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HomeMy WebLinkAbout09-0398D Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 J Chrisovalante P. Fliakos, Esq., Id. No. 94620 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 196018 DEUTSCHE BANK TRUST COMPANY AS TRUSTEE FOR RALI 2006QS 17 1100 VIRGINIA DRIVE P.O. BOX 8300 FORT WASHINGTON, PA 19034 CIVIL DIVISION TERM Plaintiff NO. 09- 3 rf ?r Cka: 1 V. CUMBERLAND COUNTY ANTHONY L. CENTURIONE, SR A/K/A ANTHONY L. CENTURIONE 142 15TH STREET UNIT G A/K/A 142 G 15TH ST NEW CUMBERLAND, PA 17070-1104 Defendant CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE ATTORNEY FOR PLAINTIFF AMERICAS COURT OF COMMON PLEAS File #: 196018 NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 File #: 196018 Plaintiff is DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS 17 1100 VIRGINIA DRIVE P.O. BOX 8300 FORT WASHINGTON, PA 19034 2. The name(s) and last known address(es) of the Defendant(s) are: ANTHONY L. CENTURIONE, SR A/K/A ANTHONY L. CENTURIONE 142 15TH STREET UNIT G A/K/A 142 G 15TH ST NEW CUMBERLAND, PA 17070-1104 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 10/31/2006 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS A NOMINEE FOR HOMECOMINGS FINANCIAL, LLC (F/K/A HOMECOMINGS FINANCIAL NETWORK, INC.) which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1972, Page 556. The PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 10/01/2008 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 196018 6 The following amounts are due on the mortgage: Principal Balance $123,904.99 Interest $3,947.16 09/01/2008 through 01/26/2009 (Per Diem $26.67) Attorney's Fees $1,300.00 Cumulative Late Charges $135.39 10/31/2006 to 01/26/2009 Property Inspections $11.25 Cost of Suit and Title Search 750.00 Subtotal $130,048.79 Escrow Credit ($67.80) Deficit $0.00 Subtotal 67.80 TOTAL $129,980.99 7 If the mortgage is reinstated prior to a Sheriffs Sale, the attorney's fee set forth above may be less than the amount demanded based on work actually performed. The attorney's fees requested are in conformity with the mortgage and Pennsylvania law. Plaintiff reserves its right to collect attorney's fees up to 5% of the remaining principal balance in the event the property is sold to a third party purchaser at Sheriffs Sale, or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. File #: 196018 9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. 10. Plaintiff hereby releases THERESA A. CENTURIONE from liability for the debt secured by the mortgage. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $129,980.99, together with interest from 01/26/2009 at the rate of $26.67 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN & SCHMIEG, LLP By: Lawrence T. Phelan, Esquire Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jenine R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire's 9?{6Zo Attorneys for Plaintiff File #: 196018 LEGAL DESCRIPTION ALL THAT CERTAIN unit in the property known, named and identified in the declaration referred to below as 'Cumberland Crossings Condominium,' located in New Cumberland Borough, Cumberland County, Pennsylvania, which has heretofore been submitted to the provisions of the Pennsylvania Uniform Condominium Act, 68 Pa. C.S.A. 3101 by the recording in the Office of the Recorder of Deeds of Cumberland County of a declaration dated March 1, 1988, and recorded on March 25, 1988, in Miscellaneous Book 347, Page 1111, as the same shall be amended from time to time, being and designated in such declaration, as the same may be amended from time to time, as Unit No. 7, also known as 142-G, which said Unit being part of said Unit, is more fully described in said declaration, as the same may be amended from time to time, together with a proportionate undivided interest in the Common Elements (as defined in said declaration, as the same may be amended from time to time). BEING THE SAME PREMISES which Scott A. Lake, a single man, by Deed dated July 1, 2003 and recorded July 3, 2003 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Record Book 257, Page 4774, granted and conveyed unto Anthony L. Centurione, Sr., a married man. UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights of way, easements and agreements of record. FURTHER UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights of way and easements as set forth on Plats and Plans - Site Plan, recorded in Plan Book 55, page 43. Parcel No.: 26-23-0541-218A-U7 PROPERTY BEING; 142 15TH STREET UNIT G, A/K/A 142 G 15TH ST File #: 196018 VERIFICATION I hereby state that I am the attorney for the 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 I am authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of my knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsifications to authorities. DATE: ( u Attorney for Plaintiff SD # q?6ZG File #: 196018 C` N acy ,'10 _N4 O G"1 C SHERIFF'S RETURN - NOT FOUND CASE NO: 2009-00398 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND J?iH DEUTSCHE BANK TRUST COMPANY AM VS CENTURIONE ANTHONY L SR ET AL i R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT CENTURIONE ANTHONY L SR A/K/A ANTHONY L CENTURIONE but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , the within named DEFENDANT ANTHONY L CENTURIONE NOT FOUND , as to CENTURIONE ANTHONY L SR A/K/A 257 WINDING WAY APT lA CAMP HILL, PA 17011 DEFENDANT DOES NOT LIVE AT GIVEN ADDRESS. HIS PARENTS LIVE AT THIS ADDRESS. Sheriff's Costs: So an r Docketing 6.00 Service 13.50 Not Found 5.00 omas Kline Surcharge 10.00 e ff of Cumberland County .00 34.50 AN HALLINAN SCHMIEG 02/02/2009. Sworn and Subscribed to before me this day of A.D. >- OD try d uj ,t Mme; a ,.-._I ? CJ'a +iLl r CO ' LA- CL cr+ C'?1 SHERIFF'S RETURN - REGULAR CASE NO: 2009-00398 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK TRUST COMPANY AM VS CENTURIONE ANTHONY L SR ET AL MICHAEL 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 CENTURIONE ANTHONY L SR A/K/A ANTHONY L CENTURIONE the DEFENDANT at 1907:00 HOURS, on the 30th day of January , 2009 at 142 15TH STREET UNIT G NEW CUMBERLAND, PA 17070-1104 by handing to ANTHONY CENTURIONE 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 Service Affidavit Surcharge Sworn and Subscibed to before me this of So Answers: 18.0 0 15.30 y .00 10.00 R. Thomas Kline .00 43.30 02/02/2009 PHELAN HALLINAN SCHMIEG By: day Deputy heriff A. D. >- ap ? Ljo F .t; I T C.: _ PHELAN HALLINAN & SCHMIEG, LLP FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS17 Plaintiff VS. ANTHONY L. CENTURIONE, SR Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO. 09-398-CIVIL CUMBERLAND COUNTY PRAECIPE TO SUBSTITUTE VERIFICATION TO CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly substitute the attached verification for the verification originally filed with the complaint in the instant matter. P Hallinan & Schmieg, LP Atto for Plaintiff B)c? Francis S. Hallinan, Esquire Date: 2/19/09 PHS #: 196018 .v PHELAN HALLINAN & SCHMIEG, LLP LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS17 Plaintiff VS. ANTHONY L. CENTURIONE, SR Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO. 09-398-CIVIL CUMBERLAND COUNTY CERTIFICATE OF SERVICE I hereby certify that a strue and correct copy of Plaintiff's Praecipe to attach Verification of Complaint was sent via first class mail to the following on the date listed below: ANTHONY L. CENTURIONE, SR 142 15TH STREET UNIT G, A/K/A 142 G 15TH ST NEW CUMBERLAND, PA 17070-1104 Hallinan & Sc w for Plaintiff By; Date: 2/19/09 J VERIFICATION Jeffrey Stephan Limited Sig ng AW001 hereby states that he/she is ?S U of HOMECOMINGS FINANCIAL, LLC, servicing agent for Plaintiff, DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR BALI 2006QS 17, in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unworn falsification to authorities. DATE: e: Jeffrey Stephan Title: Lmited Sigtuttg OMW Company: HOMECOMINGS FINANCIAL, LLC Loan: 7471217430 File #: 196018 r-.> ? ?? , =? , ` ? ?? : ? : n.? c.? ?, fLS __ .. . r S, ._.,y Phelan Hallinan & Schmieg, LLP By: Daniel G. Schmieg, Esquire Identification No. 62205 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorney for Plaintiff DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS17 VS. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION ANTHONY L. CENTURIONE, SR No. 09-398-CIVIL 14215TH STREET UNIT G A/K/A 142 G 15TH ST NEW CUMBERLAND, PA 17070-1104 PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against ANTHONY L. CENTURIONE. SR, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $129,980.99 Interest - 01/27/2009 to 03/03/2009 TOTAL $960_12 $130,941.11 I hereby certify that (1) the addresses of the Defendant( flare as shown abovg, and (2) that notice has been given in accordance with Rule 237. 1, copy attached., /i, /,? / Daniel G. Schmieg Esqu- Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: 3 t (/ PHS 11 196018 PRO PROTHY Phelan Hallinan & Schmieg, LLP By: Daniel G. Schmieg, Esquire Identification No. 62205 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorney for Plaintiff DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS17 VS. ANTHONY L. CENTURIONE, SR CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION : No. 09-398-CIVIL VERIFICATION OF NON-MILITARY SERVICE Daniel G. Schmieg, Esquire, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or it Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant ANTHONY L. CENTURIONE, SR is over 18 years of age and resides at 142 15TH STREET UNIT G, A/K/A 142 G 15TH ST, NEW CUMBERLAND, PA 17070-1104. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. _ Daniel G. Schmieg, E Attorney for Plaintiff PHELAN HALLINAN & SCHMIEG, LLP By: LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 DANIEL G. SCHMIEG, ESQ., Id. No. 62205 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-2000 ATTORNEY FOR PLAINTIFF DEUTSCHE BANK TRUST COMPANY COURT OF COMMON PLEAS AMERICAS AS TRUSTEE FOR RALI 2006QS 17 CIVIL DIVISON Plaintiff NO. 09-398-CIVIL V. ANTHONY L. CENTURIONE, SR CUMBERLAND COUNTY Defendant(s) TO: ANTHONY L. CENTURIONE, SR 142 15TH STREET UNIT G, A/K/A 142 G 15TH ST NEW CUMBERLAND, PA 17070-1104 DATE OF NOTICE: February 20, 2009 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. 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 notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 aiz?" ??< I ? 7-\ BRITTANY BOYER Legal Assistant PHS # 196018 Y903 3J19 17i W °Q ,y'. ..?.( 1. (Rule of Civil Procedure No. 236) - Revised DEUTSCHE BANK TRUST COMPANY CUMBERLAND COUNTY AMERICAS AS TRUSTEE FOR RALI 2006QS17 : COURT OF COMMON PLEAS VS. ANTHONY L. CENTURIONE, SR CIVIL DIVISION 142 15TH STREET UNIT G No. 09-398-CIVIL A/K/A 142 G 15TH ST NEW CUMBERLAND, PA 17070-1104 Notice is given that a Judgment in the above captioned matter has been entered against you on :I q0 y By: A#rjd7 -DEFU I F If you have any questions concerning this m please 4Eirce ANYINFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLYRECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOTAND SHOULD NOT BE CONSTRUED TO BEANATTEMPT TO COLLECT A DEBT, BUT ONLYENFORCEMENT OFA LIENAGAINST PROPERTY. ** Attorney or Pa1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Daniel G. Sc THIS FIRM IS A DEBT COLLECTOR A TTEMPTING TO COLLECT A DEBT AND CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) Pa.R.C.P. 3180-3183 DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS17 Plaintiff, V. ANTHONY L. CENTURIONE SR. A/K/A ANTHONY L. CENTURIONS Defendant(s). TO THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 03/04/2009 - 09/02/2009 (per diem -$21.82 ) TOTAL No. 09-398-CIVIL $130,941.11 $3,993.06 and Costs $134,9317 DANIEL G.gCHMIEGASQUIRE One Pe enter at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a presentative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. 196018 w W a? a' too O ? EU.. W 0 W? H ? o O;O W ? T?- ? A 70 QS d n O H W U x d d a owl o O Z W a x 0 W 4 H ? o nc a? U a iw W U H L7 d H ?W ?p 0 ?o ¢a • O -0 at s Q b ? a Q• 00 cr .Xti x't;' t? i --t 1 PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS17 Plaintiff, V. ANTHONY L. CENTURIONE SR. A/K/A ANTHONY L. CENTURIONE Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 09-398-CIVIL CERTIFICATION DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: 0 an FHA mortgage ( ) non-owner occupied ( ) vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. G. SQIMEG, ESQUIRE C'' == DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS17 CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS V. CIVIL DIVISION ANTHONY L. CENTURIONE SR. A/K/A ANTHONY L. CENTURIONE NO. 09-398-CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129.1 DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006OS17, Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at,14215TH STREET UNIT G A/K/A 142 G 15TH ST, NEW CUMBERLAND, PA 17070- 1104. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) ANTHONY L. CENTURIONE SR 142 15TH STREET UNIT G A/K/A ANTHONY L. CENTURIONE A/K/A 142 G 15T NEW CUMBERLAND, PA 17070-1104 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) CREDIT ONE, LL 361918 STREET METAHUE, LA 70002 4. Name and address of last recorded holder of every mortgage of record: Name None Last Known Address (if address cannot be reasonably ascertained, please indicate) 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose . interest may be affected by the sale. I Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenant/Occupant Last Known Address (if address cannot be reasonably ascertained, please indicate) 14215TH STREET UNIT G A/K/A 142 G 15TH ST NEW CUMBERLAND, PA 17070-1104 Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Internal Revenue Service Federated Investors Tower Department of Public Welfare TPL Casualty Unit Estate Recovery Program CUMBERLAND CROSSINGS 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 6`h Floor, Strawberry Sq., Dept. 28061 Harrisburg, PA 17128 13th Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, PA 15222 P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105 1 LONGSDORF WAY CARLISLE, PA 17015-7623 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 f tatemeptsllerein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unworn ?ffsificat%p t auth rities. March 24. 2009 DATE G. SOON-MG, ESQUIRE 1 R C?"?-a^ ?Y ? CF > ?' (J'y i_ C11 -'n 1, Fl } y/ I"4 e DEUTSCHE BANK TRUST COMPANY CUMBERLAND COUNTY AMERICAS AS TRUSTEE FOR RALI 2006QS17 Plaintiff, No. 09-398-CIVIL V. ANTHONY L. CENTURIONE SR. A/IUA ANTHONY L. CENTURIONE Defendant(s). March 24, 2009 TO: ANTHONY L. CENTURIONE SR. A/K/A ANTHONY L. CENTURIONE 142 15TH STREET UNIT G A/K/A 142 G 15T NEW CUMBERLAND, PA 17070-1104 **THIS FIRMIS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANYINFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANA TTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. * * Your house (real estate) at, 142 15TH STREET UNIT G A/K/A 142 G 15TH ST. NEW CUMBERLAND, PA 17070-1104, is scheduled to be sold at the Sheriffs Sale on SEPTEMBER 2, 2009 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $130,941.11 obtained by DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006OS17 (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE LEGAL DESCRIPTION ALL THAT CERTAIN unit in the property known, named and identified in the declaration referred to below as 'Cumberland Crossings Condominium; located in New Cumberland Borough, Cumberland County, Pennsylvania, which has heretofore been submitted to the provisions of the Pennsylvania Uniform Condominium Act, 68 Pa. C.S.A. 3101 by the recording in the Office of the Recorder of Deeds of Cumberland County of a declaration dated March 1, 1988, and recorded on March 25, 1988, in Miscellaneous Book 347, Page 1111, as the same shall be amended from time to time, being and designated in such declaration, as the same may be amended from time to time, as Unit No. 7, also known as 142-G, which said Unit being part of said Unit, is more fully described in said declaration, as the same may be amended from time to time, together with a proportionate undivided interest in the Common Elements (as defined in said declaration, as the same may be amended from time to time). BEING THE SAME PREMISES which Scott A. Lake, a single man, by Deed dated July 1, 2003 and recorded July 3, 2003 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Record Book 257, Page 4774, granted and conveyed unto Anthony L. Centurione, Sr., a married man. UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights of way, easements and agreements of record. FURTHER UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights of way and easements as set forth on Plats and Plans - Site Plan, recorded in Plan Book 55, page 43. TITLE TO SAID PREMISES IS VESTED IN Anthony L. Centurione, Sr., a married man, by Deed from Scott A. Lake, a single man, dated 07/01/2003, recorded 07/03/2003 in Book 257, Page 4774. PREMISES BEING: 142 15TH STREET UNIT G A/K/A 142 G 15TH ST, NEW CUMBERLAND, PA 17070-1104 PARCEL NO. 26-23-0541-218A-U7 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-398 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK TRUST COMPANY AMERICAS as Trustee ofr RALI 2006QS17, Plaintiff (s) From ANTHONY L. CENTURIONE, SR., a/k/a ANTHONY L. CENTURIONE (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 $130,941.11 L.L. $.50 Interest from 3/04/09 to 9/02/09 (per diem - $21.82) - $3,993.06 and Costs Arty's Comm % Due Prothy $2.00 Arty Paid $196.80 Other Costs Plaintiff Paid Date: 3/26/09 urtis R. Lo , rothono (Seal) By: REQUESTING PARTY: Name: DANIEL G. SCHMIEG, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 62205 Deputy AFFIDAVIT OF SERVICE PLAINTIFF DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS17 DEFENDANT(S) ANTHONY L. CENTURIONE SR. A/KIA ANTHONY 1. CENTURIONE CUMBERLAND COUNTY / No. 09-398-CIVIL ACCT. #196018 Type of Action - Notice of Sheriff's Sale SERVE ANTHONY L. CENTURIONE SR. A/K/A ANTHONY L. CENTURIONE AT: Sale Date: SEPTEMBER 2, 2009 14215TH STREET UNIT G A/K/A 142 G 15TH ST NEW CUMBERLAND, PA 17070-1104 Aq nn^_ SERVED Served and made known to K IuT+6 N 1 L_ (?f=W u R I / A Defendant, on the day of I !r 200 t at ?. o'clock +.m., at 142 Cr I s h 57. , NOW C UAV 6*A .1' u P Commonwealth of Pennsylvania, in the manner described below: Defendant personally served. Adult family member with whom Defendant(s) reside(s). Name and Relationship is Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Description: Age -44 Height 516 Weight I 1i Race W Sex Other I, R00 -p (Vl6 LL , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriff s Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subs ribed NOTARY PUBLIC before a this '?+ day STATE OF NEW JERSEY Of I L , 2001- y commission Expi ch 7, 2013 Notaw-_.k, _S_ % _ PLEAS T SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED. NOT SERVED On the day of 200_, at o'clock _.m., Defendant NOT FOUND because: Moved Unknown No Answer 1St Attempt: Time: 3rd Attempt: / Time: Sworn to and subscribed before me this day of , 200. Notary: Vacant 2"d Attempt: / / -Time: Attorney for Plaintiff DANIEL G. SCHMIEG, Esquire - I.D. No. 62205 One Penn Center at Suburban Station, Suite 1400 By: 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 FILE 10 ICE OF IHIE P?` `Tll `` oT Y 2009 APR 28 M 18* 9 _.,_, ;:, ?s rAN'A DEUTSCHE BANK TRUST COMPANY IN THE COURT OF COMMON PLEAS OF AMERICAS AS TRUSTEE FOR :CUMBERLAND COUNTY, PENNSYLVANIA RALI 20060S 17 PLAINTIFF V. ANTHONY L. CENTURIONE, SR., A/K/A ANTHONY L. CENTURIONE DEFENDANT NO. 09-398 CIVIL ORDER OF COURT AND NOW, this 19th day of July, 2010, upon consideration of the Plaintiff's Motion to Reassess Damages, IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule is issued upon the Defendant to show cause why the relief requested should not be granted; 2. The Defendant will file an answer on or before August 10, 2010; 3. If no answer to the Rule to Show cause is filed by the required date, the relief requested by Petitioner shall be granted upon the Court's receipt of a Motion requesting Rule be made Absolute. If the Defendant files an answer to this Rule to Show Cause, the Court will determine if further Order or hearing is necessary. 4. The Prothonotary is directed to forward said Answer to this Court. By the Court, ~Jenine R. Davey, Esquire Attorney for Plaintiff /Anthony L. Centurione, Sr. /k/a Anthony L. Centurione Defendant bas , ~~j ~ ~S rr-~. ~ 7~r~~~v ~~ M. L. Ebert, Jr., ~ J ~. ,..._ ~, __ ..-;- .- ,` __ - ~ Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS 17 Plaintiff v. ANTHONY L. CENTURIONE, SR A/K/A ANTHONY L. CENTURIONE Defendant W! 1- ~ L J . 1 {"~~yt r .... +. ., it ,-,~. i , _. ;a ._. ~ :.. ~ ,n ~ ~'> CD~O ~'t,',~ -,~ ail ~~' ,I~cr 3 ~prrc 4 : oa CUP - 1~v3"~` ~~ ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division CUMBERLAND County No.09-398-CIVIL CERTIFICATION OF SERVICE 196018 ,~ - ~ I hereby certify that a true and correct copy of the Rule Returnable noting a Rule Return date of August 10, 2010 was sent to the following individual on the date indicated below. ANTHONY L. CENTURIONE, SR A/K/A ANTHONY L. CENTURIONE 142 15TH STREET UNIT G A/K/A 142 G 15TH ST NEW CUMBERLAND, PA 17070-1104 DATE: '~ Z ~ ANTHONY L. CENTURIONE, SR A/K/A ANTHONY L. CENTURIONE 257 WINDING WAY, APT. lA CAMP HILL, PA 17011-8462 Phelan Hallinan & Schmieg, LLP ^ Lawrence T. Phelan, Esq., Id. No. 32227 ^ Francis S. Hallinan, Esq., Id. No. 62695 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 ATTORNEY FOR PLAINTIFF 196018 AFFIDAVIT OF SEl PLAINTIFF DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS17 DEFENDANT ANTHONY L. CENTURIONE, SR A/K/A ANTHONY L. CENTURIONE NICE CUMBERLAND COUNTY PHS # 196018 SERVICE TEAM/ 'in COURT NO.: 09-398-CIVIL SERVE ANTHONY L. CENTURIONE, SR A/K/A TYPE OF ACTION ANTHONY L. CENTURIONE AT: XX Notice of Sheriff's Sale 14215TH STREET UNIT G SALE DATE: 09/08/2010 A/K/A 142 G 15TH ST NEW CUMBERLAND, PA 17070-1104 3( S9E~RVED /, Served and made known to ~~ y ~.[F.niTNRt~befendant on the 1~`"'day of /v1I1'~ , 20 t b , at f 0 ~ 37 , o'clock 1! . M., at 142 1 S~1~- $'t : Ua,T G 1 in the manner described below: ~> _ Defendant personally served. NEwCt~Ma ~RU'u~~ Pl~~ ~ ; ~ Adult family member with whom Defendant(s) reside(s). ~'' ~~' Relationship is 5nal _ Adult in charge of Defendant's residence who refused to give name or relationship. _ _ Manager/Clerk of place of lodging in which Defendant(s) reside(s). - Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. _ Other: _-- f~J ~:_~ -- c~ , 7 ~ - ", /~~ -- y.; V ~ -~ 3 Jv .• W Lu I, _~~ LL , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Description: Age ~QS Height 5 t ION Weight ~ $0 Race W Sex ~ Other NOT SERVED On the , 20 , at o'clock _. M., Defendant NOT FOUND because: _ Vacant _ Bad Address _ Moved _ Dces Not Reside (Not Vacant) _ No Answer _ Service Refused Other: Sworn to and subscribed obeffore me this ~_ day B y: Sworn to and subsc 'bed i{]M$ERLY CURTY before me this day NOTARY PUBLiC of , 2 STATE DN: NEW IERSEY Not $y; ~'(i~Q.~_~/Y I / MY COMMIS5tON EXWRES MARCH 7, 2013 Notary: ATTORNEY FOR PLAINTIFF lawrenre T. Phebm, Esq., ld. No. 32227 Funds S. HaBtnm, Esq., ld. No. 62695 Daniel C. Sdanieg, Esq., >d. No. 62205 Mkhde M. Bradford, Esq., Id. No. 69849 Judith T. Romanq Esq., Id. Na 58745 Sheetal R Shah-Jani. Esq., Id. No. 81760 Janine R. Davey, Esq., Id. No. 67077 Iauren R. Tabas, Esq., Id. No. 93337 Vhek Sdvastava, Esq., Id. No.202331 Jay B. Jones, Eaq- Id. No. 86657 Peter ]. Mulcahy, Esq., Id. No. 61791 Andrew L Spivack, Esq., Id. No. 84439 Jabne McGutnnes; Esq., Id. No. 90134 Ch~ovalan4 P. FBakas, Feq., Id. No. 94620 Jmhue 1. Goldman, Esq., Id. No. 205047 Cou'teney R Dunn, Esq., Id. No. 206779 Andrew G Bmmbh92, Esq., id. No. 208375 One Penn Center at Subufian Station IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEUTSCHE BANK TRUST COMPANY CUMBERLAND COUNTY AMERICAS AS TRUSTEE FOR RALI 2006QS17 Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION c"~ '' c- -_ ;_¢ ANTHONY L. CENTURIONE, SR A/K/A No. 09-398-CIVIL ~ ~ ~ -__ -.~., ANTHONY L. CENTURIONE _ ~' `' Defendant(s) ~. AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 _. COMMONWEALTH OF PENNSYLVANIA ) ~ - ~,,; PHILADELPHIA COUNTY ) SS: ~ - As required by Pa. R.C.P. 3129.1(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, set forth on the Affidavit and as amended if applicable. A copy of the Certificate of Mailing (Form 381'n and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached h eto Exhi it "A". ^ Lawrence T. Phe sq., Id. No. 32227 ^ Francis S. Hallinan, Esq., Id. No. 62695 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ J dith T. Romano, Esq., Id. No. 58745 ~heetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 ~~ D Attorney for Plaintiff Date: IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff s Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PHS # 196018 DEU'~SCHE BANK TRUST COMPANY AMERICAS AS ~'RUSTEE FOR RALI 2006QS17 Plaintiff v. ANTHONY L. CENTURIONS, SR A/K/A ANTHONY L. CENTURIONS Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION N0.09-398-CIVIL CUMBERLAND COUNTY AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS17, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 14215TH STREET UNIT G A/K/A 142 G 15TH ST, NEW CUMBERLAND, PA 17070-1104. Name and address of Owner(s) or reputed Owner(s): Name 2. 3. ANTHONY L. CENTURIONS, SR A/K/A ANTHONY L. CENTURIONS SAME AS ABOVE Name and address of Defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) 14215TH STREET UNIT G A/K/A 142 G 15TH ST NEW CUMBERLAND, PA 17070-1104 257 WINDING WAY, APT. lA CAMP HILL, PA 17011-8462 Address (if address cannot be reasonably ascertained, please so indicate) Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) CREDIT ONE LLC 361918TH STREET METAIItIE, LA 70002 CREDIT ONE LLC C/O RON Z. OPHER, ESQUIRE P.O. BOX 2245 SOUTHEASTERN, PA 19399 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) BOROUGH OF NEW CUMBERLAND 1120 MARKET STREET NEW CUMBERLAND, PA 17070 BOROUGH OF NEW CUMBERLAND, c/o 127 S MARKET STREET ANDREW C. SHEELY, ESQ. PO BOX 95 MECHANICSBURG, PA 17055 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 (if address cannot be reasonably ascertained, please indicate) None. 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 (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 142 15TH STREET UNIT G A/K/A 142 G 15TH ST NEW CUMBERLAND, PA 17070-1104 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 United States Internal Revenue Special Procedures Branch Federated Investors Tower U.S. Department of Justice U.S. Attorney for the Middle District of PA Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Internal Revenue Service Federated Investors Tower Department of Public Welfare TPL Casualty Unit Estate Recovery Program CUMBERLAND CROSSING CONDOMINIUM ASSOCIATION 13th Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 6~h Floor, Strawberry Sq., Dept 28061 Harrisburg, PA 17128 13TH Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, PA 15222 P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105 142 15TH STREET NEW CUMBERLAND, PA 17070 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.A. § 4904 relating to unsworn falsification to authorities. DATE: ~ ~ By; ,~ Attorney for Plaintiff Phelan Hallinan &Schmieg, LLP ^ Lawrence T. Phelan, Esq., Id. No. 32227 ^ Francis S. Hallinan, Esq., Id. No. 62695 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^'S~heetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 ... N ` t ~ gy L~ . ~O 00 ~! O~ V1 A W N ~+ ~ p 'YQ1.' 1F 1F iF i 7F l~ A " ~ 3 MU ~! i_i ~;'d ~ ',~oW~i ~~j"00~ ~s1CC -p•~-+~lrn~+ neCA f~~'A ~-` ~ .~p 7 "C -ai~bA ~O >~ ~ C"' .e va "esP ~ m s• '->E. d • ~~ ~ ~ y~yp~,P ~ ~ ~ t7aO rgtn"'.~ ~ y e. '"~~.~s ~e m~'.~ »8. -+~ I"i a ~' ~o'`~~ Fe~$, i ~' i~a sf a oT ~<~~ Gj ~ ~A Ct~~!! a a. ~• N . , ~ ~ Z S~ ~ ~ ~ d ~ ~~ ~ A O e R M ~ ~ ~ i- ~ ~ M~ Q~ m d CC ~ e w ~, y v ~ ~ M ~ H N ~ .Oq ~ >` Q f9 a O ' c ~~~ ~~ ~ M _N ~•~ ~O h M ~ ~ ~ ,06 • ji' v ~ M e y '~w~=1 ~ . 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Ry ~ ~, 8 " ~ ' M AIL ED FR OM Oaw v,ag ce '' ~, N ~ `; c. 1 ~0~~ c~ ~ ~~~~ ~;~ 7C~ n~~ b~~~ ~ CD ~~ ~~ w ~ ~ ~~ ~~ uc ~r o t... o ,~ n b a b \` ~m ~`1~_~D-OFFICE ~~ ~'E~E F'~~CT~'OOTAR'~' Phelan Hallinan &Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS 17 v. ANTHONY L. CENTURIONE, SR. A/K/A ANTHONY L. CENTURIONE `~'ct~~~~a`fl_b't~,~! COURT OF COMMON PLEAS CIVIL DIVISION N0.09-398-CIVIL CUMBERLAND COUNTY SUGGESTION OF DEATH RE: DEFENDANT ANTHONY L. CENTURIONE, SR. A/K/A ANTHONY L. CENTURIONE .COMMONWEALTH OF PENNSYLVANIA: Plaintiff, Deutsche Bank Trust Company Americas As Trustee For RALI 2006QS 17, by its counsel, Phelan Hallinan & Schmieg, LLP, hereby certifies that, to the best of its knowledge, information and belief, the Defendant, Anthony L. Centurione, Sr. A!K/A Anthony L. Centurione, is deceased -- date of death May 16, 2010. Upon reasonable investigation and belief, Anthony L. Centurione, Sr. A/K/A Anthony L. Centurione's surviving heirs at law and next-of--kin are Theresa Centurione, Anthony Centurione, Jr., and Joseph Centurione. Dated: ~ ~ By: PHELAN HALLINAN & SCHMIEG, LLP La en a T. Phelan, Esq., Id. No.~227 Fr cis . Hallinan, Esq., Id. No. 695 Dan 1 . Schmieg, Esq., Id. No. 62205 Mich 1 M. Bradford, Esq., Id. No. 69849 Judith .Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81'j,~0 Jenine R. Davey, Esq., Id. No. 8707 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallman &Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallman, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, NA v. EUGENE H. MILLER COURT OF COMMON PLEA5 CIVIL DIVISION N0.2009-SU-001484-06 YORK COUNTY CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of Suggestion of Death Re: Anthony L. Centurione, Sr. A/K/A Anthony L. Centurione was sent via first class mail to the following on the date listed below: Theresa Centurione 257 Winding Way Camphill, PA 17011 Anthony Centurione, Jr. 142 15`}' Street, Unit G aJkla 143 G 15~` Street New Cumberland, PA 17070 Joseph Centurione 1607 Wyndham Road Camphill, PA 17011 Unknown Heirs Of Anthony Centurione, Deceased 142 15`" Street, Unit G a/k/a 143 G 15~' Street New Cumberland, PA 17070 Dated: b ~ By: La e e T. Phelan, Esq., Id. o. 32227 Fr is S. Hallinan, Esq., Id. o. 62695 Dam 1 . Schmieg, Esq., Id. No. 62205 Mich I M. Bradford, Esq., Id. No. 69844 Judith .Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 817 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 20504? Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 FILED-OFFICE OF Tr E t' :D T }icj,' i TA 2 10?,., 1 i, IL: 'COUNTY i EN'i.S YI_5 A Y?I7 Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison Wells, Esq., Id. No. 309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS17 V. ANTHONY L. CENTURIONE, SR. A/K/A ANTHONY L. CENTURIONE COURT OF COMMON PLEAS CIVIL DIVISION NO. 09-398-CIVIL CUMBERLAND COUNTY MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, Deutsche Bank Trust Company Americas As Trustee For RALI 2006QS 17, respectfully requests that this Honorable Court enter an Order granting Plaintiff's Motion for Service in the above captioned matter and in support thereof avers the following: 1. On October 31, 2006, Anthony L. Centurione and Theresa Centurion made, executed, and delivered a mortgage upon the premises at 142 15th Street Unit G a/k/a 142 G 15'h Street, New Cumberland, PA 17070. 2. The loan is in default as payments due October 1, 2008 and each month thereafter are due and unpaid. 3. On January 27, 2009, Plaintiff filed an action in mortgage foreclosure naming Anthony L. Centurione as party defendant. 4. Plaintiff did not name Theresa Centurione as a parry defendant and instead released her from liability for the mortgage in its Complaint because Theresa was not a record owner of the mortgaged premises. 5. A default judgment was entered against defendant Anthony L. Centurion on March 4, 2009. 6. Subsequently, Anthony L. Centurione died on May 16, 2010. 7. On August 18, 2010, Plaintiff was contacted by Anthony Centurione, Jr. who informed the Plaintiff that defendant Anthony L. Centurione is deceased. He advised Plaintiff that no estate had been filed, and that the defendant is survived by a spouse, Theresa Centurion, and two children, himself and Joseph Centurion. 8. Plaintiff contacted the Register of Wills of Cumberland County and was informed that no estate has been raised on behalf of Anthony L. Centurion. 9. Plaintiff performed a Good Faith Investigation in an attempt to locate any additional heirs of Anthony L. Centurione. Plaintiffs Investigator located an obituary published for the decedent in The Patriot-News that confirms the decedent is survived by Theresa Centurione, Anthony Centurione, Jr., and Joseph Centurione. Attached hereto, marked as Exhibit "A" is a true and correct copy of Plaintiff s Affidavit of Good Faith Investigation. 10. Upon information and belief, Anthony L. Centurione's surviving heirs at law are Theresa Centurione, Anthony Centurione, Jr., and Joseph Centurione. Any other parties who may have inherited an interest in the mortgaged premises are unknown to Plaintiff. 11. On October 4, 2010, Plaintiff filed a Suggestion of Death with the Cumberland County Prothonotary regarding the death of Anthony L. Centurione. Attached hereto, marked as Exhibit "B" is a true and correct copy of the Suggestion of Death. 12. Pursuant to Pennsylvania Rule of Civil Procedure 3129, it is necessary in a foreclosure action for the Sheriff to serve upon the decedent mortgagor's heirs notice of the sale of the mortgage premises in order to afford them an opportunity to bid at the sale. 13. As there may be parties with an interest in the mortgaged premises that Plaintiff may not know of, Plaintiff is herein requesting that it be permitted to serve the unknown parties by Special Order of the Court. 14. In compliance with Cumberland County Local Rule 208.3(a)(2), Plaintiff avers that the Honorable Judge M.L. Ebert, Jr. has previously entered an order granting Plaintiffs motion for reassessment on September 1, 2010. 15. In accordance with Cumberland County Local Rule 208.3(9), Plaintiff sent a copy of its proposed Motion to the parties on November 8, 2010, and requested the parties' concurrence. Plaintiff did not receive any response from the parties. A true and correct copy of Plaintiff's letter pursuant to Local Rule 208.3(9) and postmarked certificate of mailing is attached hereto, made part hereof, and marked as Exhibit "C." WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of Notice of Sheriff's Sale by regular mail and posting of the premises. PHELAN HALLINAN & SCHMIEG, LLP Dated: La By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison Wells, Esq., Id. No. 309519 Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison Wells, Esq., Id. No. 309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS 17 V. ANTHONY L. CENTURIONE, SR. A/K/A ANTHONY L. CENTURIONS COURT OF COMMON PLEAS CIVIL DIVISION NO. 09-398-CIVIL CUMBERLAND COUNTY MEMORANDUM OF LAW According to Pa.R.Civ.P. 430(a), a plaintiff may petition the court to provide an alternative to personal service if the plaintiff cannot serve a party personally. The rule requires the affidavit presented in support of the motion for alternative service to state "the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why personal service cannot be made." Pa.R.Civ.P. 430 (a). The purpose of this procedure is to provide proof that a good faith effort has been made to effect service under normal methods. Only after such proof has been offered is the Court authorized to direct another method of substitute service. Deer Park Lumber, Inc. v. Major, 384 Pa.Super. 625,559 A.2d 941, 944 (1988), appeal denied, 525 Pa. 582, 575 A.2d 113 (1990). Plaintiff has attached a report to its Motion, which sets forth the nature and extent of the investigation, which has been made to determine the whereabouts of the heirs and assigns and the reason that such service cannot be made. Any other parties with an interest in the mortgaged premises are unknown to Plaintiff. In the instant action, Plaintiff is appropriately trying to serve the unknown heirs, successors, assigns and all persons, firms, and associations claiming right title or interest from or under the decedent mortgagor as a defendant in order to convey clear and marketable title after the foreclosure sheriff s sale. Title companies customarily require foreclosing mortgagees to serve the unknown parties in order to assure that any potential party with an interest in the mortgaged premises has an opportunity to bid at the Sheriff's Sale. Finally, Plaintiff is seeking only to enforce an in rem judgment through the foreclosure of the mortgaged premises and is not pursuing a deficiency judgment in this action. WHEREFORE, Plaintiff respectfully requests this Honorable Court to grant the requested relief. PHEL LL AN & SCHMIEC3, LLP Dated: _ .0 By: Lawrence T. Phelan, Est f., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. BrambleM Esq., Id. No. 208375 Allison Wells, Esq., Id. No. 309519 cc ?? EXHIBIT A AFFIDAVIT OF GOOD FAITH INVESTIGATION File Number. 196018 Attorney Firm: Phelan, HaIlinan & Schmieg, LLP Subject: Anthony L. Centurion Sr. Property Address: 142151h Street, Unit G, AKA 142 G 15th Street New Cumberland, PA 17070 L being duly sworn according to law, do hereby depose and state as follows, an investigation into the whereabouts of the above-noted individual(s) was conducted and the following has been discovered: 1. CREDIT INFORMATION A. SOCIAL SECURITY NUMBER Our search verified the following information to be true and correct Anthony L. Centurion Sr. - xxx-xx-4001 EMPLOYMENT SEARCH Anthony L. Centurione Sr. - A review of the credit reporting agencies provided no employment information. C. INQUIRY OF CREDITORS Our inquiry of creditors indicated that Anthony L. Centurione Sr. reside(s) at: 257 Winding Way, Camp Hill, PA 17011. II. INQUIRY OF TELEPHONE COMPANY A. DIRECTORY ASSISTANCE SEARCH Our office searched directory assistance databases, which had no listing for Anthony L. Centurion Sr. B. On 08-27-10,08-30-10,08-31-10,09-M-10, 09-02-10 & 09-03-10 our office made several telephone calls to a possible phone number of the subject(s) (717) 805-0333 and received the following information: answering machine. Our office was unable to locate any heir for Anthony L. Centurion Sr. Ill. OBITUARY SEARCH A. Attempted to find obituary via http://oa.newsbank.com/ B. Found obituarypublished May 18, 2010 in the Patriot News, The (Harrisburg, PA). See attached. IV. INQUIRY OF HEIRS AND NEIGHBORS On 08-27-10 our office was unable to locate any information for Nicklaus J. Centurion, relative of Anthony L. Centurion Sr. On 08-27-10 our office was unable to locate any information for Mark D. Centurione, relative of Anthony L. Centurion Sr. On 08-27-10 our office was unable to locate any information for Edith Cappuccio, relative of Anthony L. Centurione Sr. On 08-27-10 our office attempted to contact Joseph M. Centurion, relative of Anthony L. Centurione Sr. at: 1607 Wyndham Road, Apartment Road, Camp Hill, PA 17011, but was unable to get any phone number for him. On 08-27-10 our office attempted to contact Anthony Centurion Jr., relative of Anthony L. Centurion Sr. at: 257 Winding Way, Camp Hill, PA 17011, but was unable to get any phone number for him. On 08-27-10 our office attempted to contact Anthony L. Centurione, potential relative of Anthony L. Centurione Sr. at:14215+h Street Apartment G, New Cumberland, PA 17070, but was unable to get any phone number for him. On 08-27-10 our office attempted to contact Anthony L. Centurion, potential relative of Anthony L. Centurion Sr. at: 28M Chancellorsville Drive, Apartment 836, Tallahassee, FL 32312, but was unable to get any phone number for him. ObitsArchivexom Patriot-News, The (Harrisburg, PA) - May 18, 2010 Deceased Name: Anthony L. Centurione, Sr. Anthony L. Centurione, Sr., 87, of Camp Hill, died unexpectedly on Sunday, May 16, 2010 in Holy Spirit Hospital. He was the former owner and operator of Tony's Mens Store in Middletown, a retired Sales Representative for Kayser-Roth Corp., New York and a member of St. Theresa Roman Catholic Church, New Cumberland. Tony was the son of the late Verino and Anna Centurion and is survived by his wife of 47 years, Theresa A. Forjan Centurion; 2 sons, Anthony L. Centurione, Jr. of New Cumberland and Joseph M. Centurione and his wife, Maria DiMascio Centurione of Camp Hill; 3 grandsons, Anthony L. Centurione III of Sarasota, FL. and Nicklaus J. and Mark D. Centurion of Camp Hill. He was preceded in death by 4 brothers, Dan, Frank, Joseph (who paid the ultimate sacrifice for his country in World War II) and Gardine Centurione and one sister, Edith Cappuccio, all of New Jersey. Mass of-Christian Burial will be celebrated on Thursday, May 20, 2010 at 11:00 am in St. Theresa Roman Catholic Church, 1300 Bridge St., New Cumberland, with Rev. J. Michael McFadden, his Pastor, as celebrant. Burial will be private. A visitation will held on Thursday from 10:00 until 11:00 am in his church. Arrangements are being handled by Wiedeman Funeral Home,.Steelton. In lieu of flowers, memorial contributions may be made to St. Theresa Parochial School, 1210 Bridge St., New Cumberland, PA 17070. www.wiedemanfuneralhome.com www.pennlive.com/obits Patriot-News, The (Harrisburg, PA) Date: May 18, 2010 Edition: FINAL Page: A06 Record Number: 1005184589705 Copyright, 2010, The Patriot-News Co. All Rights Reserved. Used with permission EXHIBIT (plow I FILED-OFFICE OF T"IEE;`F;GTH0N0TARY 2010 OCT -4 AM 11: 48 rtlMBFRLAND COUNTY PEtIt SYLVANIA Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745, Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza. Philadelphia, PA 19103 215-563-7000 DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS 17 V. ANTHONY L. CENTURIONS, SR. A/K/A ANTHONY L. CENTURIONE `EC0V COURT OF COMMON PLEAS CIVIL DIVISION NO. 09-398-CIVIL CUMBERLAND COUNTY SUGGESTION OF DEATH RE: DEFENDANT ANTHONY L. CENTURIONE, SR. A/K/A ANTHONY L. CENTURIONE COMMONWEALTH OF PENNSYLVANIA: PHELAN HALLINAN & SCHMIEG, LLP Suite 1400 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 215-563-7000 Fag: 215-567-0072 John.Parkinson@fedphe.com John Parkinson Legal Assistant Representing Lenders in Pennsylvania and New Jersey October 1, 2010 OFFICE OF THE PROTHONOTARY CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 RE: DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RAM 2006QS17 V. ANTHONY L. CENTURIONE, SR. A/K/A ANTHONY L. CENTURIONE NO. 09-398-CIVIL. Dear Sir/Madain: Enclosed for filing is a Suggestion of Death Re: Defendant ANTHONY L. CENTURIONE, SR. A/K/A ANTHONY L. CENTURIONE. Please file the original of record and return a time-stamped copy in the envelope enclosed for your convenience. Thank you for your cooperation in this regard. Sincere 4 J Parkinson Legal Assistant C *Please be advised that this firm is a debt collector attempting to collect a debt. Any information received will be used for that purpose. If you have previously received a discharge in bankruptcy and this debt was not reaffirmed, this correspondence is not and should not be construed to be an attempt to collect a debt, but only enforcement of a lien against property. Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS17 V. COURT OF COMMON PLEAS CIVIL DIVISION NO. 09-398-CIVIL ANTHONY L. CENTURIONE, SR.. CUMBERLAND COUNTY A/K/A ANTHONY L. CENTURIONE SUGGESTION OF DEATH RE: DEFENDANT ANTHONY L. CENTURIONE, SR A/K/A ANTHONY L. CENTURIONE COMMONWEALTH OF PENNSYLVANIA: Plaintiff, Deutsche Bank Trust Company Americas As Trustee For RALI 2006QS 17, by its counsel, Phelan Hallinan & Schmieg, LLP, hereby certifies that, to the best of its knowledge, information and belief, the Defendant, Anthony L. Centurion, Sr. A/K/A Anthony L. Centurione, is deceased -- date of death May 16, 2010. Upon reasonable investigation and belief, Anthony L. Centurione, Sr. A/K/A Anthony L. Centurion's surviving heirs at law and next-of-kin are Theresa Centurion, Anthony Centurione, Jr., and Joseph Centurion. Dated: to By: PHELAN HALLINAN & SCBMIEG, LLP Lamjred?e T. Phelan, Esq., Id. No. 12227 Fr cis . Hallinan, Esq., Id. No. 695 D 1 Schmieg, Esq., Id. No. 62205 Mich 1 M. Bradford, Esq., Id. No. 69849 Judith 4. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 8170 Jenine R Davey, Esq., Id. No. 87077 Lauren R Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, NA V. EUGENE H. MILLER COURT OF COMMON PLEAS CIVIL DIVISION NO.2009-SU-001484-06 YORK COUNTY CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of Suggestion of Death Re: Anthony L. Centurione, Sr. A/K/A Anthony L. Centurion was sent via first class mail to the following on the date listed below: Theresa Centurione 257 Winding Way Camphill, PA 17011 Anthony Centurione, Jr. 142 15a' Street, Unit G a/k/a 143 G 15m Street New Cumberland, PA 17070 Joseph Centurion 1607 Wyndham Road Camphill, PA 17011 Unknown Heirs Of Anthony Centurion, Deceased 142 15a' Street, Unit G a/k/a 143 G 15a' Street New Cumberland, PA 17070 \ANL? Dated: By: La T. Phelan, Esq., Id4o. o. 32227 F is S. Hallinan, Esq., Id. 62695 D 1 . Schmieg, Esq., Id. No. 62205 Mich M. Bradford, Esq., Id. No. 69849 Judith . Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 817 Jenne R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 .. ;A EXHIBIT "C" c--4 ITJ b z CD n 00 N O_ O bo N y r? N .? C3. co k O r °* c b? .N+ M o I "oI 001 11 o.I v, ?I ^1 O p F N ~'. - 'fO R 3 y ?' O N oa?`?°o ?•n n 9A .? W ? k N 11 U co, F•K g??c. o? 'oa 'v N 'O O ? H ^ ? N 3 SS?oL° ? O 03, fn M 3 P N 7 + RK Co a _ W.0 g -3 N N ?O ?d .p w ?a r c? cu z Q. b J O 0 w o o ?p 0 CD f? ?d 9 0 N N ?+ w CD 0 a b v O 0 x? ?C O -Oi W z G y N /r • ? P ? C b Y 0 o az a(::) x i? ? r Cn V^." W ?q l?yJ 1{, F?i _ 0 COP *$PON C wisp f , - ?= W-- 7 r-- s 02 1M $ 4 ?A 0004277256 NOV08 2010 MAILED FROM ZIP CODE 1910 3 PHELAN HALLINAN & SCHMIEG, LLP Suite 1400 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 215-563-7000 Fag: 215-567-0072 John.Parkinson@fedphe.com John Parkinson Legal Assistant, Decedent Department Representing Lenders In Pennsylvania and New Jersey November 8, 2010 Unknown Heirs Of Anthony L. Centurione, Deceased 142 15a` Street, Unit G a/k/a 143 G 150' Street New Cumberland, PA 17070 RE: DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS17 V. ANTHONY L. CENTURIONE, SR. A/K/A ANTHONY L. CENTURIONE NO.09-398-CIVEL Dear Defendant: Enclosed please find a copy of my proposed Motion for Service of the Complaint Pursuant to special Order of Court and proposed Order. In accordance with Cumberland County Local Rule 208.3(9), I am seeking your concurrence with the requested relief. Please respond to me within one week, by November 15, 2010. Should you have any further questions or concerns, please feel free to contact me. Otherwise, please be guided accordingly. Sincerel , Jqhn Parkinson Legal Assistant PHELAN HALLINAN & SCHMIEG, LLP Suite 1400 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 215-563-7000 Fax: 215-567-0072 John.Parkinson@fedphe.com John Parkinson Legal Assistant, Decedent Department Representing Lenders In Pennsylvania and New Jersey November 8, 2010 Anthony Centurione, Jr. 142 15th Street, Unit G a/k/a 143 G 15th Street New Cumberland, PA 17070 RE: DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS17 V. ANTHONY L. CENTURIONE, SR. A/K/A ANTHONY L. CENTURIONE NO. 09-398-CIVIL Dear Sir: Enclosed please fmd a copy of my proposed Motion for Service of the Complaint Pursuant to special Order of Court and proposed Order. In accordance with Cumberland County Local Rule 208.3(9), I am seeking your concurrence with the requested relief. Please respond to me within one week, by November 15, 2010. Should you have any further questions or concerns, please feel free to contact me. Otherwise, please be guided accordingly. Sincerely, son J ?"LA Legal Assistant PHELAN HALLINAN & SCHMIEG, LLP Suite 1400 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 215-563-7000 Fax: 215-567-0072 John.Parkinson@fedphe.com John Parkinson Legal Assistant, Decedent Department Representing Lenders In Pennsylvania and New Jersey November 8, 2010 Theresa Centurione 257 Winding Way Camphill, PA 17011 RE: DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS17 V. ANTHONY L. CENTURIONE, SR. A/K/A ANTHONY L. CENTURIONE NO. 09-398-CIVIL Dear Madam: Enclosed please find a copy of my proposed Motion for Service of the Complaint Pursuant to special Order of Court and proposed Order. In accordance with Cumberland County Local Rule 208.3(9), I am seeking your concurrence with the requested relief. Please respond to me within one week, by November 15, 2010. Should you have any further questions or concerns, please feel free to contact me. Otherwise, please be guided accordingly. Sincerely l?_ 1 Jo Parkinson Legal Assistant PHELAN HALLINAN & SCHMIEG, LLP Suite 1400 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 215-563-7000 Fax: 215-567-0072 John.Parkinson@fedphe.com John Parkinson Legal Assistant, Decedent Department Representing Lenders In Pennsylvania and New Jersey November 8, 2010 Joseph Centurione 1607 Wyndham Road Camphill, PA 17011 RE: DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS17 V. ANTHONY L. CENTURIONE, SR. A/K/A ANTHONY L. CENTURIONE NO. 09-398-CIVIL Dear Madam: Enclosed please find a copy of my proposed Motion for Service of the Complaint Pursuant to special Order of Court and proposed Order. In accordance with Cumberland County Local Rule 208.3(9), I am seeking your concurrence with the requested relief. Please respond to me within one week, by November 15, 2010. Should,you have any further questions or concerns, please feel free to contact me. Otherwise, please be guided accordingly. Sincerely Jo Parkinson Legal Assistant VERIFICATION The undersigned attorney hereby states that he/she is the Attorney for the Plaintiff in this action, that he/she is authorized to take this Affidavit, and that the statements made in the foregoing MOTION FOR SERVICE OF NOTICE OF SHERIFF'S SALE IN A MORTGAGE FORECLOSURE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of his/her knowledge, information, and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unworn falsification to authorities. PHELAN HALLINAN & SCHNIIEG, LLP Dated: l L ? l? By: (:?? i Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison Wells, Esq., Id. No. 309519 Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison Wells, Esq., Id. No. 309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS 17 V. ANTHONY L. CENTURIONE, SR. A/K/A ANTHONY L. CENTURIONE COURT OF COMMON PLEAS CIVIL DIVISION NO. 09-398-CIVIL CUMBERLAND COUNTY CERTIFICATION OF SERVICE I hereby certify a true and correct copy of the foregoing Plaintiff's Motion for Special Service was served by regular mail on Defendant (s) on the date listed below: Theresa Centurione 257 Winding Way Camphill, PA 17011 Anthony Centurione, Jr. 142 151' Street, Unit G a/k/a 143 G 150' Street New Cumberland, PA 17070 Joseph Centurione 1607 Wyndham Road Camphill, PA 17011 Unknown Heirs Of Anthony Centurione, Deceased 142 15'h Street, Unit G a/k/a 143 G 15" Street New Cumberland, PA 17070 PHELAN HALLINAN & SCHMLEG, LLP Dated: _ By: qn?L o?? LV I- Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison Wells, Esq., Id. No. 309519 + A NOV 2 2 2010 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS 17 V. ANTHONY L. CENTURIONE, SR. A/K/A ANTHONY L. CENTURIONE ORDER COURT OF COMMON PLEAS CIVIL DIVISION NO. 09-398-CIVIL CUMBERLAND COUNTY rb AND NOW, this 2 day of .,` l 0V , 2010, upon consideration of Plaintiff's Motion for Service of Notice of Sheriffs Sale of Real Property Pursuant to Special Order of court, it is hereby; ORDERED that Plaintiff may obtain service of Notice of Sheriffs Sale of Real Property on the Unknown Heirs, Successors, Assigns And All Persons, Firms Or Associations Claiming Right, Title Or Interest From Or Under Anthony L. Centurione, Sr. a/k/a Anthony L. Centurione, Deceased, by regular mail to the mortgaged premises located at 142 15th Street Unit G a/k/a 142 G 15th Street, New Cumberland, PA 17070; and by posting the mortgaged premises by the Sheriff or by an non-party competent adult. , e It is further ORDERED and DECREED that counsel for Plaintiff is hereby directed to file a certificate of service with the Prothonotary's office to assure compliance with this court order. BY THE COURT: J. ? `T??ete:5 Ceduriofie Y/ An 4-hOA7 een41'r,*m'e ?/ JOSI? 4 0-en4 u r• i er e f/ Un ,?CKn W? hf e i ?5 ? SQ?rht ??Gu;nnrss ?s?. eo pi es ,,,u,,, led it bobp v3 a 4 ?r? ?C ,mil"'. w o ?° -t rz ? ? -Ze . FILE :w F RRD T,j j o ;. TIA 2010 DEC 21 pH 1: 37 CUMBERLAND Cott N3' ' AENNSYLVANjp,, PHELAN HALLINAN AND SCHMIEG, L.L.P. ATTORNEY FOR PLAINTIFF BY: LAUREN R. TABAS, ESQUIRE ATTORNEY I.D. NO. 93337 ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 DEUTSCHE BANK TRUST COMPANY AMERICAS Court of Common Pleas AS TRUSTEE FOR RALI 2006QS 17 Civil Division Plaintiff V. ANTHONY L. CENTURIONE, SR A/K/A ANTHONY L. CENTURIONE Defendant CUMBERLAND County No. 09-398-CIVIL EMERGENCY MOTION FOR POSTPONEMENT OF SHERIFF'S SALE Plaintiff, by its counsel, Phelan Hallinan and Schmieg, L.L.P. petitions this Honorable Court for a three month postponement of its Sheriff's Sale scheduled in the above captioned matter and in support thereof avers the following: A Sheriff's Sale of the mortgaged property known as 142 15th Street Unit G A/K/A 142 G 15th St, New Cumberland, PA 17070-1104 involved herein has been scheduled for January 5, 2011. 2. Plaintiff wishes to postpone the Sheriff Sale in accordance with a voluntary "moratorium" on foreclosures. 3. Unless the Court grants this order to postpone the Sheriff Sale, the Plaintiff will have to re- advertise the property in furtherance of Pa.R.C.P. 3129.2 which will result in additional costs to the parties. A brief postponement of the Sheriffs Sale will not prejudice Defendant and will, in fact, inure to his benefit. WHEREFORE, Plaintiff respectfully requests that the Sheriff s Sale of the mortgaged premises be continued to April 6, 2011. HALLINAN & SCHMIEG, LLP 'LAUREN R. TABAS, ESQUIRE ATTORNEY FOR PLAINTIFF PHELAN HALLINAN AND SCHMIEG, L.L.P. ATTORNEY FOR PLAINTIFF BY: LAUREN R. TABAS, ESQUIRE ATTORNEY I.D. NO. 93337 ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 DEUTSCHE BANK TRUST COMPANY AMERICAS Court of Common Pleas AS TRUSTEE FOR RALI 2006QS 17 Civil Division Plaintiff V. ANTHONY L. CENTURIONE, SR A/K/A ANTHONY L. CENTURIONE Defendant CUMBERLAND County No. 09-398-CIVIL PLAINTIFF'S MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 3129.3 provides for the postponement of a Sheriff s Sale of real property by special order of Court. In the case sub judice, a Sheriffs Sale of the mortgaged premises has been scheduled for January 5, 2011. However, a three month postponement is requested in observance of the voluntary foreclosure moratorium. Inasmuch as the postponement will inure to the benefit of the Defendant, Defendant will not be injured by the granting of the relief requested. Accordingly, Plaintiff respectfully requests a three month continuance of the Sheriff's Sale of the mortgaged premises to the April 6, 2011 sale. 'FULLY SUBMITTED: HALLINAN AND SCHMIEG, L.L.P. LAUREN R. TABAS, ESQUIR ATTORNEY FOR PLAINTIFF VERIFICATION LAUREN R. TABAS, ESQUIRE, hereby states that she is the attorney for the Plaintiff in this action, that she is authorized to take this verification, and that the statements made in the foregoing Emergency Motion for Postponement of Sheriffs Sale are true and correct to the best of her knowledge, information and belief. The undersigned also understands that this statement herein is made subject to the penalties of 18 Pa. Sec. 4904 relating to unsworn falsification to Date: 10 OAUREN R. TABAS, ESQUIRE ATTORNEY FOR PLAINTIFF PHELAN HALLINAN AND SCHMIEG, L.L.P. BY: LAUREN R. TABAS, ESQUIRE ATTORNEY I.D. NO. 93337 ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS 17 Plaintiff V. ANTHONY L. CENTURIONE, SR A/K/A ANTHONY L. CENTURIONE Defendant CERTIFICATION OF SERVICE Court of Common Pleas Civil Division CUMBERLAND County No. 09-398-CIVIL I, LAUREN R. TABAS, ESQUIRE, hereby certify that a copy of the Emergency Motion for Postponement of Sheriff s Sale relative to the above matter and Memorandum of Law has been sent to the individuals indicated below on December 20, 2010. UNKNOWN HEIRS OF ANTHONY L. CENTURIONE, SR A/K/A ANTHONY L. CENTURIONE 142 15TH STREET UNIT G A/K/A 142 G 15TH ST NEW CUMBERLAND, PA 17070-1104 Date:/ zjt7-410 UNKNOWN HEIRS OF ANTHONY L. CENTURIONE, SR A/K/A ANTHONY L. CENTURIONE 257 WINDING WAY, APT. IA CAMP IL , PA 17011-8462 ATTORNEY FOR PLAINTIFF ATTORNEY FOR PLAINTIFF " 7D-OFFICE 4ROTHONOTARY 2010 DEC 27 T."' 1113. 15 CUMBERLA"'" "' -LINTY PENNSY, _ . A 4 jA DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS 17 Plaintiff V. ANTHONY L. CENTURIONE, SR A/K/A ANTHONY L. CENTURIONE Defendant DEC 2 2 2010 Court of Common Pleas Civil Division CUMBERLAND County No. 09-398-CIVIL ORDER AND NOW, this k day of December, 2010, after consideration of Plaintiff's Emergency Motion for Postponement of Sheriffs Sale of the mortgaged property known as 142 15th Street Unit G A/K/A 142 G 15th St, New Cumberland, PA 17070-1104, it is hereby ORDERED that the said sale is extended three months to the regularly scheduled Cumberland County Sheriff s Sale dated April 6, 2011. No further advertising or additional notice to lienholders or Defendant is required, however the Sheriff is directed to announce the continuation to the assembled bidders and Plaintiff is to forward a copy of this Order to Defendant via first class mail. BY THE COURT: cc: Sheriff of Cumberland County ,,,*Lauren R. Tabas, Esquire Anthony L. Centurione Sr. a 196018 Co?ies 10 J. UA AFFIDAVIT OF SERVICE PLAINTIFF DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS17 DEFENDANT ANTHONY CENTURIONE, JR THERESA A. CENTURIONE JOSEPH CENTURIONE UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER ANTHONY L. CENTURIONE, SR, DECEASED SERVE THERESA A. CENTURIONE AT: 257 WINDING WAY CAMP HH.L, PA 17011-8462 CUMBERLAND COUNTY PHS # 196018 -- . -3 SERVIC E TEAM/ lac r1n rn r n 1 COURT NO.: 09-398-CIVIL Z;0 <p Ln --4 ?-- z = ?.tl ?n ZC - O{z; ---i CJN 7. TYPE OF ACTION XX Notice of Sheriff's Sale SALE DATE: 04/0612011 SERVED ??b , Served and made known to THERESA A. CENfURIONE , Defendant on the S day of r-"Offu 20(1 Q-37, o'clock,. M., at 957 (,?1J1 ,A* W.4.{4 .0 U, P.4 , in the manner described below: V Defendant personally served. - Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge of Defendant's residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). _ Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other: _ Vac _ Does Not Exist _ Moved _ Does Not Reside (Not Vacant) No Answer on at at Service Refused Descn'ption: Age 1I-A76 S Height 57 . Weight ;06 Race W Sex 'P7 Other L rt0 I L( , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as rn erein case on the date and at the address indicated above. _`t C"RT ?r? f an t'L L1l Sworn to and subscribed FRsEY g;'AFf S? ?A, before me this 5?' ?y day n;,+RCH 7.2013 of ??? ,201 iNtt?,+_ :?? ' Notary: By: NOTSERVED On the ay , 20_, at _ o'clock _. M., Defendant NOT FOUND because: Other: Sworn to and subscribed before me this day of By: Notary: ATTORNEY FOR PLAINTIFF Lannnee T. Phelan, F_sq., Id. No. 32227 Francis S. Hallman. Esq., Id. No. 62695 Daniel G. Sd n k& F al , ld. -10. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Rommo, Esq., Id. No. 58745 Shedal R. Sbab-Joni, Esq.. Id. No. 81760 Jenne R. Davey, Esq., Id. No. 87077 Laaren R. Tahas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Joins, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. N. 61791 Andrew L. Spi-k, Esq., Id. No. 84039 Jahm McGukrnew Esq., Id. N. 90134 Chrisovalente P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldann, Fail, Id. No. 205047 Coartmay R. Dann, Esq., /d No. 206779 Andrew C. Bnunbklt, Esq., Id. No. 208375 A116on F. Wells Fsq., Id. No. 309519 one Pea Center at Suburban Station 1617 John F. Kennedy Blvd., Suit. 1400 Philadelphia, PA 191031814 (215) 5637000 AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS17 PHS # 196018 DEFENDANT ANTHONY CENTURIONE, JR THERESA A. CENTURIONE JOSEPH CENTURIONE UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER ANTHONY L. CENTURIONE, SR, DECEASED SERVE ANTHONY CENTURIONE, JR AT: 14215TH STREET UNIT G A/K/A 142 G 15TH ST NEW CUMBERLAND, PA 17070-1104 SERVICE TEAM/ kxc COURT NO.: 09-398-CIVIL t _ ' ttt _ rrn r I S' CA7 t "? f *t = N D GS1 TYPE OF ACTION <© 3 (D-rt XX Notice of Sheriffs Sale a' ZC:? =F "t SALE DATE: 04/06/2011 SERVED ??^^,,? Served and made known to ANTHONY CENTURIONE, JR , Defendant on the 3 PA day of t-r6*v4w , 201, at +. 22, o'clock P. M., at 142 G 15 J% Srfw-r in the manner described below: V Defendant personally served. N6wCuM6fR1.+?wlD,p1;1 - Adult family member with whom Defendant(s) reside(s). Relationship is - Adult in charge of Defendant's residence who refused to give name or relationship. - Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other: Description: Age /,,40's Height S'16" Weight 175 Race W Sex M Other __ I, ?RNV+LA At-U , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this 3eo day K1M RLY CURTY of F , 20 P. r10?-A,hv PuB??c Q? STATE 0zi --,l7WjERSF.Y Notary: By: MY C0'AMIJSION [-.. 'IRES MARCH 7, 2013 NOTSERVED On the c 20_, at _ o'clock _. M., Defendant NOT FOUND because: V c _ Does Not Exist _ Moved _ Does Not Reside (Not Vacant) o Answer on at at Service Refused Other: Sworn to and subscribed before me this day of By: Notary: ATTORNEY FOR PLAINTIFF Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmteg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheclal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 I.aunm R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcaby, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 20&375 Allison F. Wells, Esq., Id. No. 309519 One Penn Center at Suburban Station 1617 John F. Kennedy Blvd., Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Phelan Hallinan & Schmie LLP Lawrence T. Phelan, Esq, Idg 4o. 32227 Francis S. Hallinan, Esq., Id. No. 62695 I)aniel G. Schmieg, Esy., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq. Id. No. 202331 Jay B. Jones, Esq. Id. flo. 86657 Peter J. Mulcahy, hsg., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esc. 13. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq.: Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS17 Plaintiff, 'O-O HCE '. PROTHONOTARY hill ?'AR -7 Ate S: 45 11 .'AIRERLAND COUNTY PENNSYLVANIA : CUMBERLAND COUNTY : COURT OF COMMON PLEAS V. ANTHONY CENTURIONE, JR CIVIL DIVISION THERESA A. CENTURIONE JOSEPH CENTURIONE NO. 09-398-CIVIL UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER ANTHONY L. CENTURIONE, SR., DECEASED Defendant(s). AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE PURSUANT TO P.R.C.P., 404(2)/403 I hereby certify that a true and correct copy of the Notice of Sheriff Sale in the above captioned matter was sent by regular mail and certified mail, return receipt requested, to UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER ANTHONY L. CENTURIONE, SR., DECEASED on JANUARY 11, 2011 at 14215TH STREET UNIT G A/K/A 142 G 15TH STREET, NEW CUMBERLAND, PA 17070, in accordance with the Order of Court dated NOVEMBER 23, 2010. The property was posted on JANUARY 14, 2011. The undersigned understands that this statement is made subject to the penalties of 18 PE.S. §4904 relating to the unsworn falsification to authorities. P}IF,LAN H N & SCHMIEG, LLP By: Lawrence . elan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 n l 1 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 U Attorneys for Plaintiff Dated: 0 c7 W U y? ".1 a a L 7 ? M ? O ON ? a U ab A- Oa II ? L ? L y eabw zdo £01.6 L 3000dIZ WON=l O31IVW 140Z L Wr 9SZLLZb 000 1 09z3o t W4 ZO yY [L 53%09 A3Nlld G ®J"® 0 n ® ? I %d ?y y O 0. z g U V) p OW Q U U W on °C Ow ?O A ?? U z LLI z U a a } on a LU zz aWt; 0 ? p ZL ti N ~ a U (n O a Qom V?o O ?o 0 O u' ?o n°w L n t u ) ; a U w u I U a - W I V) Z O ?0?? ! ..? = J W 0 0 z m b O O U Z -4 ~ V ? d z 0 1 3 1 _> ` v z z W ?z 9 U r O T C? F H N M W) ?O t- 00 ON O N M rt v'1 z ? -a G N [- a U TTO- fir cc? , LF.1i U. R?R?1 IN THE COURT OF COMMON PLEAS OF C PENNSYLVANIA DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS17 V. ANTHONY L. CENTURIONE, SR. A/K/A ANTHONY L. CENTURIONE ORDER UMBERLAND COUNTY, COURT OF COMMON PLEAS CIVIL DIVISION NO. 09-398-CIVIL CUMBERLAND COUNTY AND NOW, this )3 rd day of lJou , 2010, upon consideration of Plaintiff's Motion for Service of Notice of Sheriff's Sale of Real Property Pursuant to Special Order of court, it is hereby; ORDERED that Plaintiff may obtain service of Notice of Sheriff's Sale of Real Property on the Unknown Heirs, Successors, Assigns And All Persons, Firms Or Associations Claiming Right, Title Or Interest From Or Under Anthony L. Centurione, Sr. a/k/a Anthony L. Centurione, Deceased, by regular mail to the mortgaged premises located at 142 15' Street Unit G a/k/a 142 G 15' Street, New Cumberland, PA 17070; and by posting the mortgaged premises by the Sheriff or by an non-party competent adult. jq?6(c It is further ORDERED and DECREED that counsel for Plaintiff is hereby directed to file a certificate of service with the Prothonotary's office to assure compliance with this court order. BY THE COURT: is f `7Yt - X- Cdr 4- J. IQG OR AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS17 PHS # 196018 DEFENDANT SERVICE TEAM/ kxc ANTHONY CENTURIONE, JR COURT NO.: 09-398-CIVIL THERESA A. CENTURIONE JOSEPH CENTURIONE UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER ANTHONY L. CENTURIONE, SR, DECEASED SERVE UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL TYPE OF ACTION PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, XX Notice of Sheriffs Sale TITLE OR INTEREST FROM OR UNDER ANTHONY L. SALE DATE: 04/06/2011 CENTURIONE, SR, DECEASED AT: 142 15TH STREET UNIT G A/K/A 142 G 15TH ST NEW CUMBERLAND, PA 17070-1104 ***PLEASE POST PER COURT ORDER*** SERVED Served and made known to UNKNOWN HEIRS. SUCCESSORS, ASSIGNS, AND ALL PERSONS FIRMS OR ASSOCIATIONS CLAIMING RIGHT TITLE OR INTEREST FROM OR UNDER ANTHONY L. CENTURIONS SR, DECEASED , Defendant on the _4? ay of uANVAgq , 20 It , at 134, o'clock A. M., at 147 G is* StyhfwQAs ,A DA , in the manner described below: - Defendant personally served. - Adult family member with whom Defendant(s) reside(s). Relationship is _ Adult in charge of Defendant's residence who refused to give name or relationship. - Manager/Clerk of place of lodging in which Defendant(s) reside(s). - Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other: posu-''l, 204ilF.Q u . Description: Age Height Weight Race Sex Other I, 7 41? -D MILL , a competent adult, being duly sworn according to law, depose and state that I personally ?05-IEp wed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above Sworn to and subscribed K1MEF:R LYCL'KTY before me this I4- •day NOTARY PUBLIC of I?1 , 20 !1. STATF, O h.11R A Notar + y: MY COMMISS.C° E'?Rf S NI p=ARCH 7, 2013 NOT SERVED On th day 20_, at o'clock _. M., Defendant NOT FOUND because: a _ Does Not Exist _ Moved _ Does Not Reside (Not Vacant) _ No Answer on at Service Refused Other: Sworn to and subscribed before me this day of 20_ By: Notary: at ATTORNEY FOR PLAINTIFF Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Shmial R Shah-Jany Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Brambleft, Esq., Id. No. 208375 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson 1 FILED-OFFICE Sheriff f"rjOF THE PROTHONOTARY Jody S Smith Chief Deputy 2011 MAR 23 PM 12: 41 Richard W Stewart CUMBERLAND COUNTY Solicitor FPE PENNSYLVANIA Deutsche Bank Trust Company Americas vs. Anthony L Centurione, Sr Case Number 2009-398 SHERIFF'S RETURN OF SERVICE 06/22/2010 03:40 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on June 22, 2010 at 1538 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 Anthony L. Centurione, located at, 142 15th Street, Unit G, a/k/a 15th Street, New Cumberland, Cumberland County, Pennsylvania according to law. 06/26/2010 09:00 AM - Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Anthony L. Centurione, Sr., but was unable to locate him in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale and Description as NOT FOUND as to the defendant, Anthony L. Centurione, Sr, deceased since May of 2010 08/26/2010 As directed by Daniel G Schmieg, Attorney for the Plaintiff, Sheriffs Sale Continued to 11/3/2010 10/26/2010 As directed by Daniel G Schmieg, Attorney for the Plaintiff, Sheriffs Sale Continued to 1/5/2011 01/05/2011 As directed by Daniel G Schmieg, Attorney for the Plaintiff, Sheriffs Sale Continued to 4/6/2011 03/23/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney Schmieg on 3/22/11. SHERIFF COST: $760.76 March 23, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF J-01) Pd • Cc-, . Am" a sw 990 (o GountySoite -;hertf. -feleo,o`t_ wc. P DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS17 Plaintiff V. ANTHONY L. CENTURIONE, SR A/K/A ANTHONY L. CENTURIONE Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO. 09-398-CIVIL CUMBERLAND COUNTY AFFIDAVIT PURSUANT TO RULE 3129.1 DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS17, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 14215TH STREET UNIT G A/K/A 142 G 15TH ST, NEW CUMBERLAND, PA 17070-1104. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) ANTHONY L. CENTURIONE, SR A/K/A ANTHONY L. CENTURIONE 2. Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE 14215TH STREET UNIT G A/K/A 142 G 15TH ST NEW CUMBERLAND, PA 17070-1104 257 WINDING WAY, APT. 1A CAMP HILL, PA 17011-8462 Address (if address cannot be reasonably ascertained, please so indicate) Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) CREDIT ONE LLC 361918 STREET METAIRIE, LA 70002 CREDIT ONE LLC C/O RON Z. OPHER, ESQUIRE P.O. BOX 2245 SOUTHEASTERN, PA 19399 Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be None reasonably ascertained, please indicate) . 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANVOCCUPANT Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare United States Internal Revenue Special Procedures Branch Federated Investors Tower 142 15TH STREET UNIT G A/K/A 142 G 15TH ST NEW CUMBERLAND, PA 17070-1104 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 13th Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, PA 15222 U.S. Department of Justice U.S. Attorney for the Middle District of PA Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Internal Revenue Service Federated Investors Tower Department of Public Welfare TPL Casualty Unit Estate Recovery Program CUMBERLAND CROSSING CONDOMINIUM ASSOCIATION Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 6`h Floor, Strawberry Sq., Dept 28061 Harrisburg, PA 17128 13TH Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, PA 15222 P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105 142 15TH STREET NEW CUMBERLAND, PA 17070 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 uN to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. f P /? March 22, By; / Attorney for P aind Phelan Halli an & chmieg, LL ? Lawrenc T. Phe , Esq., I o. 32227 ? Francis . Hallinan, s No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS17 VS. ANTHONY L. CENTURIONE, SR A/K/A ANTHONY L. CENTURIONE Defendant(s) : NO. 09-398-CIVIL : CUMBERLAND COUNTY NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ANTHONY L. CENTURIONE, SR A/K/A ANTHONY L. CENTURIONE 142 15TH STREET UNIT G A/K/A 142 G 15TH ST NEW CUMBERLAND, PA 17070-1104 ANTHONY L. CENTURIONE, SR A/K/A ANTHONY L. CENTURIONE 257 WINDING WAY, APT. 1A CAMP HILL, PA 17011-8462 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 14215TH STREET UNIT G A/K/A 142 G 15TH ST, NEW CUMBERLAND, PA 11070-1104 is scheduled to be sold at the Sheriffs Sale on SEPTEMBER 8, 2010 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $130,941.11 obtained by DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS17 (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 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.) : COURT OF COMMON PLEAS : CIVIL DIVISION Plaintiff : Y 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 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. 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 filing of the proposed schedule. 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. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 09-398-CIVIL DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS17 VS. ANTHONY L. CENTURIONE, SR A/K/A ANTHONY L. CENTURIONE owner(s) of property situate in NEW CUMBERLAND BOROUGH, Cumberland County, (Municipality) Pennsylvania, being 142 15TH STREET UNIT G A/K/A 142 G 15TH ST. NEW CUMBERLAND. PA 17070-1104 Parcel No. 26-23-0541-218A-U7 . (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $130,941.11 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 LEGAL DESCRIPTION ALL that certain unit in the property known, named and identified in the declaration referred to below as'Cumberland Crossings Condominium,' located in New Cumberland Borough, Cumberland County, Pennsylvania, which has heretofore been submitted to the provisions of the Pennsylvania Uniform Condominium Act, 68 Pa. C.S.A. 3101 by the recording in the Office of the Recorder of Deeds of Cumberland County of a declaration dated March 1, 1988, and recorded on March 25, 1988, in Miscellaneous Book 347, Page 1111, as the same shall be amended from time to time, being and designated in such declaration, as the same may be amended from time to time, as Unit No. 7, also known as 142-G, which said Unit being part of said Unit, is more fully described in said declaration, as the same may be amended from time to time, together with a proportionate undivided interest in the Common Elements (as defined' in said declaration, as the same may be amended from time to time); UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights-of-way, easements and agreements of record; FURTHER UNDER and SUBJECT to any and all covenants, conditions, restrictions, rights-of- way and easements as set forth on Plats and Plans- Site Plan, recorded in Plan Book 55, page43' TITLE TO SAID.PREMISES IS VESTED IN Anthony L. Centurion, Sr., a married man, by Deed from Scott A. Lake, a single man, dated 07/01/2003, recorded 07/03/2003 in Book 257, Page 4774. PREMISES BEING: 142 15TH STREET UNIT G A/K/A 142 G 15TH ST, NEW CUMBERLAND, PA 17070-1104 PARCEL NO. 26-23-0541-218A-U7 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 09-398 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK TRUST COMPANY AMERICAS, as Trustee for RALI 2006QS17, Plaintiff (s) From ANTHONY L. CENTURIONE, SR a/k/a ANTHONY L. CENTURIONE (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 $130,941.11 L.L. Interest from 3/4/19 to Date of Sale ($21.81 per diem) -- $12,088.28 Atty's Comm % Due Prothy $2.00 Atty Paid $1,091.95 Plaintiff Paid Date: 3/31A 0 Other Costs David D. Buell, rothonotary (Seal) By: Deputy REQUESTING PARTY: Name: JOSHUA I. GOLDMAN, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP ONE PENN CENTER, SUITE 1400 1617 JFK BOULEVARD PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 205047 On June 14, 20 10 the Sheriff levied upon the defendant's interest in the real property situated in - Now Cumberland Borough, Cumberland County, PA, L Down and numbered as, 142 15th Street, Unit G, a/k/a 2 G. 15th Street, New Cumberland, PA 17070 New Cumberland, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 14, 2010 By: Qejal Estate Coordinator TPe Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE Z4 e patriot News Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant 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 Markel: 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 she 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 she 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: Writ No. 2009-398 Civil Term 07109/10 utsche Bank Trust Company Americas as Trustee for RALI 07116110 20060517 Vs L Antho 07/23/10 ny . Centurions a/k/a • , Anthony L. Centurions .. ........ • • • • • • • • • • . • • • Atty: Daniel G Schmieg By virtue of a Writ of Execution NO. 09-398- CIVIL DEUTSCHE BANK TRUST COMP Sworn to and s6bscribed be ore me this 05 d4y?of August, 2010 A.D. ANY AMERICAS AS TRUSTEE FOR RALI 2006 QS17 f lif - '4 r V5 ANTHONY L. CENTURIONE, SR A/K/A Notary Public ANTHONY U f f L QM- 1 2F2F p N SyLVAN1A prop property y situate in NEW owner(s) ) o CUMBERLAND BORO Notarial Seat UGH, Cumberland Count Sherrie L. Klsner, Notary Puolic Lower P y, (Municipality) axton Twp., Dauphin County My CommlSSion Expires Nov. 26 2011 Pennsylvania, being , momder. Pennsylvania Assar_iation of ryo ries 142 15TH STREET UNIT G A/K/A 142 G 15TH ST, NEW CUMBERLAND, PA 17070-1104 (Acreage or street address) Parcel No. 26-23-0541-218A-U7 Improvements thereon: RESIDENTIAL. DWELLING 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: July 16, July 23, and July 30, 2010 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. Writ No. 2009-398 Civil Deutsche Bank Trust Company Americas as Trustee for BALI 2006QS17 vs. Anthony L. Centurione a/k/a Anthony L. Centurione Atty.: Daniel G. Schmieg By virtue of a Writ of Execution NO. 09-398-CIVIL, DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS17 vs. ANTHONY L. CENTURIONE, SR A/K/A ANTHONY L. CENTURIONE, owners of property situate in NEW CUMBERLAND BOROUGH, Cum- berland County, Pennsylvania, being 142 15TH STREET UNIT G A/K/A 142 G 15TH ST, NEW CUMBER- LAND, PA 17070-1104. Parcel No. 26-23-0541-218A-U7. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $130,941- .11. sa Marie Coyne, Edi r SWORN TO AND SUBSCRIBED before me this 0 day of Jul 2010 J 4t&? Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Pubk CARLISLE BOROUGH, CUMBERLAND COUNTY My COIp111fitf011 Exgru Apr 28.2014 PHELAN HALLINAN & SCHMIEG, LLP John Michael Kolesnik, Esq. Id. No. 308877 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 `? Y t JUL -2 for Plaintiff 2ot? ? DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS 17 Plaintiff VS. ANTHONY L. CENTURIONE, SR A/K/A ANTHONY L. CENTURIONE ANTHONY CENTURIONE, JR THERESA A. CENTURIONE JOSEPH CENTURIONE UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER ANTHONY L. CENTURIONE, SR, DECEASED Defendant COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 09-398-CIVIL WITHDRAWAL OF APPEARANCE To the Prothonotary: Kindly withdraw my appearance on behalf of Plaintiff, DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS 17. Phelan Hallinan & Schmieg, LLP Date:-O// By: / Jo Michael Kolesnik, Esq. Id. No. 308877 Attorney for Plaintiff PHS # 196018 I UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 C _ `.?. ., PAIGE M. BELLINO, ESQUIRE - ID #309091 HARRY B. REESE, ESQUIRE - ID #310501 t? rfj- -vim AMY GLASS, ESQUIRE - ID #308367 wry C33 KASSIA FIALKOFF, ESQUIRE - ID#310530 Q ELIZABETH WASSALL, ESQUIRE - ID#7778 y? -°iC Q ELANA FLEHINGER, ESQUIRE - ID#209197 ; N AGNES MOMBRUN, ESQUIRE - ID#309356 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com DEUTSCHE BANK TRUST COMPANY :-COURT OF COMMON PLEAS AMERICAS AS TRUSTEE FOR RALI =CIVIL DIVISION 2006QS17 :CUMBERLAND County Plaintiff V. :NO. 09-398-CIVIL ANTHONY L. CENTURIONE, SR A/K/A ANTHONY L. CENTURIONE ANTHONY CENTURIONE, JR. THERESA A. CENTURIONE JOSEPH A. CENTURIONE UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALLPERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER ANTHONY € L.CENTURIONE, SR, DECEASED 142 G 15TH STREET UNIT # G NEW CUMBERLAND, PA 17070 Defendant (s ) ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the following counsel: Mark J. Udren, Esquire; Stuart Winneg, Esquire; Lorraine Doyle, Esquire; Alan M. Minato, Esquire; Sherri J. Braunstein, Esquire; Paige M. Bellino, Esquire; Amy Glass, Esquire; Kassia Fialkoff, Esquire; Harry B. Reese, Esquire; Elizabeth Wassall, Esquire; Elana Flehinger, Esquire; and Agnes Mombrun, Esquire on behalf of the Plaintiff, DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS17 in the above-captioned matter. LAW OFFl',?7_ES , P. C. MOMBRLIK, ESQUIRE PA ID 3093 11120597-1 UDREN LAW OFFICES P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings(a~udren.com Deutsche Bank Trust Company Ameri acs 'COURT OF COMMON PLEAS ~., As Trustee For Rali 2006QS17 'CIVIL DIVISION ~ Plaintiff Cumberland County v. I x Anthony L.Centurione, Sr A/K/A Anthony L. Centurione Defendant(s) MORTGAGE FORECLOSURE .c1'4~ rx N0.09-398-CIVIL ~, --a PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due $ 153,192.26 Interest From 9/9/2010 $ 23,942.10 to Date of Sale March 6.2013 Ongoing Per Diem of $26.31 to actual date of sale including if sale is held at a later date (Costs to be added) $ d as ~~a~~ ~'1 ~~ y 3.3o CAF Sd a ~~ Lc q ~~ 3. l~5 MJLT#: 11120597 CASE#: 11120597-1 '? (p0 . ~ Co `` a~ ©o„~, g~ oo,,., ~ $ 81 ~ ~I I a UDREN LAW OFFICES, P.C. BY: -----~.., At or laintiff ELIZAB P HID ~~~$$ ~~ ESQ C~~ ~da~~l ~# a~~3g N v c-~ w ara a 0 -~ ~~ .~, _..., ,-~ x -~n -~ ~-~ ~~ ~Y~ ~ ~~ IN THE COURT OF COMMON PLEAS CLIMBERLANll COUNTY, PENNSYLVANIA DELT'SCIIE BANK TRUST COMPANY Caurt of Common Picas AMERICAS AS TRUSTEE FOR BALI 2006£,517 Plaintiff Civil Division v. ANTHONY L. CENTII~RIONE, SR CUMBERLAND Caunty AiKf~A ANTHONY L. CENTURIONS ; Defendant No. 09-3~)8-CIVIL ORI)E R AND NOW, this /'~"da}• of ~~./~'~ , ?010, upon consideration of Plaintiff's Motion to Make Rule Absolute, it is hereby ORDERED and DECREED, that the Rule entered upon Defendant shall be and is hereby made absolute; and Plaintiff s Motion to Reassess Damages in the above captained matter is hereby GRAN`T'ED. The- Prothonotary is ordered to amend the. ;judgment and the Sheri:Ef is ordered to amend the writ nuns pro tune as iollaws: Principal Balance ~;1'?3•c)(}4,9g Interest Thraugh September 8, 201(? ~;1 ~)e446.:? 1 Per Diem $26.31 Late Charges X45.13 Legal fees S'~.(i37.50 Cast of Suit and Title ~I,535.50 Sheriff's Sale Costs Sg7;,{i5 Property Inspections! Property Preservation ~ I ~~,~> AppraisallBrokers Price Opinion ~39(a,00 1~Iartgage Insurw~.ce Premium I ~;gg?5 Private Mortgage Insurance Non Sufficient Funds Charge ~;(),(}{} Suspense/Misc. Credits (~(~.00} Escrow Deficit S4,?47.8 TOTAL S? 5 ~.1 {)2?{7 Plus interest from September 8, 2010 through the date of sale at six percent per annum. Note: The above figure is not a payoff' quate. Sheriff's commission is not inclnde;tf in the above figure. BY THE COURT ~. c3~{~' f. '. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com ____ Deutsche Bank Trust Company Americas ~ COURT OF COMMON PLEAS '.~~ -, ~ ~--~+ As Trustee For Rali 2006 S17 Q CIVIL DIVISION ~ ,~ ..w ~ ~' c~ M .r _...k ~ ~~;~,,: Plaintiff Cumberland County ~, ~-- -z~ f"" c-~ ~ ~~ ._. - - : ~ t , MORTGAGE FORECLOSURE c~ a Anthony L.Centurione, Sr A/K/A Anthony ~* c-, ~ ~:.., L. Centurione ~ ca r~ NO. 09-398-CIVIL p .~..{ ~ ' ~, Defendant(s) -< CERTIFICATE OF ACT 91 I hereby state that as the attorney for the Plaintiff in the above-captioned matter: ~ Act 91 procedures have been fulfilled [] Premises is not subject to the provisions of Act 91 as this is an FHA insured mortgage This statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. BY: Atto y or Plaintiff ~ ELIZABETH L WASSALL, FS PA ID '~' ~=,; UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings(a~udren.com ATTORNEY FOR PLAINTIFF Deutsche Bank Trust Company Americas COURT OF COMMON PLEAS As Trustee For Rali 2006QS17 CIVIL DIVISION Plaintiff Cumberland County v. Anthony L.Centurione, Sr A/K/A Anthony L. Centurione Defendant(s) MORTGAGE FORECLOSURE NO. 09-398-CIVIL AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 c-'a e~ -r ~~' ~ ~; ~~~ `nt r r-' ~~ --{ -~: r°*t c-~ w 0 r~ -t, .--~ eT~ ~: U' <~ ~~ -: c~a -r; _,_ c~ ~.~;; ~~ ,. Deutsche Bank Trust Company Americas As Trustee For Rali 2006QS17, Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 142 15th Street Unit G A/K/A 142 G 15th Street, New Cumberland, PA 17070 1. Name and address of Owner(s) or reputed Owner(s): Anthony L.Centurione, Sr A/K/A Anthony L. Centurione 142 15th Street Unit G A/K/A 142 G 15th Street New Cumberland, PA 17070 Anthony L.Centurione, Sr A/K/A Anthony L. Centurione c/o Unknown Heirs, Successors, Assigns and All Persons, Firms, or Associations Claiming Right, Title or Interest from or under Anthony L. Centurione, Sr., Deceased 142 15th Street Unit G A/K/A 142 G 15th Street New Cumberland, PA 17070 2. Name and address of Defendant(s) in the judgment: Anthony L.Centurione, Sr A/K/A Anthony L. Centurione 142 15th Street Unit G A/K/A 142 G 15th Street New Cumberland, PA 17070 Anthony L.Centurione, Sr A/K/A Anthony L. Centurione c/o Unknown Heirs, Successors, Assigns and All Persons, Firms, or Associations Claiming Right, Title or Interest from or under Anthony L. Centurione, Sr., Deceased 142 15th Street Unit G A/K/A 142 G 15th Street New Cumberland, PA 17070 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Jr Lien Holders -None 4. Name and address of the last recorded holder of every mortgage of record: Deutsche Bank Trust Company Americas As Trustee For Rali 2006QS17 1661 Worthington Road, Suite 100 West Palm Beach, FL 33409 Sr Mortgage Holders -None Jr Mortgage Holders -None 5. Name and address of every other person who has any record lien on the property: Credit One, LL 3619 18th Street Metairie, LA 70002 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: Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Tenants/Occupants 142 15th Street Unit G A/K/A 142 G 15th Street New Cumberland, PA 17070 Internal Revenue Service, Pittsburgh Office Moorehead Building, 1000 Liberty Avenue, Rm 112 Pittsburgh, PA 15222 Department of Public Welfare, TPL Casulty Unit, Estate Recovery Program PO BOX 8486, Willow Oak Bldg. Harrisburg, PA 17105-8486 Commonwealth of PA, Bureau of Individual Tax, Inheritance Tax Division 6th Floor, Strawberry Square, Dept. 280601 Harrisburg, PA 17128 Anthony Centurione, Jr. 142 15th Street Unit G A/K/A 142 G 15th Street New Cumberland, PA 17070 r Theresa A. Centurione 257 Winding Way Camp Hill, PA 17011-8462 Joseph Centurione Address to Follow Unknown Heirs, Successors, Assigns and All Persons, Firms, or Associations Claiming Right, Title, or Interest from or under Anthony L. Centurione, Sr., Deceased 142 15th Street Unit G A/K/A 142 G 15th Street New Cumberland, PA 17070 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: Federal Tax Lien Holders -None Cumberland Crossing Condo Association Address to Follow I verify that the statements made in this affidavit are true and correct to the best of my 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: UDREN LAW OFFICES, P.C. Attorney for Plaintiff MJU#: 11120597 CASE#: 11120597-1 ELIZABE ~ i7 ,_ ,;,,~,~;;~~, t;, PA ID 77788 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings(a~udren.com Deutsche Bank Trust Company Americas As Trustee For RaG 2006QS17 Plaintiff v. ANTHONY L.CENTURIONE, SR A/K/A ANTHONY L. CENTURIONE Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 09-398-CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Anthony L.Centurione, Sr A/K/A Anthony L. Centurione 142 15th Street Unit G A/K/A 142 G 15th Street New Cumberland, PA 17070 ~a -~- r~, cn ~"` r c~ ~~ ~~ ~~ --t «~ N a rn i w a^• c~ .~- rv Your house (real estate) at 142 15th Street Unit G A/K/A 142 G 15th Street, New Cumberland, PA 17070 is scheduled to be sold at the Sheriffs Sale on March 6, 2013 at 10:00am at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $153,192.26, 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 Sheriffs Sale, you must take immediate action: -~~ .~.., -~s :~-, _,,..~ .:~ -:-, ~t ~ ~,'.=} 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. 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. 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.) r 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 maybe 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 ca11856-669-5400. 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 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800)990-9108 ~: ~.,.. IN THE COURT OF COMMON PLEAS OF C PENNSYLVANIA DEUTSCHE BANK TRUST COMPANY AMERICAS. AS TRUSTEE FOR R.ALI 2006QS 17 v. ANTHONY L. CENTURIONE, SR. A/K/A ANTHONY L. CENTURIONS ORDER UMBERLAND COUNTY, COURT OF COMMON PLEAS CIVIL DIVISION NO. 09-398-CIVIL CUMBERLAND COUNTY AND NOW, this a 3'~d day of It~4iJ , 2010, upon consideration of Plaintiff's Motion far Service of Notice of Sheriffs Sale of Real Property Pursuant to Special Order of court, it is hereby; ORDERED that Plaintiff may obtain service of Notice of Sheriff's Sale of Real Property on the unknown Heirs, Successors, Assigns And All Persons, Firms Or Associations Claiming Right, Title Or Interest From Or Under Anthony L. Centurione, Sr. a/k/a Anthony L. Centurione, Deceased, by regular mail to the mortgaged premises located at 142 15~' Street Unit G a/k/a 142 G 15~' Street, New Cumberland, PA 17070; and by posting the mortgaged premises by the Sheriff or by an non-parry competent adult. 1~~61~ It is further ORDERED and DECREED that counsel for Plaintiff is hereby directed to file a certif cate of service with the Prothonotary's office to assure compliance with this court order. BY THE COURT: J. t ~~ ~ ~~~-~ ~~ o~~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 09-398 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RALI 2006QS17 Plaintiff (s) From ANTHONY L. CENTURIONE, SR. A/K/A ANTHONY L. CENTURIONE (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: $153,192.26 L.L.: Interest FROM 9/9/2010 TO DATE OF SALE MARCH 6, 2013 -Ongoing Per Diem of $26.31 to actual date of sale including if sale is held at a later date - J 23, 4y~ , /U Atty's Comm: Due Prothy: $2.25 Atty Paid: $1,881.21 Other Costs: Plaintiff Paid: Date: 12/3/12 .~ ,_ _ David D. Buell, Prothono (Seal) Deputy REQTJESTING PARTY: Name; ELI~A)1<ETH L. WASSALL, ESQUIRE Address: UDREN LAW OFFICES, P.C. l ll WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 77788 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff IJ Jody S Smith Chief Deputy f 3+ aiY 22 Ai"1 ; ' t Richard W Stewart Solicitor OF CE )`°�E""ER'FF PEN N'S YLWANIA Deutsche Bank Trust Company Case Number vs. 2009-398 Anthony L Centurione, Sr SHERIFF'S RETURN OF SERVICE 12/07/2012 Entry of Appearance By Udren Law Office, As Atty for Plaintiff, filed in Prothonotary's Office 7/2/12. 01/03/2013 11:51 AM -Deputy Dennis Fry, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 142 15th Street Unit G A/K/A 142 G 15th Street, New Cumberland, PA 17070, Cumberland County. 01/03/2013 11:51 AM -Deputy Dennis Fry, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit:Anthony L Centurione, Sr, pursuant to Order of Court by"Posting"the premises located at 142 15th Street, Unit G, A/K/A 142 G 15th Street, Boro of New Cumberland, New Cumberland, PA 17070, Cumberland County with a true and correct copy according to law. 03/07/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Cumberlad County, on March 6, 2013 at 10:00 a.m. He sold the same for the sum of$ 1.00 to Attorney Mark Udren, on behalf of Deutsche Bank Trust Company Americas, as Trustee for Residential Accredit Loans, Inc. (RALI)2006-QS17, being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $1,216.16 SO ANSWERS, May 17, 2013 RONWY R ANDERSON, SHERIFF 41 rf-.oD P�. aa. �. - Pw - L 'UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER Ill WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadinus(a-),udren.com Deutsche Bank Trust Company Americas COURT OF COMMON PLEAS As Trustee For Rali 2006QS17 CIVIL DIVISION Plaintiff Cumberland County v. MORTGAGE FORECLOSURE Anthony L.Centurione, Sr A/K/A Anthony L. Centurione NO. 09-398-CIVIL Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 Deutsche Bank Trust Company Americas As Trustee For Rali 2006QS17,Plaintiff in the above action,by its undersigned attorney,upon information and belief, Udren Law Offices,P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 142 15th Street Unit G A/K/A 142 G 15th Street,New Cumberland,PA 17070 1. Name and address of Owner(s) or reputed Owner(s): Anthony L.Centurione,Sr A/K/A Anthony L. Centurione 14215th Street Unit G A/K/A 142 G 15th Street New Cumberland, PA 17070 Anthony L.Centurione, Sr A/K/A Anthony L. Centurione c/o Unknown Heirs,Successors,Assigns and All Persons,Firms,or Associations Claiming Right,Title or Interest from or under Anthony L. Centurione, Sr.,Deceased 142 15th Street Unit G A/K/A 142 G 15th Street New Cumberland, PA 17070 2. Name and address of Defendant(s) in the judgment: Anthony L.Centurione,Sr A/K/A Anthony L. Centurione 142 15th Street Unit G A/K/A 142 G 15th Street New Cumberland, PA 17070 Anthony L.Centurione, Sr A/K/A Anthony L. Centurione c/o Unknown Heirs, Successors, Assigns and All Persons, Firms, or Associations Claiming Right,Title or Interest from or under Anthony L. Centurione, Sr., Deceased 142 15th Street Unit G A/K/A 142 G 15th Street New Cumberland, PA 17070 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Jr Lien Holders -None 4. Name and tddress of the last recorded holder of every mortgage of record: Deutsche Bank Trust Company Americas As Trustee For Rail 2006QS17 1661 Worthington Road, Suite 100 West Palm Beach, FL 33409 Sr Mortgage Holders-None Jr Mortgage Holders -None 5. Name and address of every other person who has any record lien on the property: Credit One,LL 3619 18th Street Metairie,LA 70002 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: Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Commonwealth of PA,Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Tenants/Occupants 142 15th Street Unit G A/K/A 142 G 15th Street New Cumberland, PA 17070 Internal Revenue Service, Pittsburgh Office Moorehead Building, 1000 Liberty Avenue,Rm 112 Pittsburgh, PA 15222 Department of Public Welfare,TPL Casulty Unit, Estate Recovery Program PO BOX 8486, Willow Oak Bldg. Harrisburg, PA 17105-8486 Commonwealth of PA, Bureau of Individual Tax, Inheritance Tax Division 6th Floor, Strawberry Square,Dept. 280601 Harrisburg, PA 17128 Anthony Centurione,Jr. 142 15th Street Unit G A/K/A 142 G 15th Street New Cumberland, PA 17070 'Theresa A. Centurione 257 Winding Way Camp Hill, PA 17011-8462 Joseph Centurione Address to Follow Unknown Heirs,Successors,Assigns and All Persons, Firms,or Associations Claiming Right, Title, or Interest from or under Anthony L.Centurione,Sr.,Deceased 142 15th Street Unit G AIKCA 142 G 15th Street New Cumberland, PA 17070 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: Federal Tax Lien Holders -None Cumberland Crossing Condo Association Address to Follow I verify that the statements made in this affidavit are true and correct to the best of my 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: UDREN LAW OFFICES, P.C. BY: Attorney for Plaintiff MJU#• 11120597 CASE#• 11120597-1 ELIZABLIt-ii.. PA ID 77788 r UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadin-zs(udren.com Deutsche Bank Trust Company Americas 1 COURT OF COMMON PLEAS As Trustee For Rali 2006QS17 ! CIVIL DIVISION Plaintiff Cumberland County V. MORTGAGE FORECLOSURE ANTHONY L.CENTURIONE,SR A/K/A ANTHONY L. CENTURIONE Defendant(s) NO. 09-398-CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Anthony L.Centurione, Sr A/K/A Anthony L. Centurione 142 15th Street Unit G A/KIA 142 G 15th Street New Cumberland, PA 17070 Your house (real estate) at 142 15th Street Unit G A/K/A 142 G 15th Street,New Cumberland,PA 17070 is scheduled to be sold at the Sheriffs Sale on March 6,2013 at 10:00am at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle,PA 17013, to enforce the court judgment of$153.192.26, 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 Sheriffs 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 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 Cow IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEUTSCHE BANK TRUST COMPANY AMERICAS COURT OF COMMON PLEAS AS TRUSTEE FOR RALI 2006QS17 CIVIL DIVISION V. NO. 09-398-CIVIL ANTHONY L. CENTURIONE, SR. CUMBERLAND COUNTY A/K/A ANTHONY L. CENTURIONE ORDER AND NOW, this --) 3r-` day of /Jov , 2010, upon consideration of Plaintiff's Motion for Service of Notice of Sheriffs Sale of Real Property Pursuant to Special Order of court, it is hereby; ORDERED that Plaintiff may obtain service of Notice of Sheriffs Sale of Real Property on the Unknown Heirs, Successors, Assigns And All Persons, Firms Or Associations Claiming Right, Title Or Interest From Or Under Anthony L. Centurione, Sr. aW- a Anthony L. Centurione, Deceased, by regular mail to the mortgaged premises located at 142 15th Street Unit G alkla 142 G 15"' Street, New Cumberland, PA 17070; and by posting the mortgaged premises by the Sheriff or by an non-party competent adult. It is further ORDERED and DECREED that counsel for Plaintiff is hereby directed to file a certificate of service with the Prothonotary's office to assure compliance with this court order. BY THE COURT: r 15 f J. i. L ALL THAT CERTAIN unit in the property known, named and identified in the declaration referred to below as 'Cumberland crossings Condominium, , located in New Cumberland Borough, Cumberland County, Pennsylvania, which has heretofore been submitted to the provisions of the Pennsylvania Uniform Condominium Act, 68 Pa. C.S.A. 3101 by the recording in the office of the Recorder of Deeds of Cumberland County of a declaration dated March 1, 1988, and recorded on March 25, 1988, in Miscellaneous Book 347, Page 1111, as the same shall be amended from time to time, being and designated in such declaration, as the same may be amended from time to time, as Unit No. 7, also known as 142-G, which said Unit being part of said unit, is more fully described in said declaration, as the same may be amended from time to time, together with a proportionate undivided interest in the Common Elements (as defined in said declaration, as the same may be amended from time to time) . BEING THE SAME PREMISES which Scott A. Lake, a single man, by Deed dated July 1, 2003 and recorded July 3, 2003 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Record Book 257, Page 4774, granted and conveyed unto Anthony L. Centurione, Sr. , a married man. UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights of way, easements and agreements of record. FURTHER UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights of way and easements as set forth on Plats and Plans - Site Plan, recorded in -Plan Book 55, page 43. Parcel No. : 26-23-0541-218A-U7 BEING KNOV� N AS: 142 15TH STREET UNIT G A/KJA 142 G 15TH STREET,NEW CUMBERLAND, PA 17070 PROPERTY ID NO.: 26-23-0541-218A-U7 TITLE TO SAID PREMISES IS VESTED IN ANTHONY L. CENTURIONS, SR.,A MARRIED MAN BY DEED FROM SCOTT A. LAKE,A SINGLE MAN DATED 07/01/2003 RECORDED 07/03/2003 IN DEED BOOK 257 PAGE 4774. CUMBERLAND LAW JOURNAL Writ No. 2009-398 Civil restrictions,rights of way and ease- ments as set forth on Plats and plans Deutsche Bank Trust Company Site Plan,recorded in Plan Book 55, vs page 43 Parcel No.: 26-23-0541- 218A-U7. Anthony L. Centurione,Sr. BEING KNOWN AS: 142 15TH a/k/a Anthony L. Centurione STREET UNIT G a/k/a 142 G 15TH Atty.:Mark Udren STREET, NEW CUMBERLAND, PA ALL THAT CERTAIN unit in the 17070. property known, named and iden- PROPERTY ID NO.: 26-23-0541- tified in the declaration referred 218A-U7. to below as `Cumberland Cross- TITLE TO SAID PREMISES IS ings Condominium,'located in New VESTED IN ANTHONY L. CENTU- Cumberland Borough, Cumberland RIONE, SR., A MARRIED MAN BY County, pennsylvania, which has DEED FROM SCOTT A. LAKE, A heretofore been submitted to the SINGLE MAN DATED 07/01/2003 provisions of the pennsylvania Uni- RECORDED 07/03/2003 IN DEED form Condominium Act,68 Pa.C.S.A. BOOK 257 PAGE 4774. 3101 by the recording in the Office of the Recorder of Deeds of Cumberland County of a declaration dated March 1, 1988,and recorded on March 25, 1988, in Miscellaneous Book 347, Page 1111, as the same shall be amended from time to time, being and designated in such declara- tion, as the same may be amended from time to time,as Unit No.7,also known as 142-G, which said Unit being part of said Unit,is more fully described in said declaration,as the same may be amended from time to time, together with a proportionate undivided interest in the Common Elements(as defined in said declara- tion, as the same may be amended from time to time)BEING THE SAME PREMISES which Scott A. Lake, a single man, by Deed dated July 1, 2003 and recorded July 3, 2003 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Record Book 257, Page 4774, granted and conveyed unto Anthony L. Centurione, Sr.,a married man. UNDER AND SUBJECT to any and all covenants,conditions,restric- tions, rights of way, easements and agreements of record. FURTHER UNDER AND SUBJECT to any and all covenants,conditions, 29 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: January 25, February 1, and February 8, 2013 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. L' a Marie Coyne Editor SWORN TO AND SUBSCRIBED before me this 8 day of February,2013 ' r Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 i The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Now you know Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE= C,"-.RLISL E PA 1701? 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 Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant 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 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, 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/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement a- to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement or 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. 2009-n8 Chrll Deutsche Bank�rrustCo pay This ad ran on the date(s)shown below: ony L Centurion,S sWa 01/22/13 Anthony L.-CeMurlo Atty-Mark Udren 01/29/13 ALL THAT CERTAIN unit in the 02/05/13 perry known, named and identified ', m the declaration referred to below as 'Cumberland Crossings Condominium,' located in New Cumberland Borough, . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Cumberland County, which has heretofore beePennsylvania, to the provisions of the PennsylMm Sworn ro and spbscribed before me t 4 of February, 2013 A.D. Uniform Condominium Act,68 Pa.C.$.A. 3101 by the.recording in the Office of the Recorder of Deeds of Cumberland County of a declaration`dated March 1, 0 " 1988,and recorded on March 25;1988,in Ot Miscellaneous Book 347,Page 1111,as the same shall be amended from time to time, being and designated in such declaration, COMMONW TM OF PENNSYLVANIA as the same may be amended from time to Notarial Seal time,as Unit No.7,also known as 142-G, Holly Lynn Warfel,Notary Public which said Unit being part of said Unit,.' Washington Twp.,Dauphin County more fully described in said declaration, My Commission Expires Dec.12,2016 as the same may be amended from time MEMBER PENNSYLVANIA ASSOCWTION OF NOTARIES to time, together with a,proportionate undivided interest in the Coi4on El is (as defined in said declaratitfet,as th, safe may be amended from time to time) BEING THE SAME PREMISES which Scott A.Lake,a single man,by Deed dated July 1,2003 and recorded July 3,2003 in the Office of the-Recorder of Deeds in and for Cumberland County,Penmymma,in Record Book 257,Page 4774,,,$grraannted and conveyed unto Anthony L. fturionc,Sr,a married man. UNDER AND SUBJECT to any and all covenants,conditions,restrictions,rights of way,easements and agreements of record. FURTHER UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights of way and easements as set forth on Plats and plans Site Plan, recorded in Plan Book 55,page 43. Parcel No.:26.23-0541-2184-U7 BEING KNOWN AS:14215TH STREET UN1T G A/K/A 142 G 15TH STREET, NEW CUMBERLAND,PA 17070 PROPERTY ID NO.:26-23-0541-218A-U7 TnU TO SAID PREMISES IS VESTED IN ANTHONY L. CENTURIONS,SR., A MARRIED MAN By DEED FROM DATED 07/01 A SINGLE MAN RECORDED- 07/03/2003 IN DEED nnnv1c,,. __.--. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: 1, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Deutsch Bank Trust co Americas as Trustee for Residential Accredit Loans Inc. is the grantee the same having been sold to said grantee on the 6th day of March A.D., 2013, under and by virtue of a writ Execution issued on the 3rd day of December, A.D., 2012, out of the Court of Common Pleas of said County as of Civil Term, 2009 Number 398, at the suit of Deutsche Bank Trust Co Americas as Trustee for Rali 2006OS 17 against Anthony L. Centurione Sr. A/K/A Anthon�L. Centurione is duly recorded as Instrument Number 201316841. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this . --'d day of A.D. az 13 F" ecorder of Deeds d owiftOeA*FA MyQWftdM �RitMa dJn7,014