HomeMy WebLinkAbout08-4856T •
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
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Deutsche Bank National Trust : COURT OF COMMON PLEAS
Company, as Trustee CIVIL DIVISION
4708 Mercantile Drive
Ft. Worth, TX 76137 ::Cumberland County
Plaintiff
V.
Justin D. Gordon
Amber Gordon NO. DR - 434% Owt Term
950 Baltimore.Road
Shippensburg, PA 17257
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 provisiones de
esta demanda. Usted puede perder dinero o sus propiedades u otros
derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO
0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN
PERSONA 0 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
t ,
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: Saxon Mortgage, Inc. d/b/a Saxon Home Mortgage
Assignments of Record to: Deutsche Bank National Trust Company, as
Trustee
Recording Date: LODGED FOR RECORDING
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: 950 Baltimore Road
MUNICIPALITY/TOWNSHIP/BOROUGH: Southampton Township
COUNTY: Cumberland
DATE EXECUTED: 2/14/07
DATE RECORDED: 2/26/07 BOOK: 1983 PAGE: 1535
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
8/5/08:
Principal of debt due $148,141.99
Unpaid Interest at 9.35%
from 3/1/08 to 8/5/08
(the per diem interest accruing on
this debt is $37.95 and that sum
should be added each day after
8/5/08) 5,923.14
Title Report 325.00
Court Costs (anticipated, excluding
Sheriff's Sale costs) 280.00
Escrow Overdraft/(Balance)
(The monthly escrow on this account
is $157.80 and that sum should
be added on the first of each
month after 8/5/08) (576.22)
Late Charges
(monthlyy late charge of $59.80
should be added in accordance
with the terms of the note
each month after 8/5/08) 851.07
Uncollected Fees 56.94
Attorneys Fees (anticipated and actual
to 5% of principal) 7,407.10
TOTAL $162,409.02
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 $162,409.02 plus interest,
costs and attorneys fees as more fully set forth in the Complaint,
and for foreclosure and sale of the Mortgaged premises.
UDREN %, , 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
EXHiEIT "A"
ALL THE FOLLOWING DESCRIBED THREE TRACTS OF REAL ESTATE LYIKG AND
BEING SITUATE IN SOUTHAMPTON TOWNSHIP, COMBERUMD C'OOFTY, PENNSYLVANIA
aOMDBD ' AND LIMITED AS FOLLOWS :
TRACT NO 1: BEGINNING AT AN IRON PIN IN THE CXVTRER OF THE PUBLIC ROAD
LEADING FROM SHIPPPNSEURG TO CLPVSRSBUR;G, AS THE, BALT1140RE ROAD
AT THE LINE OF LAND NOW OS FORMERLY OF ROBERT C. HEBBRLING AM DORIS
J. HEBRRLING HIS WIFE THENCE AEMG SAID LANDS NOW OR FORMERLY OF
HSBSRLIM SOUTH 17 DEGREES 45 MINUTRS WnT A DISTANCE OF 150 PERT TO
AN IRON PICT AT LANDS NOW OR PVkMRRLY OF LESLIE D. SHOAP AND HAZEL V.
SHOAP HIS WIFE AND L. RICRUM SHOA,P SINGLE MAN THENCE BY SAM- LANDS
NOW OR FORMERLY OF SAP SOUTR 72 DRIM MS 15 MINUTES BAST A DISTANCE
OF 75 FEET TO AN IRON PIN AT OTHER LANDS NOW OR FORMERLY OF THE SAID
SEMP TRENCS BY THE SAME NORTH 17 DR== 45 KXNUTKB EAST A DISTANCE
OF 150 FEET TO AN IRON PIN IN TER CRNTRBR OF THE AFQARSAID PUBLIC
ROAD; THENCE ALONG THE CENTRER OF AFORESAID PUBLIC ROAD NORTH 72
DEGREES 15 MINUTES WEST A DISTANCE OF 75 FEET TO AN IRON PIN, THE
PLACE OF BEGINNING
TRACT NO. 2
BEGINNING AT A POINT IN THE CNN= OF THE PUBLIC ROAD LNADnV FROM
SHIPPENSBURG TO CLV8R8SDRQ, MlOWN AS BALTIMORE ROAD AT LINE OF OTHER
LAND NOW OR FORMERLY OF JOHN L. STINE AND MIL=D V. STINK NIS RIFE,
THENCE ALONG THE SAME SOUTH 17 DDS 45 M130 S WEST A DISTANCE OF
150 FEET TO A POINT AT LINE OF LAND NOV OR. FORMERLY OF LISLIS D. SHOAP
AND HAZEL V. SHOAP HIS WIFE, AM L. RICHARD SHCaAP THENCE BY THE SAME
SOUTH 72 DEGREES 15 MINUTES PAST A DISTANCE OF 75 FEET TO THE POINT ON
LINE OF LAND NOW OR FORMERLY OF NORMAN 8I , THKNC.S BY THE
SAM, NORTH 17 DUMES 45 MINMMS EAST A DISTANCE OF 150 FBBT TO THE
Ponu IN THE CENTER OF THE AFOiRESAYD PUBLIC: RORD; THEIFCE BY THE CENTER
OF THE AFORNSAID PUBLIC ROAD NORTH 72 DEGREES 15 MINUTES WEST A
DISTANCE OF 75 FE'E'L' TO A POINT, THE PLACE OF BEGIN
TRACT 20 3
BEGINNING AT AN IRON PIN LOCATED ON THE SOUTHWEST COMM OF LANDS NOW
OR FORMERLY OF LESTER SLED IRS TOWCE BY LANDS NOW OR FORMERLY OF
I NSTfI L. GESSAMAH HIS WIrR SOUTH 18 DIGRUS 49 MINUTES 01 SECONDS
WEST 50 FEET TO AN IRON PIN; MLINCB BY TAB SAME NORTH 71 DEGREES 10
MIND S. 59 SBCONDS WEST 150 FEET TO AN IPM PIN THENCE BY LANDS NOW OR
FOR14BHLY OF THOMAS RZ=Y NORTH 18 DEGREES 49 MINUTZSI 01 SECONDS BAST
50 FEET TO AN IRAN PINS THENCE BY OTHER LAWS NOW OR FORMERLY OF THE
SAID G88SAMAN SOUTH 71 DRORZES 10 MINUTES 59 SECONDS BAST 150 FW M TO
AN IRAN PIN, THE PLACE OF HPGINNING
TAX ID# 39-36-2428-015
ACT 91 NOTICE
DATE OF NOTICE: 06/05/2008
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THE PURPOSE OF COLLECTING THE DEBT.
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 pages.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP may be
able to help to save your home. This Notice explains how the program works.
To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT
COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this
Notice with you when you meet with the Counseling Agency.
The name, address and phone number of Consumer Credit Counseling Agencies serving
your County are listed at the end of this Notice. If you have any questions, you may call the
Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired
hearing can call (717) 780-1869.)
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 any 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
viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion
immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al
numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado
"Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la
perdida del derecho a redimir su hipoteca.
Prepared by: GOLDBECK McCAFFERTY & McKEEVER
Suite 5000 - Mellon Independence Center.
701 Market Street
Philadelphia, PA 19106
Fax (215) 627-7734
EXHIBIT A
Date: 06/05/2008
Homeowners Name: AMBER D. GORDON and JUSTIN D. GORDON
Property Address: 950 Baltimore Road, Shippensburg, PA 17257
Loan Account No.: 12068705
Original Lender: SAXON MORTGAGE SERVICES INC.
Current Lender/Servicer: SAXON MORTGAGE SERVICES INC.
HOMEOWNERS'
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"), 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 designated 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 agencies for the county in which the property is located are set
forth at 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 fact-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR
IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER,
FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR
APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
AGENCY ACTION - Available funds for emergency mortgage assistance are very limited.
They will be 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 filed bankruptcy you can still apply for
Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT Brine it up to date).
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property
located at: 954 Baltimore Road, Shippensburg, PA 17257 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:
(a) Monthly payment from 04/01/2008 thru 06/05/2008
(3 mos. at $1,343.44/month) $4,030.32
(b) Late charges from 04/01/2008 thru06/05/2008 (3 mos. at $59.28/month) $177.84
(c) Other charges; Escrow, Inspec., NSF Checks
(d) Other provisions of the mortgage obligation, if any
(e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $4,208.16
HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the
date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH
IS $4,208.16, 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:
SAXON MORTGAGE SERVICES INC.
4708 Mercantile Drive North
Fort Worth, TX 76137
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 mortQaQe 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 brings legal proceedings against you, you will still be required to pay the
reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are
started against 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 cure the default within the THIRTY (30) DAY
Period, you will 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 cured 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 Sheriffs Sale.
You may do so by paving the total amount then past due, plus any late or other charges then due
reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected
with the Sheriffs 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 SHERIFF'S SALE DATE - It is estimated that the earliest date that such a
Sheriffs Sale of the mortgaged property could be held would be approximately four (4) to six (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 by contacting the
lender.
HOW TO CONTACT THE LENDER:
Name of Lender: SAXON MORTGAGE SERVICES INC.
Address: 4708 Mercantile Drive North
Fort Worth, TX 76137
Phone Number: 888-325-3502
Contact Person: Loss Mitigation Department
EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of
the mortgaged property and your right to occupy it. If you continue to live in the property after the
Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by
the lender at any time.
ASSUMPTION OF MORTGAGE - You may 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.
Contact: Loss Mitigation Department
Phone Number: 888-325-3502
1 u? .
ACT 91 NOTICE
DATE OF NOTICE: 06/05/2008
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THE PURPOSE OF COLLECTING THE DEBT.
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 pages.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) mgy be
able to help to save your home. This Notice explains how the program works.
To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT
COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this
Notice with you when you meet with the Counseling Agency.
The name, address and phone number of Consumer Credit Counseling Agencies serving
your County are listed at the end of this Notice. If you have any questions you may call the
Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired
hearing can call (717) 780-1869.)
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 any 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
viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion
immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al
numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado
"Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la
perdida del derecho a redimir su hipoteca.
Prepared by: GOLDBECK McCAFFERTY & McKEEVER
Suite 5000 - Mellon Independence Center.
701 Market Street
Philadelphia, PA 19106
Fax (215) 627-7734
1 . . ,
Date: 06/05/2008
Homeowners Name: AMBER D. GORDON and JUSTIN D. GORDON
Property Address: 950 Baltimore Road, Shippensburg, PA 17257
Loan Account No.: 12068705
Original Lender: SAXON MORTGAGE SERVICES INC.
Current Lender/Servicer: SAXON MORTGAGE SERVICES INC.
HOMEOWNERS'
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"), 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 designated 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 agencies for the county in which the property is located are set
F • • f
forth at 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 fact-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR
IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER,
FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR
APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
AGENCY ACTION - Available funds for emergency mortgage assistance are very limited.
They will be 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 filed bankruptcy you can still 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: 950 Baltimore Road, Shippensburg, PA 17257 IS SERIOUSLY IN DEFAULT because:
1 1.
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months
and the following amounts are now past due:
(a) Monthly payment from 04/01/2008 thru 06/05/2008
(3 mos. at $1,343.44/month) $4,030.32
(b) Late charges from 04/01/2008 thru06/05/2008 (3 mos. at $59.28/month) $177.84
(c) Other charges; Escrow, Inspec., NSF Checks
(d) Other provisions of the mortgage obligation, if any
(e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $4,208.16
HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the
date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH
IS $4,208.16, 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:
SAXON MORTGAGE SERVICES INC.
4708 Mercantile Drive North
Fort Worth, TX 76137
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 brings legal proceedings against you, you will still be required to pay the
reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are
started against 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 cure the default within the THIRTY (30) DAY
period, you will 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 cured 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 Sheriffs Sale.
You may do so by paving the total amount then past due, plus any late or other charges then due,
reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected
I . 1
with the Sheriff s Sale as specified in writing by the lender and by performing gny 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 SHERIFF'S SALE DATE - It is estimated that the earliest date that such a
Sheriffs Sale of the mortgaged property could be held would be approximately four (4 to six (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 by contacting the
lender.
HOW TO CONTACT THE LENDER:
Name of Lender: SAXON MORTGAGE SERVICES INC.
Address: 4708 Mercantile Drive North
Fort Worth, TX 76137
Phone Number: 888-325-3502
Contact Person: Loss Mitigation Department
EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of
the mortgaged property and your right to occupy it. If you continue to live in the property after the
Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by
the lender at any time.
ASSUMPTION OF MORTGAGE - You may 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.)
I .
* 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.
Contact: Loss Mitigation Department
Phone Number: 888-325-3502
4 . , 0
V E R I F I C A T I O N
The undersigned, hereby states that he/she is the attorney for
the Plaintiff, a corporation unless designated otherwise; that
he/she 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/she
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/her 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.
UDREN P.C.
BY:
Attorn't-Is or Plaintiff
MARK J. REN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
%-InQUIS A. SIMONI, ESQUIRE
( 311
'
^?
00 7rti Y
y fT
IN
i
v G_? k
0
SHERIFF'S RETURN - REGULAR
..CASE NO: 2008-04856 P
t
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
....r.
DEUTSCHE BANK NATIONAL TRUST
VS
GORDON JUSTIN D ET AL
BRIAN BARRICK , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
GORDON JUSTIN D
the
DEFENDANT , at 1337:00 HOURS, on the 6th day of September, 2008
at 950 BALTIMORE ROAD
SHIPPENSBURG, PA 17257
JUSTIN GORDON
by handing to
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 19.00
Affidavit .00
Surcharge 10.00
/ .00
41 47.00
Sworn and Subscibed to
before me this day
of ,
So Answers:
R. Thomas Kline
09/08/2008
UDREN LAW OFFICES .,..
...r.
By .
Deputy Sheriff
A. D.
SHERIFF'S RETURN - REGULAR
ZASE NO: 2008-04856 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
GORDON JUSTIN D ET AL
BRIAN BARRICK
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
GORDON AMBER
the
DEFENDANT , at 1347:00 HOURS, on the 6th day of September, 2008
at 106 GILBERT ROAD
SHIPPENSBURG, PA 17257
AMBER GORDON
a true and attested copy of COMPLAINT - MORT FORE
was served upon
by handing to
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 6.00
Service 19.00
Affidavit .00
Surcharge 10.00
00
?ll?lO s 3,7- 5.00
Sworn and Subscibed to
before me this day
So Answers:
R. Thomas Kline
09/08/2008
UDREN LAW OFFICES
By: Deputy Sheriff
0 f A. D.
UDREN LAW OFFICES, P.C.
'MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadingsC@udren.com
ATTORNEY FOR PLAINTIFF
Deutsche Bank National Trust :COURT OF COMMON PLEAS
Company, as Trustee :CIVIL DIVISION
4708 Mercantile Drive -:Cumberland County
Ft. Worth, TX 76137
Plaintiff :MORTGAGE FORECLOSURE
V.
Justin D. Gordon :NO. 08-4856 Civil Term
Amber Gordon
950 Baltimore Road
Shippensburg, PA 17257
Defendant(s)
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and
Defendant(s) Justin D. Gordon and Amber Gordon for failure
Answer to Plaintiff's Complaint within 20 days from service
for foreclosure and sale of the mortgaged premises,
Plaintiff's damages as follows:
As set forth in Complaint
Interest Per Complaint
From 8/6/08 to 10/10/08
Late charges per Complaint
From 8/6/08 to 10/10/08
Escrow payment per Complaint
From 8/6/08 to 10/10/08
$162,409.02
2,504.70
119.60
315.60
against the
to file an
thereof and
and assess
TOTAL $165,348.92
I hereby certify that (1) the addresses of the Plaintiff and
Defendant are as shown above, and (2) that notice has been given in
accordance with Rule 237.1, a copy of which is attached hereto.
UDREN LAW OFFICES, P.C.
BY : ( // i
Attorneys -for Plairitiff
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
DAMAGES ARE HEREBY ASSESSED AS INDICATED
DATE : /0%0 /D? PRO PROTHY
UDREN LAW OFFICES P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNRG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - .ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEKA, ESQUIRE - ID #203437
LOUIS A. SIMONI, ESQUIRE - ID #200869
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadingsOudren.com
Deutsche Bank National Trust :COURT OF COMMON PLEAS
Company, as Trustee c CIVIL DIVISION
4708 Mercantile Drive
Ft. Worth, TX 76137 :Cumberland County
Plaintiff
V.
N
Q
am'
(, .S y
.
d
} .
Justin D. Gordon T
Amber Gordon NO. Q$ - ?$ Civ I `o- ro'
950 Baltimore..Road
Shippensburg, PA 17257
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 PER.
LAWYERS REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
Qdo?t if (;? S- / Ii AB
SHERIFF'S RETURN - REGULAR 1
CASE NO: 2048-04856 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
GORDON JUSTIN D ET AL
BRIAN BARRICK Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
GORDON AMBER the
DEFENDANT at 1347:00 HOURS, on the 6th day of September, 2008
at 105 GILBERT ROAD
SHIPPENSBURG, PA 17257 by handing to
AMBER GORDON
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 6.00
Service 19.00
Affidavit . 00
Surcharge 10.00 R. Thomas Kline
00
35.00 09/08/2008
UDREN LAW OFFICES
Sworn and Subscibed to By:
14Z
T
y
before me this day Deputy Sheriff
of , A. D.
SHERIFF'S RETURN - REGULAR
CASE NO: 20Q8-04856 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
GORDON JUSTIN D ET AL
BRIAN BARRICK
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
GORDON JUSTIN D the
DEFENDANT
, at 1337:00 HOURS, on the 6th day of September, 2008
at 950 BALTIMORE ROAD
SHIPPENSBURG, PA 17257
JUSTIN GORDON
by handing to
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So Answers:
Docketing 18.00
Service 19.00
Affidavit .00 ;Y?wa?•i'
Surcharge 10.00 R. Thomas Kline
.00
47.00 09/08/2008
UDREN LAW OFFICES
Sworn and Subscibed to By:
before me this day Deputy Sheriff
of A.D.
UDREN LAW OFFICES, P.C.
MARK J. UDR=F, ESQUIRE - ID #04302
STUART WIEG, ROWIRS - ID #45362
LORRAINE DOYLE, NSQUIRZ - ID 34576
ALAN K. NNATO, ZBOUX R8 - ID 075860
CAU=RA X. ARMNIA, XSQUXR2 - ID #203437
LOUIS A. SI110NI, ESQ XRE - ID #200869
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY MILL, NJ 08003
856-669-5400
.-1 _-AA ___,....___ --
Deutsche Bank National Trust Company, as
Trustee
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
V.
Justin D. Gordon
Amber Gordon Defendant (s)
NO. 08-4856 Civil Term
T0: Justin D. Gordon
950 Baltimore Road
Shippensburg, PA 17257
Date of Notice: Septemeber 29, 2008
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING
OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
TEN DAYS FROM THE DATE OF THIS NOTICE A JUDG
WITHOUT A HEARING AND YOU MAY LOSE 156R PROPS
RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAW
HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE S:
CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING
REDUCED FEE OR NO FEE.
'ER A WRITTEN APPEARANCE
'H THE COURT YOUR DEFENSES
UNLESS YOU ACT WITHIN
MAY BE ENTERED AGAINST YOU
OR OTHER IMPORTANT
AT ONCE. IF YOU DO NOT
ORTH BELOW. THIS OFFICE
AWYER. IF YOU CANNOT
TO PROVIDE YOU WITH
ERVICES TO ELIGIBLE PERSONS
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
USTED SE ENCUENTR.A EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION
REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE
UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION EL TRIBUNAL PODRA SIN
NECESI
SBNTEN? EN SUM ONTRACEUSTEDEPUEDECPERDER BIEENNESAY OPREU TROOS DE?RECCHHU,Di
IMPORTANTES. DEBE LLEW ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI
USTED NO TIENE ABOGADO O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO,
VAYA EN PERSONA 0 LLAMk POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE P6EDE CONSEGUIR ASSISTENCIA
SERVICIO DE REFERENCIA LEGAL
LAWYER REFERRAL SERVICE
Cumberland Count Bar Association
2 Liberty Avenue
Carlisle PA 17013
717-29-3166
800-990-9108
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS
DEEMMD TO HE A DEBT COLLECTO AIR ATTEMPT TO COLLECT A DEBT. AIRY
INFORMATION OBTAINED wxLL BE SED R T PURPOSE.
i •
rx of n, squ}re
Stuart W nneg, Esquire
Lorraine Do le, Esquire
Alan M. Min to, Esquire
Chandra M. Ar ema, Esquire
ow-bouts A. Simoni, Esquire
Woodcrest Corporate center
111 Woodcrest load, Suite 200
Cherry Hill, New Jersey 08003-3620
UDREN LAN OFFICES
MARK J. UDREN, ES
STUART W118 G, ES
LORRAINE DOYLE, E
ALAN X. MINATO, E
CHANDRA X. AR33ZA
LOUIS A. OXMONI.
NJ
P. C.
UIRE - ID #04302
UIRE - ID #45362
QQUIRZ - ID #34576
QUIRE - ID #75860
ESQUIRE - ID #203437
SQUIRE ID #200869
0030 TE 200
Deutsche Bank National Trust Company, as
Trustee
Plaintiff
V.
Justin D. Gordon
Amber Gordon
Defendant(s)
TO: Amber Gordon
106 Gilbert Road
Shippensburg, PA 17257
Date of Notice: Septemeber 29, 2008
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 08-4856 Civil Term
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES
OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN
TEN DAYS FROM THE DATE OF THIS NOTICE A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING AND YOU MAY LOSE 066. PROPERTY OR OTHER IMPORTANT
RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE
CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT
AFFORD TO HIRE A LAWYER THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH
INFORMATION ABOUT AGENCfES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS
AT A REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVIC$
Cumberland County Bar Association
2-Liberty Avenue
Carlisle PA 17013
717-249-3166
800-990-9108
USTED SE ENCUENTR.A EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION
REQUIRIDA DE SU PARTE ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE
UN TERMING DE DIEZ (10) DIAS DE ESTA NOTIFICACION EL TRIBUNAL PODRA SIN
SEENTENCIA EN COMCPARARECER USTEDEPUEDECPRERDER BIENECSY OTROOSSADERALGUNA ECHOb DfCTAR
IMPORTANTES. DEBE LLEW ESTA NOTIFICACION A UN ABOGADO IMMEDIATAL(+IENTE SI
USTED NO TIENE ABOGADO 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO,
VAYA EN PERSONA 0 LLAMA POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE MEDE CONSEGUIR ASSISTENCIA
LEGAL.
SERVICIO DE REFERENCIA LEGAL
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAO FIRM IS
DEHHBD TO HE A DEBT COLLECTOR AL TUX"S AN ATTEOT TO COLLECT A DEBT. ANY
INFORMATION OBTAINED WILL H PURPOSE.
-9 Na" squire
Stuar W nnegg, Esquire
Lorraine Doyyre, Esquire
Alan M. M3. to, Esquire
Chandra M. Arkema, E-sgµire
-Louis A. Simoni, Esquire
Woodcrest Co orate Center.
111 Woodcrest Road, Suite 200
Cherry Hill, New Jersey 08003-3620
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. 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
ATTORNEY FOR PLAINTIFF
Deutsche Bank National Trust :COURT OF COMMON PLEAS
Company, as Trustee :CIVIL DIVISION
Plaintiff :Cumberland County
V.
:MORTGAGE FORECLOSURE
Justin D. Gordon
Amber Gordon
Defendant(s) NO. 08-4856 Civil Term
AFFIDAVIT OF NON-MILITARY SERVICE
STATE OF NEW JERSEY
COUNTY OF CAMDEN
SS
THE UNDERSIGNED being duly sworn, deposes and says that the
averments herein are based upon investigations made and records
maintained by us either as Plaintiff or as servicing agent of the
Plaintiff herein and that the above Defendant(s) are not in the
Military or Naval Service of the United States of America or its Allies
as defined in the Servicemembers' Civil Relief Act (108 P.L. 189; 117
Stat. 2835; 2003 Enacted H.R. 100), and that the age and last known
residence and employment of each Defendant are as follows:
Defendant: Amber Gordon
Age: Over 18
Residence: As captioned above
Employment: Unknown
Defendant: Justin D. Gordon
Age: Over 18
Residence: As captioned above
Employment : Unknown -CAI 2E
Name:
Title: ATTORNEY FOR PLAINTIFF
Sworn to and subscribed Company: UDREN LAW OFFICES, P.C.
before me this 10 day
of /Qctober, 2008 ,
c
46-
_O
W ?
t
D
(. i C.:r 4... 3
"T1
4 f ;w„
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 National Trust :COURT OF COMMON PLEAS
Company, as Trustee :CIVIL DIVISION
Plaintiff ::Cumberland County
V.
:MORTGAGE FORECLOSURE
Justin D. Gordon NO. 08-4856 Civil Term
Amber Gordon
Defendant(s)
TO: Justin D. Gordon
950 Baltimore Road
Shippensburg, PA 17257
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are
hereby notified that a Judgment has been entered against you in the
above proceeding as indicated below.
Prothonotary
X Judgment by Default
Money Ju
Judgment
Judgment
Judgment
Judgment
Judgment
3gment
in Replevin
for Possession
on Award of Arbitration
on verdict
on Court Findings
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL:
ATTORNEY Mark J. Udren, Esquire
At this telephone number: 856-669-5400
UDREN LAW OFFICES, P.C.
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
L'ORRAINE 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
ATTORNEY FOR PLAINTIFF
Deutsche Bank National Trust :COURT OF COMMON PLEAS
Company, as Trustee :CIVIL DIVISION
Plaintiff ::Cumberland County
V.
:MORTGAGE FORECLOSURE
Justin D. Gordon :NO. 08-4856 Civil Term
Amber Gordon
Defendant(s)
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Please issue Writ of Execution in the above matter:
Amount due $165,348.92
Interest From 10/11/08 5,502.75
to Date of Sale March 4, 2009
Ongoing Per Diem of 37.95
to actual date of sale including if sale is
held at a later date
(Costs to be added) $
UDREN LAWOFFICES, ?P.C.
j?BY 00AYJ11 ? 1&j
Attorneys- for Plaiintif-f
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
440-
9b
p ? `L Oe i?I Q.C.
u? o ? $ a?
+? 0 0
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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 National Trust :COURT OF COMMON PLEAS
Company, as Trustee :CIVIL DIVISION
Plaintiff :Cumberland County
V.
:MORTGAGE FORECLOSURE
Justin D. Gordon :NO. 08-4856 Civil Term
Amber Gordon
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:
A. An individual
X 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:
UDREN LAW OFFICES, P.C.
,?BY ?/?i? L,G1/
Attorneys for Plaintiff
MARK J. UDREN, ESQUIRE
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 - 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 National Trust :COURT OF COMMON PLEAS
Company, as Trustee :CIVIL DIVISION
Plaintiff ;Cumberland County
V.
:MORTGAGE FORECLOSURE
Justin D. Gordon :NO. 08-4856 Civil Term
Amber Gordon
Defendant(s)
C E R T I F I C A T E
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.
UDREN?L/AW OFFICES, P.C.
BY :Llf //g??
Attorneys for Plaintiff
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
?a
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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 National Trust :COURT OF COMMON PLEAS
Company, as Trustee :CIVIL DIVISION
Plaintiff €:Cumberland County
V.
:MORTGAGE FORECLOSURE
Justin D. Gordon :NO. 08-4856 Civil Term
Amber Gordon
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129.1
Deutsche Bank National Trust Company, as Trustee, 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: 950 Baltimore Road, Shippensburg, PA 17257
1. Name and address of Owner(s) or reputed Owner(s):
Name Address
Justin D. Gordon 950 Baltimore Road
Shippensburg, PA 17257
Amber Gordon 106 Gilbert Road
Shippensburg, PA 17257
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 the last recorded holder of every mortgage
of record:
Name Address
Deutsche Bank National 4708 Mercantile Drive
Trust Company, as Trustee Ft. Worth, TX 76137
5. Name and address of every other person who has any record lien
1 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 950 Baltimore Road
Shippensburg, PA 17257
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: October 10, 2008
UDREN LAW OFFICES, P.C.
BY: / & //// 1,1,f M -4 A/JA1-,.K11LM i
Attorneys for Plaintiff
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
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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 National Trust :COURT OF COMMON PLEAS
Company, as Trustee :CIVIL DIVISION
Plaintiff :Cumberland County
V.
Justin D. Gordon :NO. 08-4856 Civil Term
Amber Gordon
Defendant(s)
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
OWNER(S): Justin D. Gordon and Amber Gordon
PROPERTY: 950 Baltimore Road
Shippensburg, PA 17257
Improvements: RESIDENTIAL DWELLING
The above captioned property is scheduled to be sold at the
Cumberland County Sheriff's Sale on March 4, 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 that 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.
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 National Trust :COURT OF COMMON PLEAS
Company, as Trustee :CIVIL DIVISION
Plaintiff :Cumberland County
V.
:MORTGAGE FORECLOSURE
Justin D. Gordon :NO. 08-4856 Civil Term
Amber Gordon
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Amber Gordon
106 Gilbert Road
Shippensburg, PA 17257
Your house (real estate) at 950 Baltimore Road
(Southampton Township)Shippensburg, PA 17257 is scheduled to be
sold at the Sheriff's Sale on March 4, 2009, at 10:00 A.M. in the
Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA,
to enforce the court judgment of $165,348.92, 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 Sheriffs sale is not stopped, your property will be sold
to the highest bidder. You may find out the price bid by calling 856-669-
5400.
2. You may be able to petition the Court to set aside the sale if the
bid price was grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the
full amount due in the sale. To find out if this has happened, you may call
856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff, you
will remain the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount
due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that
time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for
your house. A schedule of distribution of the money bid for your house will
be filed by the Sheriff within 30 days after the sale. This schedule will
state who will be receiving that money. The money will be paid out in
accordance with this schedule unless exceptions (reasons why the proposed
distribution is wrong) are filed with the Sheriff within ten (10) days after
Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting
your home back, if you act immediately after the sale.
YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
CZ)
.. 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. ARREMA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
Deutsche Bank National Trust :COURT OF COMMON PLEAS
Company, as Trustee :CIVIL DIVISION
Plaintiff :Cumberland County
V.
:MORTGAGE FORECLOSURE
Justin D. Gordon :NO. 08-4856 Civil Term
Amber Gordon
Defendant (s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Justin D. Gordon
950 Baltimore Road
Shippensburg, PA 17257
Your house (real estate) at 950 Baltimore Road
(Southampton Township)Shippensburg, PA 17257 is scheduled to be
sold at the Sheriff's Sale on March 4, 2009, at 10:00 A.M. in the
Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA,
to enforce the court judgment of $165,348.92, 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
j 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
-?s
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-4856 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL, TRUST COMPANY,
as Trustee, Plaintiff (s)
From JUSTIN D. GORDON and AMBER GORDON
(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 $165,348.92
L.L.$ 0.50
Interest from 10/11/08 to Date of Sale 3/04/08 Ongoing Per Diem of $37.95 to actual date of sale
including if sale is held at a later date - $5,502.75
Atty's Comm %
Atty Paid $201.00
Plaintiff Paid
Date: 10/10/08
(Seal)
Due Prothy $2.00
Other Costs
/Ijbin
0 em
othonota
By:
Deputy
REQUESTING PARTY:
Name: CHANDRA ARKEMA, ESQUIRE
Address: UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
Attorney for: PLAINTIFF
Telephone: 856-669-5400
Supreme Court ID No. 203437
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
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400 pleadings@udren.com
Deutsche Bank National Trust :COURT OF COMMON PLEAS
Company, as Trustee :CIVIL DIVISION
Plaintiff .€Cumberland County
V.
Justin D. Gordon :NO. 08-4856 Civil Term
Amber Gordon
Defendant
PRAECIPE TO WITHDRAW JUDGMENT AND DISCONTINUE WITHOUT PREJUDICE
TO THE PROTHONOTARY:
Kindly mark the above captioned matter JUDGMENT
WITHDRAWN and ACTION DISCONTINUED WITHOUT PREJUDICE.
DATED: December 9. 2008
UD ?FI4 W'S-) P. C.
'A
BY:
Attorney Plaintiff
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
LOUIS A. SIMONI, ESQUIRE
C? -(A-
00
L L cn* -rts
Deutsche Bank National Trust Company
VS
Justin D. Gordon and Amber Gordon
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2008-4856 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED per letter of request from Attorney Mark Udren.
Sheriffs Costs:
Docketing
Poundage
Law Library
Prothonotary
Levy
Mileage
Surcharge
R. Thomas Kline, Sheriff
(r
BY
Real Estate Sergeant
30.00
244.96
.50
2.00
45.00
40.00
50.00
$412.46 ? .F Ji w k -? t
C. .
is U 4ti
i
,?e L. -I r ' % 7
?1'RI7' OF E;?iECI'fC0\ andhru ?1'fAt'H.?1T:N1
COMMONWEAUfII OF PENNSy"IX,,kNl yi
C(".1NTY OF CUMI3FRI.AND)
'; t) 08-4856 M1
TO TIIE SHERIFF OF CUMBERLAND COON Vl :
ho satisfy the debt, interestand costs due DEUTSCHE BANK NATIONAL. I IYUSI (O.VIP:??1'.
as Trustee, Plaintiff (s)
From JUSTIN D. GORDON and AMBER GORDON
(1) You are directed to Ievy upon the property of the defendant (s)and tc, x+L '41F LEGAI
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not Ievled up0h ,n tike poti?e5s;ur
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued: (b) the garnishee( s) Is en)ou"Cd lion)
paying any debt to or for the account of the defendant (s) and from delivering, any property oi c dcicndan€
(s) or otherwise disposing thereof,
(3) If property of the defendant(s) not levied upon an subject to attachment is found m the potise5s!??3,
of anyone other than a named garnishee, you are directed to notify him/her that he: di has been added _t,
-arnishee and is enjoined as above stated.
Amount We S165,348.92 l.J _S 0.50
Interest from 10/11/08 to Date of Sale 3/04/08 Ongoing Per Diem of $37.95 to actual date of sale
including if sale is held at a later date -- S5,502.75
Atty's Comm Due Frothy 52.00
Atty Paid $201.00
Plaintifl,Paid
Date: 10/10/08
(Seal)
Other t osts
l<
Prothunotaiy _. -
Ueput,REQUESTING PARTY:
Name: CHANDRA ARKEMA, ESQUIRE
Address: UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
I I I WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
Attorncv for: PLAINTIFF
Telephone: 856-669-5400
Sunreme Con-1 11) No 21114'17
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRANE 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 National Trust :COURT OF COMMON PLEAS
Company, as Trustee '-CIVIL DIVISION
Plaintiff 'Cumberland County
V.
MORTGAGE FORECLOSURE
Justin D. Gordon
Amber Gordon
Defendant(s)
NO. 08-4856 Civil Term
AFFIDAVIT PURSUANT TO RULE 3129.1
Deutsche Bank National Trust Company, as Trustee, 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: 950 Baltimore Road, Shippensburg, PA 17257
1. Name and address of Owner(s) or reputed Owner(s):
Name Address
Justin D. Gordon 950 Baltimore Road
Shippensburg, PA 17257
Amber Gordon 106 Gilbert Road
Shippensburg, PA 17257
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 the last recorded holder of every mortgage
of record:
Name Address
Deutsche Bank National 4708 Mercantile Drive
Trust Company, as Trustee Ft. Worth, TX 76137
5. Name and address of every other person who has any record lien
on the property:
Name Address
None
6. Name and address of every other person who has any record
interest in the property and whose interest may be affected by
the sale:
Name Address
Real Estate Tax Dept
Domestic Relations Section
Commonwealth of PA,
Department of Revenue
7. Name and address of
has knowledge who has
affected by the sale:
Name
Tenants/Occupants
Address
950 Baltimore Road
Shippensburg, PA 17257
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: October 10, 2008
1 Courthouse Sq.,
Carlisle, PA 17013
13 N. Hanover St.
Carlisle, PA 17013
Bureau of Compliance, PO Box 281.230
Harrisburg, PA 171.28-1230
every other person of whom the plaintiff
any interest in the property which may be
UDREN LAW OFFICES, P.C.
BY: 6ue'y'?? ? Ir?
Attorneys for Plaintiff
MARK J. UDREN, ESQUIRE
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
SrUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CIiANDRA M. ARKEMA, ESQUIRE - ID #203437
WOODCREST CORPORATE CENTER
1L1 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pLeadings@udren.com
Deutsche Bank National Trust
Company, as Trustee
Plaintiff
V.
Tustin D. Gordon
Amber Gordon
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
NO. 08-4856 Civil Term
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Amber Gordon
106 Gilbert Road
Shippensburg, PA 17257
Your house (real estate) at 950 Baltimore Road
(Southampton Township)Shippensburg, PA 17257 is scheduled to be
sold at the Sheriff's Sale on March 4, 2009, at 10:00 A.M. in the
Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA,
to enforce the court judgment of $165,348.92, 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 Sheriffs 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
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LDRRAINE 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 National Trust :COURT OF COMMON PLEAS
Company, as Trustee '-CIVIL DIVISION
Plaintiff ':Cumberland County
V.
MORTGAGE FORECLOSURE
Justin D. Gordon NO. 08-4856 Civil Term
Amber Gordon
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Justin D. Gordon
950 Baltimore Road
Shippensburg, PA 17257
Your house (real estate) at 950 Baltimore Road
(Southampton Township) Shippensburg, PA 17257 is scheduled to be
sold at the Sheriff's Sale on March 4, 2009, at 10:00 A.M. in the
Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA,
to enforce the court judgment of $165,348.92, 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
RLGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
•1. If the Sheriff's Sale is not stopped, your property will be sold
t) the highest bidder. You may find out the price bid by calling 856-669-
5=.00.
2. You may be able to petition the Court to set aside the sale if the
b;d 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
fill 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
die 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 THE FOLLOWING DESCRIBED THREE TRACTS OF REAL ESTATE LYING AND
B&TJrG SITUATE IN SOUTHAMPTON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA
8001DED'AND LIMITED AS FOLLOWS;
TRACT NO 1: BEGINNING AT AN IRON PIN IN THE CXXTRER OF THE PUBLIC ROAD
LEADING FROM SHIPPENSBURG TO CLSVBRSBURG, KNOWN AS THE _BALTIMORE ROAD
AT' MM LINE OF LAND NOW OR FORMERLY OF ROBERT C. HEBBRLING AND DORIS
J- NBFRLING HIS WIFE THENCE ALONG SAID LANDS NOW OR FORMERLY OF
HSB=ING SOUTH 17 DEGREES 45 MINUTES WEST A DISTANCE OF 150 FEET TO
AN LRON PIN AT LANDS NOW OR FORMERLY OF LESLIE D. SHOAP AND HAZEL V.
SEICNP HIS WIFE AM L. RICHARD SHOA.P SINGLE MAN THENCE BY SAID- LANDS
NOW OR FORMERLY OF SHOAP SOUTH 72 DEGREES 15 MINUTES EAST A DISTANCE
OF 75 FEET TO AN IRON PIN AT OTHER LANDS NOW OR FORMERLY OF THE SAID
SSW TRENCH BY THE SAME NORTH 17 DEGREES 45 MINUTES EAST A DISTANCE
OF 150 FEET TO AN IRON PIN IN THE CENTRRR OF THE AFORESAID PUBLIC
ROAD; THENCE ALONG THE CENTRER OF AFORESAID PUBLIC ROAD NORTH 72
DEGREES 15 MINUTES WEST A DISTANCE OF 75 FEET TO AN IRON PIN, THE
PLACE OF BEGINNING
TRACT NO. 2
BEGINNING AT A POINT IN THE CENTER OF THE PUBLIC ROAD LEADING FROM
SKIPPENSBURG TO CLVERSBURG, KNOWN AS BALTIMORE ROAD AT LINE OF OTHER
LADID NOW OR FORMERLY OF JOHN L. STINE AND MILDRBD V. STINE HIS WIFE,
TMNCS ALONG THE SAME SOUTH 17 DEGREES 45 MINUTES WEST A DISTANCE OF
150 FEET TO A POINT AT LINE OF LAND NOW OR FORMERLY OF LESLIE D_ SHOAP
AND $AZEL V. SHOAP HIS WIFE, AND L. RICHARD SHOAP THENCE BY THE SAME
S0t?H 72 DEGREES 15 MINUTES EAST A DISTANCE OF 75 FEET TO THE POINT ON
LINE OF LAND NOW OR FORMERLY OF NORMAN EICEiE SEWER, THENCE BY THE
SANE, NORTH 17 DR,IIsES 45 MINUTES EAST A DISTANCE OF 150 FEET TO THE
POINT IN THE CENTER OF THE AFORESAID PUBLIC ROAD; THENCE BY THE CENTER
OF THE AFORESAID PUBLIC ROAD NORTH 72 DEGREES 15 MINUTES WEST A
DISTANCE OF 75 FRET TO A POINT, THE PLACE OF BEGINNING
TRACT NO 3
BEGINNING AT AN IRON PIN LOCATED ON THE SOUTHWEST CORNER OF LANDS NOW
OR FORMERLY OF LESTER SLIDERS THENCE BY LANDS NOW OR FORMERLY OF
KMETH L. GRESAMAN HIS WIFE SOUTH 18 DEGREES 49 MINUTES 01 SECONDS
WEST 50 FELT TO AN IRON PIN; THV=E BY THE SAME NORTH 71 DEGREES 10
MINUTES 59 SECONDS WEST 150 FEET TO AN IRON PIN THENCE BY LANDS NOW OR
FORMERLY OF THOMAS REILLY NORTH 18 DEGREES 49 MINUTES' 01 SECONDS EAST
50 FEET TO AN IRON PIN; TFMUCE BY OTHER LANDS NOW OR FORMERLY OF THE
SAID GSESAMAN SOUTH 71 DEGREES 10 MINUTES 59 SECONDS EAST 150 FEET TO
AN IRON PIN, THE PLACE OF BEGINNING
TAX LD# 39-36-2428-015
BEING KNOWN AS: 950 Baltimore Road, Shippensburg, PA 17257
PROPERTY ID NO.: 39-36-2428-015
TITLE TO SAID PREMISES IS VESTED IN JUSTIN D. GORDON AND AMBER
GORDON, HUSBAND AND WIFE AS JOINT TENANTS WITH FULL RIGHT OF
SURVIVORSHIP BY DEED FROM JUSTIN D. GORDON, SINGLE, NOW MARRIED
DATED 2/14/2007 RECORDED 2/26/2007 IN DEED BOOK 278 PAGE 4432.