2011 RON R ANDERSON, SHERIFF ??,cc, Pj . Cc. OM )) 5?y 155y IIDREN LAW OFFICES, P.C. ATTORNEY WOODCREST CORPORATE CENTER 111 ~POODCREST ROAD, SIIITE 200 CHERRY HILL, NJ 08003 856-669-5400 FOR PLAINTI DEUTSCHE BANK TRUST COMPANY :COURT OF COMMON PLEAS AMERICAS (F/K/A BANKERS TRUST :CIVIL DIVISION COMPANY), AS TRUSTEE BY :CUMBERLAND County RESIDENTIAL FUNDING COMPANY, LLC F/K/A RESIDENTIAL FUNDING CORPORATION, ATTORNEY-IN-FACT €NO. 07-7143 4828 LOOP CENTRAL DRIVE HOUSTON, TX 77081 Plaintiff V• KRISTY M. BITTING 205 WILLOW MILL PARK ROAD MECHANICSBURG, PA 17050 Defendant(s) TO THE PROTHONOTARY: c C ',~_. ]~- ~~ Kindly mark the above captioned matter JUDGMENT W and ACTION DISCONTINUED WITHOUT PREJUDICE, upon payment of costs only. DATED : Auctus t 2 2 , 2 012 Atto~or"i~ifj HAR Y B. REESE, ESQUIRE PA ID 310501 I~ ~I ~'' a N 07110270-1 ~4.5o p o C~ 3i11o3 P.;~a ~9 ~ c: ~a~ ~_ ca 3 y