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Home My WebLink About08-6856°/ GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866)413-2311 W W W.GOLDBECKLAW.COM DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS TRUST COMPANY AS TRUSTEE FOR HOLDERS OF MORTGAGE PASS- THROUGH CERTIFICATES, SACO 1,INC., SERIES 1999- 5, AS THEIR SUCCESSORS AND ASSIGNS PO Box 293150 Lewisville, TX 75029 Plaintiff Vs. LORI A. TRACE RONALD D. TRACE Mortgagors and Record Owners 20 West Simpson Street Mechanicsburg, PA 17055 Defendants IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE C/ tfterm No. Of -- Uhgf CIVIL ACTT MORT0AW PORLMLOOL"F NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the 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 claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRPTA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTIN = TO CO i ECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAUgM FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website hgW://www.Dhfa.ora/conswners/ho meowners/realaspx. 5). Call the Plaintiff (your lender) at 877-362-6631 and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionCa goldbecklaw com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 75182FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS TRUST COMPANY AS TRUSTEE FOR HOLDERS OF MORTGAGE PASS-THROUGH CERTIFICATES, SACO l,INC., SERIES 1999-5, AS THEIR SUCCESSORS AND ASSIGNS, PO Box 293150, Lewisville, TX 75029. 2. The names and addresses of the Defendants are LORI A. TRACE, 20 West Simpson Street, Mechanicsburg, PA 17055 and RONALD D. TRACE, 20 West Simpson Street, Mechanicsburg, PA 17055, who are the mortgagors and record owners of the mortgaged premises hereinafter described. 3. On June 21, 1996 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to SIGNET MORTGAGE CORPORATION, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1327, Page 666. The mortgage has been assigned to: DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS TRUST COMPANY AS TRUSTEE FOR HOLDERS OF MORTGAGE PASS-THROUGH CERTIFICATES, SACO 1,INC., SERIES 1999-5, AS THEIR SUCCESSORS AND ASSIGNS by assignment of Mortgage . Plaintiff is the real party in interest pursuant to a purchase or transfer of the mortgage obligation from the last record holder and an Assignment of Mortgage to Plaintiff has been and/or will be lodged for recording with the Recorder of Deeds in the ordinary course of business. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for April 01, 2008 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ..................................................................... Interest from 03/01/2008 through 11/30/2008 at 8.5000%...... Per Diem interest rate at $16.23 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph.., Late Charges from 04/01/2008 to 11/3 0/2008 _ _ _ _ _ _ _ Monthly late charge amount at $34.89 Costs of suit and Title Search ...................... ............... $69,722.75 .................$4,463.25 ................$3,486.14 ................... $353.02 ................................................ $900.00 Pro Rata MIP/PMI .........................................................................................$52.56 Escrow Advance .......................................................................................$1,874.16 NSF Charges ..................................................................................................$45.00 Recoverable Balance .................................................................................$2,682.38 Monthly Escrow amount $245.89 $83,579.26 7. If the Mortgage is reinstated prior to a Sheriff's. Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriffs Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "i_personam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. The Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983 or Act 160 of 1998. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $83,579.26, together with interest at the rate of $16.23, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. By: GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION Michael T. McKeever, Esquire, hereby states that he is attorney for PLAINTIFF in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the Verification could not be obtained within the time allowed for the filing of the pleading that he is authorized to make this verification pursuant to Pa.R.C.P 1024(c) and that the statements made in the foregoing pleading in the Civil Action in Mortgage Foreclosure are based upon the information supplied by Plaintiff and are true and correct to the best of his knowledge, information and belief. Furthermore, it is the undersigned's intention to substitute a verification from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities. Date : kn Michel T. Mc ever, Esquire PA I.D. #56129 ExhibitA ALL THAT CERTAIN Oece or parcel of land sites in the Borough of Mechanicsburg, Cumberland County, Pennsylvania, being bounded and described according to a survey made by D. P. Raffensperger, a Registered Surveyor, dated August 4, 1980, as follows to wit: BEGINNING at a drill hole on the Northeast corner of West Simpson Street (60 feet wide) and Lamont Avenue; thence extending from said point of beginning and along the East side of Lamont Avenue North 23 degrees 16 minutes 34 seconds West the distance of 133.51 feet to a railroad spike on the South side of a public alley; thence along said alley North 71 degrees 56 minutes 46 seconds East the distance of 36.00 feet to an iron pin at the corner of lands now or formerly of Cynthia P. McNaughton being House No. 18; thence along said lands South 23 degrees 16 minutes 35 seconds East the distance of 116.00 feet to a pipe; thence continuing along the same South 21 degrees 10 minutes Seat the distance of 21.50 feet to a point on the North side of West Simpson Street; thence along the said side of West Simpson Street South 78 degrees 23 minutes 35 seconds West the distance of 35.85 feet to a point the place of BEGINNING. ATTACHMENT A V r 4t J ?= ? C7 y ,. LJ ij t'T7 Co A CASE NO: 2008-06856 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS TRACE LORI A ET AL NOAH CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon TRACE LORI A the DEFENDANT , at 0009:20 HOURS, on the 21st day of November-, 2008 at 20 WEST SIMPSON STREET MECHANICSBURG, PA 17055 by handing to LORI A TRACE DEFENDANT 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 18.00 Service 10.00 Affidavit .00 Surcharge 10.00 00 la/atdo?' ??- 38 Sworn and Subscibed to before me this day of , So Answers: '0.10 o?z_ R.'Thomas Kline 11/24/2008 GOLDBECK MCCAFFERTY & MCKEEVER By: Deputy Sheriff A. D. A f CASE NO: 2008-06856 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS TRACE LORI A ET AL NOAH CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon TRACE RONALD D the DEFENDANT , at 0009:20 HOURS, on the 21st day of November-, 2008 at 20 WEST SIMPSON STREET MECHANICSBURG, PA 17055 by handing to LORI A TRACE ADULT IN CHARGE 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 6.00 Service .00 Affidavit .00 Surcharge 10.00 ?z?as?o • 00 ? 16.00 Sworn and Subscibed to before me this day of , So Answers: i:1.4. e ? 2z - , . T s 1n 11/24/2008 GOLDBECK MCCAFFERTY & MCKEEVER By: ? Deputy Sheriff A. D. In the Court of Common Pleas of Cumberland County DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS TRUST COMPANY AS TRUSTEE FOR HOLDERS OF MORTGAGE PASS- THROUGH CERTIFICATES, SACO 1,INC., SERIES 1999-5, AS THEIR SUCCESSORS AND ASSIGNS PO Box 293150 Lewisville, TX 75029 Plaintiff VS. LORI A. TRACE RONALD D. TRACE (Mortgagor(s) and Record Owner(s)) 20 West Simpson Street Mechanicsburg, PA 17055 Defendant(s) PRAECIPE FOR JUDGMENT No. 08-6856 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. Enter the Judgment in favor of Plaintiff and against LORI A. TRACE and RONALD D. TRACE by default for want of an Answer. Assess damages as follows: Debt Interest from 12/30/2008 to Date of Sale per diem at $16.23 Total (Assessment of Damages attached) $84,330.71 I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 Michael T. McKeever Attorney for Plaintiff I.D. #56129 AND NOW Q 9 _ , Judgment is entered in favor of DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS TRUST COMPANY AS TRUSTEE FOR HOLDERS OF MORTGAGE PASS-THROUGH CERTIFICATES, SACO 1,INC., SERIES 1999-5, AS THEIR SUCCESSORS AND ASSIGNS and against LORI A. TRACE and RONALD D. TRACE by default for want of an Answer and damages assessed in the sum of $84,330.71 as per the above ceNN cation. 1 1 ihonotary 75182FC 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. DATE OF THIS NOTICE: December 12, 2008 TO: LORI A. TRACE 20 West Simpson Street Mechanicsburg, PA 17055 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS TRUST COMPANY AS TRUSTEE FOR HOLDERS OF MORTGAGE PASS-THROUGH CERTIFICATES, SACO 1,INC., SERIES 1999-5, AS THEIR SUCCESSORS AND ASSIGNS PO Box 293150 Lewisville, TX 75029 vs. LORI A. TRACE RONALD D. TRACE (Mortgagor(s) and Record Owner(s)) 20 West Simpson Street Mechanicsburg, PA 17055 TO: LORI A. TRACE 20 West Simpson Street Mechanicsburg, PA 17055 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 08-6856 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 (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 75182FC 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. DATE OF THIS NOTICE: December 12, 2008 TO: RONALD D. TRACE 20 West Simpson Street Mechanicsburg, PA 17055 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS TRUST COMPANY AS TRUSTEE FOR HOLDERS OF MORTGAGE PASS-THROUGH CERTIFICATES, SACO 1,INC., SERIES 1999-5, AS THEIR SUCCESSORS AND ASSIGNS PO Box 293150 Lewisville, TX 75029 vs. LORI A. TRACE RONALD D. TRACE (Mortgagor(s) and Record Owner(s)) 20 West Simpson Street Mechanicsburg, PA 17055 TO: RONALD D. TRACE 20 West Simpson Street Mechanicsburg, PA 17055 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 08-6856 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 (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 Michael T. McKeever GOLDBECK McCAFFERTY & MCKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, LORI A. TRACE, is about unknown years of age, that Defendant's last known residence is 20 West Simpson Street Mechanicsburg, PA 17055, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: 19_ La O Un d ?L? l r VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, RONALD D. TRACE, is about unknown years of age, that Defendant's last known residence is 20 West Simpson Street Mechanicsburg, PA 17055, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: 2''? o ?? Q ?/ GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS TRUST COMPANY AS TRUSTEE FOR HOLDERS OF MORTGAGE PASS- THROUGH CERTIFICATES, SACO 1,INC., SERIES 1999-5, AS THEIR SUCCESSORS AND ASSIGNS PO Box 293150 Lewisville, TX 75029 Plaintiff vs. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE LORI A. TRACE RONALD D. TRACE (Mortgagor(s) and Record owner(s)) 20 West Simpson Street Mechanicsburg, PA 17055 No. 08-6856 Defendant(s) ORDER FOR JUDGMENT Please enter Judgment in favor of DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS TRUST COMPANY AS TRUSTEE FOR HOLDERS OF MORTGAGE PASS- THROUGH CERTIFICATES, SACO I,INC., SERIES 1999-5, AS THEIR SUCCESSORS AND ASSIGNS, and against LORI A. TRACE and RONALD D. TRACE for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of service of the Complaint, in the sum of $84,330.71. ? Q - q!M9n Michael T. McKeever Attorney for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS TRUST COMPANY AS TRUSTEE FOR HOLDERS OF MORTGAGE PASS-THROUGH CERTIFICATES, SACO 1,INC., SERIES 1999-5, AS THEIR SUCCESSORS AND ASSIGNS PO Box 293150 Lewisville, TX 75029 and that the name(s) and last known address(es) of the Defendant(s) is/are LORI A. TRACE, 20 West Simpson Street Mechanicsburg, PA 17055 and RONALD D. TRACE, 20 West Simpson Street Mechanicsburg, PA 17055; ? KIM U :- \---, iz/] GOLDBECK McCAFFERTY & MCKEEV R BY: Michael T. McKeever Attorney for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance Interest from 03/01/2008 through 12/29/2008 $69,722.75 $4,933.92 Reasonable Attorney's Fee Late Charges Costs of Suit and Title Search Escrow Payments Due 1 X $245.89 Pro Rata MIP/PMI Escrow Advance NSF Charges Recoverable Balance $3,486.14 $387.91 $900.00 $245.89 $52.56 $1,874.16 $45.00 $2,,682.38 $84,330.71 q&?MAl ? ` howL n GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff AND NOW, this ?l3'} day of ?- , 2008 damages are assessed as above. P o Prothy 7 4t, cn? ?' i e-? PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS TRUST COMPANY AS TRUSTEE FOR HOLDERS OF MORTGAGE PASS- THROUGH CERTIFICATES, SACO 1,INC., SERIES 1999-5, AS THEIR SUCCESSORS AND ASSIGNS PO Box 293150 Lewisville, TX 75029 Plaintiff vs. LORI A. TRACE RONALD D. TRACE Mortgagor(s) and Record Owner(s) 20 West Simpson Street Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-6856 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 12/30/2008 to Date of Sale per diem at $16.23 $84,330.71 (Costs to be added) U0 U 7- W GOLDBECK McCAFFERTY & MCKEEVER BY: Michael T. McKeever Attorney for Plaintiff Q ? rn d o . ? Cz7 W ,-. F a oo¢?' U «, ,n v W p w CO H?wU 0 ¢ 0 vQQF. °? oa ao ? ? O I Nu ?rA c i? a? q. ?4A O ?W ++ U W o oU? z o 03? ° w ¢xa ? w w P-4 H W?WU xWHxQ U a A E.., ?? to r- JC ? - L C-.) ?- y F-- C=) + C.L. LL- C H cUd v ? tU U y O N w o H O N r-., ?o a W 0 % to 400000 8 (? O ocn pin r nM-t- c6 `? U -f- 3 rl P CY/ ALL THAT CERTAIN piece or parcel of land situate in the Borough of Mechanicsburg, Cumberland County, Pennsylvania, being bounded and described according to a survey made by D. P. Raffensperger, a Registered Surveyor, dated August 4, 1980, as follows, to wit: BEGINNING at a drill hole on the Northeast corner of West Simpson Street (60 feet wide) and Lamont Avenue; thence extending from said point of beginning and along the East side of Lamont Avenue North 23 degrees 16 minutes 34 seconds West the distance of 133.51 feet to a railroad spike on the South side of a public alley; thence along said alley North 71 degrees 56 minutes 46 seconds East the distance of 36.00 feet to an iron pin at the corner of lands now or formerly of Cynthia P. McNaughton being House No. 18; thence along said lands South 23 degrees 16 minutes 35 seconds East the distance of 116.00 feet to a pipe; thence continuing along the same South 21 degrees 10 minutes East the distance of 21.50 feet to a point on the North side of West Simpson Street; thence along the said side of West Simpson Street South 78 degrees 23 minutes 35 seconds West the distance of 35.85 feet to a point the place of BEGINNING. TAX PARCEL #: 16-23-0565-088 PROPERTY ADDRESS: 20 WEST SIMPSON STREET, MECHANICSBURG, PA 17055 Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS TRUST COMPANY AS TRUSTEE FOR HOLDERS OF MORTGAGE PASS-THROUGH CERTIFICATES, SACO 1,INC., SERIES 1999-5, AS THEIR SUCCESSORS AND ASSIGNS PO Box 293150 Lewisville, TX 75029 Plaintiff vs. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE LORI A. TRACE RONALD D. TRACE (Mortgagor(s) and Record Owner(s)) 20 West Simpson Street Mechanicsburg, PA 17055 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 08-6856 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS TRUST COMPANY AS TRUSTEE FOR HOLDERS OF MORTGAGE PASS-THROUGH CERTIFICATES, SACO 1,INC., SERIES 1999-5, AS THEIR SUCCESSORS AND ASSIGNS, Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 20 West Simpson Street Mechanicsburg, PA 17055 1.Name and address of Owner(s) or Reputed Owner(s): LORI A. TRACE 20 West Simpson Street Mechanicsburg, PA 17055 RONALD D. TRACE 20 West Simpson Street Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: LORI A. TRACE 20 West Simpson Street Mechanicsburg, PA 17055 RONALD D. TRACE 20 West Simpson Street Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: BANKERS TRUST COMPANY 3 Park Plaza 16th Floor Irvine, CA 92714 BANKERS TRUST COMPANY 7105 Corporate Drive PTX B 35 Plano, TX 75024 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. TENANTS/OCCUPANTS 20 West Simpson Street Mechanicsburg, PA 17055 (attach separate sheet if more space is needed) 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. Section 4904 relating to unworn falsification to authorities. DATED: December 29, 2008 V A i M a p I-. \A U C /\ GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff C? r l . CX2 r d ' l T r ( ? --i CJT 08-6856 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS TRUST COMPANY AS TRUSTEE FOR HOLDERS OF MORTGAGE PASS-THROUGH CERTIFICATES, SACO I,INC.,. SERIES 1999-5, AS THEIR SUCCESSORS AND ASSIGNS PO Box 293150 Lewisville, TX 75029 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE vs. LORI A. TRACE RONALD D. TRACE Mortgagor(s) and Record Owner(s) Term No. 08-6856 20 West Simpson Street Mechanicsburg, PA 17055 Defendants; THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: TRACE, LORI A. LORI JL TRACE 20 West Simpson Street Mechanicsburg, PA 17055 Your house at 20 West Simpson Street, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, June 10, 2009, at 10:00 AM, in Commissioners Hearing Rm. 2nd FL Courthouse to enforce the court judgment of $84,330.71 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS TRUST COMPANY AS TRUSTEE FOR HOLDERS OF MORTGAGE PASS-THROUGH CERTIFICATES, SACO 1,INC., SERIES 1999-5, AS THEIR SUCCESSORS AND ASSIGNS against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE Y, 08-6856 To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS TRUST COMPANY AS TRUSTEE FOR HOLDERS OF MORTGAGE PASS-THROUGH CERTIFICATES, SACO 1,INC., SERIES 1999-5, AS THEIR SUCCESSORS AND ASSIGNS, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause, You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below 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 NOT 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 price by calling the Sheriff of 717-240-6390. 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 the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a 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 thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.orgJforeclosure/ 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 08-6856 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 08-6856 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website htlp://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at 877-362-6631 and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866413-2311 or via email at homeretention(a,goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 7518217C. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. ? { C`? r?. ? ..? ?.?, * ?i . f ..fir ;'t"1 : . F. _. L° ? ? --?, ,.- 08-6856 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff DEUTSCHE BAND. NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS TRUST COMPANY AS TRUSTEE FOR HOLDERS OF MORTGAGE PASS-THROUGH CERTIFICATES, SACO 1,INC., SERIES 1999-5, AS THEIR SUCCESSORS AND ASSIGNS PO Box 293150 Lewisville, TX 75029 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE VS. LORI A. TRACE RONALD D. TRACE Mortgagor(s) and Record Owner(s) Term No. 08-6856 20 West Simpson Street Mechanicsburg, PA 17055 Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: TRACE, RONALD D. RONALD D. TRACE 20 West Simpson Street Mechanicsburg, PA 17055 Your house at 20 West Simpson Street, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, June 10, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $84,330.71 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS TRUST COMPANY AS TRUSTEE FOR HOLDERS OF MORTGAGE PASS-THROUGH CERTIFICATES, SACO 1,INC., SERIES 1999-5, AS THEIR SUCCESSORS AND ASSIGNS against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 08-6856 To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS TRUST COMPANY AS TRUSTEE FOR HOLDERS OF MORTGAGE PASS-THROUGH CERTIFICATES, SACO 1,INC., SERIES 1999-5, AS THEIR SUCCESSORS AND ASSIGNS, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below 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 NOT TAKE PLACE. I . If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 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 the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a 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 thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: hm://www Rhiladelphiafed orp-/foreclosure/ 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 08-6856 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 08-6856 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website htip://www.phfa.org,/conswners/homeowners/real.Wx. 5). Call the Plaintiff (your lender) at 877-362-6631 and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 75182FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. f"? ? <::) t'... _ ? cv ?? x;" Q -r-a - ? ? W `'; O :f ?. ? ??`'? C.,? - ?% L? _ ? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-6856 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, f/Wa BANKERS TRUST COMPANY, as Trustee for HOLDERS OF MORTGAGE PASS-THROUGH CERTIFICATES, SACO 1, INC., SERIES 1999-5, AS THEIR SUCCESSORS AND ASSIGNS Plaintiff (s) From LORI A. TRACE and RONALD D. TRACE (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 $84,330.71 L.L. $.50 Interest from 12/30/08 to Date of Sale per diem at $16.23 Atty's Comm % Due Prothy $2.00 Atty Paid $173.00 Other Costs to be added Plaintiff Paid Date: 12/30/08 urtis R. Long, rot onotary (Seal) By: REQUESTING PARTY: Name: MICHAEL T. McKEEVER, ESQUIRE Address: GOLDBECK McCAFFERTY & McKEEVER SUITE 5000-MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Deputy Telephone: 215-627-1322 Supreme Court ID No. 56129 GOLDBECK McCAFFERTY & McKEEVER Professional Corporation ATTORNEY FOR PLAINTIFF By: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6303 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS TRUST COMPANY AS TRUSTEE FOR HOLDERS OF MORTGAGE PASS- THROUGH CERTIFICATES, SACO 1,INC., SERIES 1999-5, AS THEIR SUCCESSORS AND ASSIGNS IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY Term No. 08-6856 PO Box 293150 Lewisville, TX 75029 VS. LORI A. TRACE and RONALD D. TRACE Mortgagor(s) and Record Owner(s) 20 West Simpson Street Mechanicsburg, PA 17055 PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification to Plaintiff s Complaint filed on November 20, 2008 in the above captioned matter. GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff GOLDBECK McCAFFERTY & McKEEVER Professional Corporation By: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6303 ATTORNEY FOR PLAINTIFF DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS TRUST COMPANY AS TRUSTEE FOR HOLDERS OF MORTGAGE PASS- THROUGH CERTIFICATES, SACO 1,INC., SERIES 1999-5, AS THEIR SUCCESSORS AND ASSIGNS PO Box 293150 Lewisville, TX 75029 VS. LORI A. TRACE and RONALD D. TRACE Mortgagor(s) and Record Owner(s) 20 West Simpson Street Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY Term No. 08-6856 CERTIFICATION OF SERVICE I certify that a true and correct copy of Plaintiff's Praecipe to Substitute Verification to Plaintiff's Complaint was served on Defendant(s) via first class mail on February 26, 2009 as follows: LORI A. TRACE 20 West Simpson Street Mechanicsburg, PA 17055 RONALD D. TRACE 20 West Simpson Street Mechanicsburg, PA 17055 GOLDBECK McCAFFERTY & McKEEVER Michael T. McKeever Attorney for Plaintiff VERIFICATION I,- as the representative of the servicing agent for the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unworn falsification to authorities. Date: DEUTSCH ANK NATIONAL TRUST COMPANY S TRUSTEE, F/K/A BANKERS TRUST COMPANY AS TRUSTEE FOR HOLDERS OF MORTGAGE PASS-THROUGH CERTIFICATES, SACO 1,INC., SERIES 1999-5, AS THEIR SUCCESSORS AND ASSIGNS, BY EMC MORTGAGE CORPORATION AS ATTORNEY IN FACT. #75182FC LORI A. TRACE and RONALD D. TRACE 20 West Simpson Street Mechanicsburg, PA 17055 ?? ? t'.'? ?- rT tz? : 7 i k r ., ? - ? ? ; T' ?. -. ` ti j . ; r ? r -?'` ? :za -.? ..? v' GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 75182FC CF: 11/20/2008 SD: 06/10/2009 $84,330.71 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS TRUST COMPANY AS TRUSTEE FOR HOLDERS OF MORTGAGE PASS-THROUGH CERTIFICATES, SACO 1,INC., SERIES 1999-5, AS THEIR SUCCESSORS AND ASSIGNS PO Box 293150 Lewisville, TX 75029 vs. LORI A. TRACE RONALD D. TRACE Mortgagor(s) and Record Owner(s) 20 West Simpson Street Mechanicsburg, PA 17055 Plaintiff Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Term No. 08-6856 Michael T. McKeever, Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: Personal Service by the Sheriffs Office%eteat a,(copy of return attached). ( ) Certified mail by Michael T. McKeever (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Michael T. McKeever, Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by Michael T. McKeever (original receipt(s) for Certified Mail attached). ( ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Michael T. McKeever, Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, BY: Michael T. McKeever, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 4 ?? $oc z ¦No 0w . ? U) Lb Lb R o ?1JNfl O O ? ? E ?m m il t i H W E? W CD CN. E E' z LL 0 to 0. wt: co Ls 10 0 U U O 0 am v aI a mom, v ea W ?: ?a w Q Li ~M toi. rn H U o? ?v?m a- 0 0 $ O - 2 Li ?tL 0° U' 0e?!-? a I o S 1b 'c -- - x tt m vCO of WZ o? W wtm? m OX S 74 c o m _ J? aorai? , i as SU03 p co .'z wN a -- .`..pin i 2 a ;a ?a Z LLJ oN ?a ? cA Q ruair <0 21mi WQ(YWto CO roQo? E°?m go ;2 05C=a, 0a)Y.-a- N ri . V: ui co E° Z '11 z? A a a° g a a a s a rn O N _O CD O w m ?a W N O C F+ r 3 O U 0 '0 J s z a 0 E U W 06 a1 U ri U ~ N Q U 00 a 1 *1 . ri I In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2008-6856 Civil Term Deutsche Bank National Trust , as Trustee fVa Bankers Trust Corn as 1, Inc,., Series 1999-5, As Their Successors and Assigns Vs Lnri A TrarP and Ronald P Trace Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on January 31, 2009 at 1148 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Lori A. Trace and Ronald D. Trace,, by making known unto Lori Tnee, pamftffi'ly and as Adult in ohmp, V* 20 West simpsoll Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on April 4, 2009 at 1026 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 Lori A. Trace and Ronald D. Trace, located at, 20 West Simpson Street, Mechanicsburg, Cumberland County, Pennsylvania according to law. 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 defendants, to wit: Lori A. Trace and Ronald D. Trace, by regular mail to their last known address of 20 West Simpson Street, Mechanicburg, PA 17055. This letter was mailed under the date of April 1, 2009 and never returned to the Sheriffs Office So Answers, ?000"'??" R. Thomas Kline, S eriff ;' 1 Restate Coordinator GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS TRUST COMPANY AS TRUSTEE FOR HOLDERS OF MORTGAGE PASS-THROUGH CERTIFICATES, SACO 1,INC., SERIES 1999-5, AS THEIR SUCCESSORS AND ASSIGNS PO Box 293150 Lewisville, TX 75029 Plaintiff LORI A. TRACE RONALD D. TRACE Mortgagor(s) and Record Owner(s) vs. 20 West Simpson Street Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-6856 AFFIDAVIT PURSUANT TO RULE 3129 DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS TRUST COMPANY AS TRUSTEE FOR HOLDERS OF MORTGAGE PASS-THROUGH CERTIFICATES, SACO 1,INC., SERIES 1999-5, AS THEIR SUCCESSORS AND ASSIGNS, Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 20 West Simpson Street Mechanicsburg, PA 17055 1.Name and address of Owner(s) or Reputed Owner(s): LORI A. TRACE 20 West Simpson Street Mechanicsburg, PA 17055 RONALD D. TRACE 20 West Simpson Street Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: LORI A. TRACE 20 West Simpson Street Mechanicsburg, PA 17055 RONALD D. TRACE 20 West Simpson Street Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: BANKERS TRUST COMPANY 7105 Corporate Drive PTX B 35 Plano, TX 75024 BANKERS TRUST COMPANY 3 Park Plaza 16th Floor Irvine, CA 92714 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. TENANTS/OCCUPANTS 20 West Simpson Street Mechanicsburg, PA 17055 (attach separate sheet if more space is needed) 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. Section 4904 relating to unworn falsification to authorities. DATED: May 27, 2009 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff rl. t _ i ,f,?? ?_„? r ? + n u J , 1 ? ti' ? ?' ?..? s , L..l.:i?s'?; It ,i,w;_ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which DEUTSCHE BANK NATIONAL TR CO TR is the grantee the same having been sold to said grantee on the 10TH day of JUNE A.D., 2009, under and by virtue of a writ Execution issued on the 30TH day of DEC, A.D., 2008, out of the Court of Common Pleas of said County as of Civil Term, 2008 Number 6856, at the suit of DEUTSCHE BANK NATIONAL TR CO TR against LORI A TRACE & RONALD D is duly recorded as Instrument Number 200922889. IN TESTIMONY WHEREOF, I have hereunto set my hand an heal of said office this day of A.D.1 -, Z/ Reorder of Deeds H4U- 14z( el +aos, A W Av3rand County, CaJli * PA 14 Conwi"w E pi,, *w FWM Mwdey of Jan. 2010 qk In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2008-6856 Civil Term Deutsche Bank National Trust Company, as Trustee f/k/a Bankers Trust Company as Trustee for holders of Mortgage Pass-Through Certificates, SACO 1, Inc,., Series 1999-5, As Their Successors and Assigns Vs Lori A. Trace and Ronald D. Trace Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on January 31, 2009 at 1148 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Lori A. Trace and Ronald D. Trace, , by making known unto Lori Trace, personally and as Adult in charge, at, 20 West Simpson Street, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on April 4, 2009 at 1026 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 Lori A. Trace and Ronald D. Trace, located at, 20 West Simpson Street, Mechanicsburg, Cumberland County, Pennsylvania according to law. 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 defendants, to wit: Lori A. Trace and Ronald D. Trace, by regular mail to their last known address of 20 West Simpson Street, Mechanicburg, PA 17055. This letter was mailed under the date of April 1, 2009 and never returned to the Sheriff s Office R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on June 10, 2009 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Michael McKeever, on behalf of Deutsche Bank National Trust Company, as Trustee, F/K/A Bankers Trust Company, as Trustee for Holders of Mortgage Pass-Through Certificates, SACO 1, Inc., Series 1999-5, as their Successors and Assigns of P.O. Box 293150, Lewisville, TX 75029 being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $ 952.97 Sheriff's Costs: Docketing 30.00 Poundage 18.69 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 48.00 Auctioneer 10.00 Law Library .50 z Prothonotary 2.00 Milage 18.00 Levy 15.00 Surcharge 30.00 Law Journal 355.00 Patriot News 305.85 Share of Bills 15.43 Distribution of Proceeds 25.00 Sheriff's Deed 49.50 952.97 So Answers, R. Thomas Kline, Sheriff By - Real Estate Coordinator 7100"q (?', r'? N c7 f.. -i cp' w5?3`i 7 0 Gidh?cl: ?1?('<ff?:rt?;E?tcKce?uHY: Michael I.:11cKcc?cr :lttornc?1.D. r,->6129 Suite SOUO -- ;1lcllon Independence ('utter 7()1 Market Strcct Philadelphia, P,A 19106 215-627-13.1 Attornc% loo Plaintiff OFLF'l S('111: BANK NATION_ 1, -CR( I ST COMPANY AS TRUSTH.:, F'K'A HANKI,RS I RUS I COMPANY ASTRUSTIT FOR 11011)1`16 OF \I()R"I GA(JI: PASS-THROUGH CFRTIFIC,ATFS. S.ACO LINC.. SFRIFS 1999-5. AS THEIR SUCCISSORS AND ;ASSIGNS PO Rox 293150 LeWls%illc. I'X 75029 IN T11F COIiR I OI C?J?1;?ION PLEAS ofCunthcrl?uui ('uunl? CIVIL ACTION - I-AW Plaintiff vs. LORI A. "CRACK: RONALD I). TRACL (Mortgagor(s) and Record Owner(s)) 20 West Simpson Street Mechanicsburg, PA 17055 N() - 0S-6556 Defendant(s) AFFIDAVIT PURSUAN,I'TO RULE, 3129 DLUI SCHE BANK NATIONAL CRUST COMPANY AS TRUSTFF. F'K%A BANKERS TRUST COMPANY AS TRUSTEE FOR HOLDERS OF MORTGAGE PASS THROUGH CERTIFICATES, SACO ],INC., SERIES 1999-5. AS THEIR SUCCESSORS AND ASSIGNS. Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at 20 West Simpson Street Mechanicsburg, PA 17055 LName and address of Owner(s) or Reputed Owner(s): LORI A. TRACE 20 West Simpson Street Mechanicsburg, PA 17055 RONALD D. TRACE 20 West Simpson Street Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: LORI A. TRACE 20 West Simpson Street Mechanicsburg, PA 17055 ACTION OF MO1; CGAG1: I OIZh:CLOSU1l11 RONALD D. TRACE 20 West Simpson Street Mechanicsburg, PA 17055 Name and last known addI ofe%er% judgment ?Icdit(,: ju?iIII cnt i,? a rr( r,rcl lien he }?r??t??rty t?? he :?,ld: Ii:ANKI:RS I RUS I )NIPANM Park Plaza l 6th Floor Ir6 ine. C.1 O_'-14 I3ANK1:RS TR11S"I C( )N11':ANl 7105 Corporate [)rive P1x13: Plane..1,X _024 llOytl=S I W RH A 11()NS 01 CL!!?1131 R1-:ANU CUUN I PO Rox 32u Carlisle. PA I ?01 , PA 0I:PAR-l NILNT ( )I PUBLIC \VI I I ARI - 131.11-eau Of( hild Support Enforcement Health and Wclfarc 131d?z. - Room 4)2 1,J). Ro.x 2075 Ilarrisburg. P:1 17105-20, 15 4. Name and address Of tile last recorded holdcr ofCVcl-v mortgage ohrccol-d: 5. Name and address of every other person «ho has anv record may be a interest in or record lien on the propert'? and %khose interest ffected by the sale: 6. Name and address of every other person of %vhorn the plaintiff has knov?,ledge who has any record interest in the property which may be affected by the sale. 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. TENANTS/OCCUPANTS 20 West Simpson Street Mechanicsburg, PA 17055 (attach separate sheet if more space is needed) 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. Section 4904 relating to unsworn falsification to authorities. DATED: December 29, 2008 U , GOLDBECK McCAFFERTY &. McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff U`-( (? ?6 GOLDBECK NIcCAFFERTY & 1\ KEEVER BY': Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia. PA 19106 215-825-6314 Attornev for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE. F%K/A BANKERS 7 RUST COMPANY AS TRUSTEE FOR HOLDERS OF MORTGAGE PASS-THROUGH CERTIFICATES, SACO 1,INC., SERIES 1999-5, AS THEIR SUCCESSORS AND ASSIGNS PO Box293150 Lewisville, TX 75029 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW Plaintiff ACTION OF MORTGAGE FORECLOSURE vs. LORI A. TRACE RONALD D. TRACE Mortgagor(s) and Record Owner(s) Term No. 08-6856 20 West Simpson Street Mechanicsburg, PA 17055 Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: TRACE, LORI A. LORI A. TRACE 20 West Simpson Street Mechanicsburg, PA 17055 Your house at 20 West Simpson Street, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, June 10, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $84,330.71 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS TRUST COMPANY AS TRUSTEE FOR HOLDERS OF MORTGAGE PASS-THROUGH CERTIFICATES, SACO LINC., SERIES 1999-5, AS THEIR SUCCESSORS AND ASSIGNS against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE (),-() S ?, 6 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against vou, you still may be able to SAVE YOUR HOME FROM FORECLOSURE 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gyov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http:!/www.phfa.org%'consumers/homeowners/reahaspx. >). Call the Plaintiff (your lender) at 877-3362-663 1 and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(&?goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 75182FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ALL ITAf CERTAIN piece or parcel of land situate in the Borough ??f Nlechanicshur<<, Cumberland County, Pennsylyania_ being bounded and described according to a sure c made by D. P. Raftensperger. a Registered Surveyor, dated August 4, 1980, as fiollo", to wit: BF-:GINNING at a drill hole on the Northeast corner of Nest Simpson Street (60 feet wide) and Lamont A\cnue: thence exteriding from said point of heginninL, and along the East side o1 Lamont Avenue North 23 dcwvcs 16 minutes 34 seconds West the distance of 133.51 feet to a railroad spike on the South side of a public alley: thence along said alley North 71 degrees 56 minutes 46 seconds East the distance of 36MO feet to an On pin at the corner of lands no%v or formerly of Cynthia P. NONaughton being House No. 1 S: thence along said lands South 23 degrees 16 minutes 35 seconds Fast the distance of 1 16.00 feet to a pipe: thence continuing along the same South 2 1 degrees M minutes East the distance of 21.50 feet to a point on the North side of West Simpson Street: thence along the said side of West Simpson Street South 78 degrees 23 minutes 35 seconds West the distance of 35.85 feet to a point the place of BEGINNING. TAX PARCEL t?: 16-23-0565-085 PROPERTY ADDRESS: 20 'VEST SIMPSON STREET, MECHANICSBURG, PA 17055 GOLDBECK McCAFFERTY & McKEEVER 13Y: Michael T. McKee%cr -\ttomev I.D.4:56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-63 t 8 :Attorney for Plaintiff 08-056 DEUTSCIE BANK NATIONAL TRUST COMPANY AS TRUSTEE, FiKiA BANKERS TRUST COMPANY AS TRUSTEE FOR HOLDERS OF MORTGAGE PASS-THROUGH CERTIFICATES, SACO 1,INC., SERIES 1999-5 AS THEIR SUCCESSORS AND ASSIGNS PO Box 293150 Lewisville. TX 75029 Plaintiff IN THE COURT OF COMMON PLI-\S of Cumberland Cottttty CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE vs. LORI A. TRACE RONALD D. TRACE Mortgagor(s) and Record Owner(s) Term No. 08-6856 20 West Simpson Street Mechanicsburg, PA 17055 Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: TRACE, RONALD D. RONALD D. TRACE 20 West Simpson Street Mechanicsburg, PA 17055 Your house at 20 West Simpson Street, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, June 10, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $84,330.71 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS TRUST COMPANY AS TRUSTEE FOR HOLDERS OF MORTGAGE PASS-THROUGH CERTIFICATES, SACO 1,INC., SERIES 1999-5, AS THEIR SUCCESSORS AND ASSIGNS against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE V o prevent this Sheriffs Sale v,ou must take iiZimcdlate action O(?-6850 I. fhe sale will be cancelled if you pav to DI UTSCI-111 IiANK NAI-ZONAL fRUS1 CON'IP.,\N1' AS TRI ISTEL. F K A BANKFRS TRUST COMPANY AS TRUS fI E F01) HODERS ()I- _ MORTGAGE PASS-THROUGH CFR1 IFICATES. SAGO LIN('.. SI=,RIES 1999-?. AS THEIR SUCCESSORS AND .-ASSIGNS, the back pw rnents_ late charges. costs and reasonable attorney's fees due, To find out how much vott must pav call our office at 213-x_25 0321) or 1-M6-413-23 1 1 . 2. You may be able to stop the sale by tilim" a petition asking' the Court to strike or open judgment. if the judgment vas improperly entered. You may also ask the Court to postpone the sale for >ood cause. i You may also be able to stop the sale through other legal proceedim-,s 4. You may need an attorney to assert your rights. The sooner you contact one_ the more chance you Will have of stopping the sale. (See notice below on how to obtain an attomev). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAN E OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT 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 price by calling the Sheriff of 717-240-0390. 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 the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff. you will remain the owner of the property as if the sale never happened. ?. You have a 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 thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/'foreclosure/ 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 08-6856 LEGAL SLRVICF,S INC S 11-N ille Row Carlisle. PA 17013 17-243-9400 r . 08-6856 Resources available for Homeowners in Foreclosure ACT NONV1 Even thouIJh your lender (and our client) has tiled an Action of Mortgaz(,c Foreclosure a?-,ainst "ou. you still may be able to SAVE YOUR HOME FROM FORECLOSURE. I ). Call an attorney. For referrals to a qualified attorney call either Of the lollawing numbers: or 71 7-243-9400. 2). Call the COnslrlner Credit Counseling Agency at 1-800-939-2227 for tree counseling. 3). Visit HUD'S website www.hud.«ov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agcncy also offers other loan programs that may assist homeowners in default. Please See the PHFA w•ebsite http://w??w.phfa.or consumers/homeowners.'real.aspx. 5). Call the Plaintiff (your lender) at 877-362-6631 and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-231 1 or via email at homeretention(cr(,(-)](ibecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 75182FC. Para infornacion en espanol puede communicarse con Loretta al 215-825-6344. ALL THAT CERTAIN piece or parcel of bunt situate in the Borough of MCChanil sburg, C'umherland County. Pennsylvania. being hounded and descrihed according to a surve,? made by D. P. Rattensperger. a Re<-1IStercd Su1-vC?01-. dated Au(ust 4. 1980, as f6llo?cs. to wit: RE'UNNING at a drill hole on the Northca?,t earner of west Simpson Street (60 feet ?I k1c) and Lamont A% cnuc: thence extending f un said point of heginnin , and alon., the East side of Lamont Avenue North 23 degrees 16 minutes 34 seconds West the distance of 133.51 teet to a railroad spike on the South side ofa public allcv: thence ilon- said alley North 71 degrees 56 minutes 46 seconds list the distance of 36JM feet to an 11,011 pin at the corner of lands now or Awmcdv of WOW P. McNau,-,hton being House No. 18: thence along said lands South 23 degrees 16 minutes 5 seconds Fist the distance of 1 1400 tcet to a pipe: thence continuing along the same South 21 degrees H) minutes list the distance of21.50 feet to a point on the North side of W,cst Simpson Street; thence along the said side of West Simpson Street S0u11i 78 degrees 23 minutes 35 seconds West the distance of 35.85 feet to a point the place of BEGINNING. TAX PARCEL #: 16-23-0565-058 PROPERTY ADDRESS: 20 WEST SIMPSON STREET. MECHANICSBURG, PA 17055 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 08-6856 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO TILE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY, as Trustee, f/Wa BANKERS TRUST COMPANY, as Trustee for HOLDERS OF MORTGAGE PASS-THROUGH CERTIFICATES, SACO 1, INC., SERIES 1999-5, AS THEIR SUCCESSORS AND ASSIGNS Plaintiff (s) From LORI A. TRACE and RONALD D. TRACE (I) 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 fOLInd 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 $84,330.71 L.L. S.50 Interest from 12/30/08 to Date of Sale per diem at $16.23 Any's Comm % Due Prothy $2.00 Arty Paid $173.00 Plaintiff Paid Date: 12/30/08 (Seal) REQUESTING PARTY: Name: MICHAEL T. McKEEVER, ESQUIRE Address: GOLDBECK McCAFFERTY & McKEEVER SUITE 5000-MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 Other Costs to be added urtis R. Lo? rothono ry By: Deputy Real Estate Sale # 06 On January 15, 2009 the Sheriff levied upon the defendant's interest in the real property situated in the Borough of Mechanicsburg, Cumberland County, PA Known and numbered as 20 West Simpson Street, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: January 15, 2009 By. 0S r/ Z i?'??r?u? 11I 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 hf PatNow 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 05101 /09 05/08/09 ......?ubscribed ......i . ............ Sworn to an before me thfs 12 d?y of May, 2009 A.D. Notary Public COMMONWEALTH OF PENNSYLVANIA N°OtPOCi Seal Sherrie L. darner, Notary Public City Of Harnsburg, Dauphin County W COrnmimw tacpires Nov. 26, 2011 Member, Pennsylvania Association of Notaries Real Estate Sale No. 6 Writ No. 2006-6856 Civil Term Deutsche Bank National Trust Company, as Trustee, f/k/a Bankers Trust Company as Trustee for Holders of Mortgage Pass-Through Certificates, SACO 1, Inc. Series 1999-5, As Their Successors and Assigns VS Lori A. Trace Ronald D. Trace Attorney Michael T. McKeever LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Borough of Mechanicsburg, Cumberland County, Pennsylvania, being bounded and described according to a survey made by D. P. Raffensperger, a Registered Surveyor, dated August 4, 1980, as follows, to wit: BEGINNING at a drill hole on the Northeast comer of West Simpson Street (60 feet wide) and Lamont Avenue; thence extending from said point of beginning and along the East side of Lamont Avenue North 23 degrees 16 minutes 34 seconds West the distance of 133.51 feet to a railroad spike on the South side of a public alley; thence along said alley North 71 degrees 56 minutes 46 seconds East the distance of 36.00 feet to an iron pin at the comer of lands now or formerly of Cynthia P. McNaughton being House No. 18; thence along said lands South 23 degrees 16 minutes 35 seconds East the distance of 116.00 feet to a pipe; thence continuing along the same South 21 degrees 10 minutes East the distance of 21.50 feet to a point on the North side of West Simpson Street; thence along the said side of West Simpson Street South 78 degrees 23 minutes 35 seconds West the distance of 35.85 feet to a point the place of BEGINNING. TAX PARCEL #: 16-23-0565-088 PROPERTY ADDRESS: 20 WEST SIMPSON STREET, MECHANICSBURG, PA 17055 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 and character of publication are true. SWORN TO AND SUBSCRIBED before me this 15 day of May, 20099 GEC , Notary - a " ??- z. , ' a Marie Coyne,dito r NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 201 0 REAL ESTATE SALE NO. 6 Writ No. 2008-6856 Civil Deutsche Bank National Trust Company, as Trustee, f/k/a Bankers Trust Company as Trustee for Holders of Mortgage Pass- Through Certificates, SACO 1, Inc., Series 1999-5, As Their Successors and Assigns vs. Lori A. Trace and Ronald D. Trace Atty.: Michael T. McKeever ALL THAT CERTAIN piece or par- cel of land situate in the Borough of Mechanicsburg, Cumberland Coun- ty, Pennsylvania, being bounded and described according to a survey made by D. P. Raffensperger, a Registered Surveyor, dated August 4, 1980, as follows, to wit: BEGINNING at a drill hole on the Northeast corner of West Simpson Street (60 feet wide) and Lamont Avenue; thence extending from said point of beginning and along the East side of Lamont Avenue North 23 degrees 16 minutes 34 seconds West the distance of 133.51 feet to a railroad spike on the South side of a public alley; thence along said al- ley North 71 degrees 56 minutes 46 seconds East the distance of 36.00 feet to an iron pin at the corner of lands now or formerly of Cynthia P. McNaughton being House No. 18; thence along said lands South 23 degrees 16 minutes 35 seconds East the distance of 116.00 feet to a pipe; thence continuing along the same South 21 degrees 10 minutes East the distance of 21.50 feet to a point on the North side of West Simpson Street; thence along the said side of West Simpson Street South 78 degrees 23 minutes 35 seconds West the distance of 35.85 feet to a point the place of BEGINNING. TAX PARCEL #: 16-23-0565- 088. PROPERTY ADDRESS: 20 WEST SIMPSON STREET, MECHANICS- BURG, PA 17055. 4. KML LAW GROUP, P.C. r Suite 5000 - BNY Independence Centers- tMry�Ij�; OF 701 Market Street PR THE#/L r3�r Philadelphia, PA 19106 2'l3 QC- _ Af 1 215-627-1322 I /um. 53 Attorney for Plaintiff W18E-R PENNS YN Ab UtiT Iq DEUTSCHE BANK NATIONAL TRUST IN THE COURT OF COMMON PLEAS COMPANY AS TRUSTEE, F/K/A BANKERS TRUST COMPANY AS TRUSTEE FOR OF Cumberland COUNTY HOLDERS OF MORTGAGE PASS- THROUGH CERTIFICATES, SACO 1,INC., SERIES 1999-5, AS THEIR SUCCESSORS Term AND ASSIGNS No. 08-6856 PO Box 293150 Lewisville, TX 75029 vs. LORI A. TRACE and RONALD D. TRACE Mortgagor(s) and Record Owner(s) 20 West Simpson Street Mechanicsburg, PA 17055 PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly mark the judgment in the above matter satisfied of record. 1. , By: J I; ■ L AW GROUP,P.C. ichael McKeever Pa.ID 56129 ay E.Kivitz Pa.ID 26769 Lisa Lee Pa. ID 78020 Thomas Puleo Pa.ID 27615 David Fein Pa. 1D 82628 Jill P.Jenkins Pa.ID 306588 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello,Attorney ID 313897 Attorneys for Plaintiff akk ajt- LITSCUL° KML LAW GROUP,P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6321 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS IN THE COURT OF COMMON PLEAS TRUST COMPANY AS TRUSTEE FOR HOLDERS OF MORTGAGE PASS- OF Cumberland COUNTY THROUGH CERTIFICATES, SACO 1,INC., SERIES 1999-5, AS THEIR SUCCESSORS AND ASSIGNS Term PO Box 293150 No. 08-6856 Lewisville, TX 75029 vs. LORI A. TRACE and RONALD D. TRACE Mortgagor(s) and Record Owner(s) 20 West Simpson Street Mechanicsburg, PA 17055 CERTIFICATION OF SERVICE I hereby certify that a true and correct copies of Plaintiff's Praecipe to Discontinue and End and Praecipe to Satisfy Judgment was sent by first class mail, postage pre-paid, upon the following on the date listed below: LORI A. TRACE 20 West Simpson Street Mechanicsburg, PA 17055 RONALD D. TRACE 20 West Simpson Street Mechanicsburg, PA 17055 By: //i / t. KML LAW !r"OUP,P.C. Angela Smith—Legal Assistant asmith @kmllawgroup.com 215-825-6325 (Direct Phone) 215-627-7734(Main Fax) Date: 9/30/2013 KML LAW GROUP, P.C. F ILE;U-OFF(c Suite 5000—BNY Mellon Independence Center OF 1 HE PROTHONOTARY 701 Market Street OCT Philadelphia, PA 19106-1532 215-627-1322 CUMBER._ a 1,p • v PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS IN THE COURT OF COMMON PLEAS TRUST COMPANY AS TRUSTEE FOR • HOLDERS OF MORTGAGE PASS- OF CUMBERLAND COUNTY THROUGH CERTIFICATES, SACO 1,INC., SERIES 1999-5, AS THEIR SUCCESSORS AND ASSIGNS PO Box 293150 No. 08-6856 Lewisville, TX 75029 Plaintiff vs. LORI A. TRACE ( RONALD D. TRACE (Mortgagor(s) and Record owner(s)) 20 West Simpson Street Mechanicsburg, PA 17055 Defendant(s) PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended without prejudice upon payment of your costs only. KML LAW GROUP,P.C. F/K/. GOLDBECK McCAFFERTY& McKEEVER il By: r ichael McKeever Pa. ID 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa. ID 78020 Thomas Puleo Pa. ID 27615 David Fein Pa.ID 82628 Jill P.Jenkins Pa. ID 306588 Alyk L.Oflazian Pa. ID 312912 Salvatore Filippello,Attorney ID 313897 Attorneys for Plaintiff KML LAW GROUP, P.C. Suite 5000—BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, F/K/A BANKERS IN THE COURT OF COMMON TRUST COMPANY AS TRUSTEE FOR PLEAS HOLDERS OF MORTGAGE PASS- OF CUMBERLAND COUNTY THROUGH CERTIFICATES, SACO 1,1NC., SERIES 1999-5, AS THEIR SUCCESSORS CIVIL ACTION - LAW AND ASSIGN S Plaintiff ACTION OF MORTGAGE vs. FORECLOSURE LORI A. TRACE No. 08-6856 RONALD D. TRACE (Mortgagor(s) and Record Owner(s)) Defendant(s) CERTIFICATE OF SERVICE Angela M. Smith , hereby certifies that he/she did serve true and correct copies of Praecipe to Discontinue and End and all supporting papers attached hereto upon Defendant, by first class mail,postage pre-paid, on q '30 _a LORI A. TRACE 20 West Simpson Street Mechanicsburg, PA 17055 RONALD D. TRACE 20 West Simpson Street Mechanicsburg,PA 17055 KML LAW GROUP,P.C. F/K/A GOL►.r:ECK McCAFF -'TY McKEEVER By: Or t f An_• a M. Smith , Legal Assistant asmith @kmllawgroup.com 215-825-6325 (Direct Phone)