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Home My WebLink About04-2059 GOLDBECK McCAFFERTY & McKEEVER By: JOSEPH A. GOLDBECK, JR. ATTORNEYI.D. #16132 SUITE 5000 - MJi;LLON INDEPENDENCE CENTER. 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2003-4 9451 Corbin Avenue Northridge, CA 91324 OF CUMBERLAND COUNTY CIVIL ACTION - LAW Plaintiff ACTION OF MORTGAGE FORECLOSURE vs. JONATHAN BALDARI TAMMY BALDARI Mortgagor{s) and Real Owner{s) Term I?' l No. 04 - ;),Os-'t l;~I.>\' Ieit.~ 806 Hummel Avenue Lemoyne, P A 17043 Defendant(s) CIVIL ACTION: MORTGAGE FO~!CLOSUAE TIDS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personal1y or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. Yau are warned that if you fail to do so the case may proceed without you and ajudgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE TIDS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW, TillS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT IDRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THA T MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE, LEGAL SERVICES mc 8 Irvine Row Carlisle. PA 17013 717.24)-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 i\..Y.ll.Q LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y A VISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A EST A DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU P ARTICIP ACION. ENTONCES, LA COUTE PUBDE. SIN NOTlFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE EST A DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORT ANTES. USTED DEBE LLEV AR E.STE P APEL A SU ABOGADO ENSEGUIDA. SI VSTED NO T1ENE UN ABOGADQ, VA Y A 0 LLArvffi POR TEL1lFONO LA OFICINA FIJADA AQUJ ABAJO, E5TA OFICINA PUEDE PROVEERb CON INFORMACION DE COMO CONSEUIR UN ABOGADO. 51 USTED NO PUBOE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AOENCIAS QUE PUEOAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REOUCIDO 0 GRATIS, LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA17013 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiffjs DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2003-4,9451 Corbin Avenue, Northridge, CA 91324. 2. The name(s) and addressees) ofthe Defendant(s) is/are JONATHAN BALDARI, 806 Hummel Avenue, Lemoyne, PA 17043 and TAMMY BALDARI, 806 Hummel Avenue, Lemoyne, PA 17043, who is/are the mortgagor( s) and real owner( s) of the mortgaged premises hereinafter described. 3. On May 20,2003 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to LONG BEACH MORTGAGE COMPANY, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1815 Page 3080. The mortgage has not been assigned unless said assignment to the Plaintiff is hereafter mentioned. The aforementioned mortgage was assigned to: DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2003-4 by Assignment of Mortgage, which assignment is lodged for recording. These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 10 19(9). 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payment of principal and interest upon said mortgage due November 01,2003, and each month thereafter are due and unpaid, and by the tenns of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest from 10/01/2003 through 05/31/2004 at 9.8000% Per Diem interest rate at $21.86 Attorney's Fee at 5.0% of Principal Balance Late Charges from 11/01/2003 to 05/31/2004 Monthly late charge amount at $42.24 Costs of suit and Title Search $81,446.31 $5,333.83 $4,072.32 $295.68 Escrow Fees Recoverable balance Monthly Escrow amount $103.80 $900.00 $92,048.14 +$511.76 +$102.60 +$330.00 $92,992.50 7. The Attorney's Fees set forth above are in confonnity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriff's Sale. Ifthe Mortgage is reinstated prior to the Sale reasonable Attorney's Fees will be charged based on work actually perfonned. 8. Notice ofIntention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant(s) by Certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) VERIFICATION I, CARRIE CASCONE, as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: MAy.f , 2004 D NATIONAL TRUST FOR LONG LOAN TRUST #0074570417 - JONATHAN BALDARI and TAMMY BALDARI D8\1!: 4/29103 .. .. OEd8r ~r: 000011762 Re: J"".tIIa.. ..ldad 'l'Uay ..1dari 806 HUMMBL AVENUB LBMOlNB, PA 170.3 CUMBERLAND County . '&DI.BIlf 1.1.1 ALL THAT CERTAIN lot of ground .itu.te in the Borough of Lemoyne, Cumberland County, pennsylvania, said lot being bounded and de.cribed es follow.: BEGINNING at a point on the Southern line of Hummel Avenue st the distsnce of .0 reet we.twardly, mea.ured from the southwest corner of Hu..el Avenue and Eighth Street formerly blackberry Alley; thence in southerly direction, along the western line of Lot Mo. 12 Block ~E" on the plan or lot. hereinafter mentioned, 150 feet to a point on the northern line or Peach Alley; "thence 'in a westerly direction, along the northern line of .aid Peach Alley, 17-1/2 feet, more or le.., to a point; thence in a northerly direction, along a line running through the center of the partition wall of the double hou.e erected in part on .aid Lot, 150 Ceet to a point on the Southern line of Hummel Avenue, thence in an ea.terly direction along the Southern line of Hummel Avenue, 17-1/2 feet, more or less, to a point, the Place of BEGINNING. f9ge: 7 of 7 1lme: 12:50:38 PH Ordlr Nurmer ??oo11762 Washington Mutual P.O Box 1039 Northridge, CA 91328-1 093 January 14, 2004 '0002592441' Jonathan Baldari 806 Hummel Ave Lemoyne, P A 17043-0000 EXHIBIT A ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE FOUR The Homeowners' Emergency Mortgage Assistance Program (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can helD vou. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the counselin~ agency. The name. address. and phone number of Consumer Credit Counselinlot A.gencies serving your county are listed at the end of this Notice. If YOU have any Questions. you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (persons with impaired hearing; can call 717-780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. La Notificaion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa, Si no comprende el contenido de esta notificion obtenga una traduccion immediatamente llamando esta agenda (Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba. Puedes ser elegible para un prestamo por el programa Hamado "Homeowners' Emergency Mortgage Assistance Program" al cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: Jonathan Baldari 806 Hummel Ave Lemoyne,PA 17043 0074570417 Washington Mutual LOAN ACCOUNT NUMBER: CURRENT You may be eligible for fmancial assistance. which can save your home from foreclosure and help vou make future mortgage payments, if you comply with the provision of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be eligible for emergency mortgage assistance: . If your default has been caused by circumstances beyond your control, . If you have a reasonable prospect of being able to pay your mortgage payments, and . If you meet other eligibility requirements established by the Pennsylvania Housing Finance Agency. Washington Mutual P.O Box 1039 Northrldge, CA 91328.1093 January 14,2004 '0002592440. Tammy Baldari 806 Hununel Ave Lemoyue, P A 17043-0000 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific infonnation about the nature of the default is provided in the attached pages. IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE FOUR The Homeowners' Emergency Mortgage Assistance Program (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can help vou. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF lHIS NOTICE. Take this Notice with yoU when vou meet with the counselimt agency. The name, address. and phone number of Consumer Credit Counseling Agencies serving your county are listed at the end afthis Notice. If YOU have any Questions. you may call the Pennsylvania Housing Finance Agency tQII free at 1-800-342-2397 (oersons with impaired hearing can call 717-780-1869). This Notice contains important legal information, If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. La Notjficaion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notificion obtenga una traduccion imrnediatamente llamando esta agencia (Pennsylvania Housing Finance Agency) sin cargos a1 numero mencionado arriba. Puedes ser elegible para un prestamo par el programa llamado "Homeowners' Emergency Mortgage Assistance Program" al cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: Tammy Baldari 806 Hununel Ave Lemoyne, PA 17043 0074570417 Washington Mutual LOAN ACCOUNT NUMBER: CURRENT You may be eligible for [mancial assistance, which can save vour home from foreclosure and help vou make future mortgage payments, if you comply with the provision of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be eligible for emergency mortgage assistance: . If your default has been caused by circumstances beyond your control, . If you have a reasonable prospect of being able to pay your mortgage payments, and . If you meet other eligibility requirements established by the Pennsylvania Housing Finance Agency. Page two 0074570417 TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of the foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer COWlSeling agencies listed at the end of this Notice. This meeting must occur within the next thirty (30) davs. IF YOU DO NOT AP.PLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NQTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take further action against you for thirty (30) days after the date of this meeting. The names. addresses and telephone numbers of designated consumer counseling agencies for the county in which vour property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. You should advise this lender innnediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for [mancial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit cOWlSeling agencies have applications for the program and they will assist you in submitting a completed application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDlA TEL Y AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing finance Agency has sixty (60) days to make a decision after it receives you application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (Uyou have filed bankruptcy you can stilI apply for Emergency Mortgage Assistance) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at 806 Lemovne. P A 17043 IS SERIOUSLY IN DEFAULT because: Hummel Ave A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payments from 1110112003: (b) Late charger s) : (c) Other chargers): NSF & Advances (d) Less: Credit Balance (e) Total amount required as of 01/13/2004: $2,423.64 $42.24 $15.20 $.00 $2,481.08 B. YOU HA VE FAILED TO TAKE THE FOLLOWING ACTION (if applicable): HOW TO CURE THE DEFAULT - You may cure this default within THIRTY (30) days from the date of this letter BY PAYING THE TOTAL AMOUNT PAST DUE TO LENDER, WHICH IS 52.481.08. PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check, or money order made payable to Washington Mutual at COLLECTION SUPPORT MAIL STOP N010201, 9451 CORBIN AVENUE, NORTHRIDGE, CA 91324. Page three 0074570417 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) days of this letter date, the lender intends to exercise its ri~ht to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately, and you may lose the chance to pay the mortgage in monthly installments. IffuB payment of the amount of default is not made within THIRTY (30) days of the letter date, Washington Mutual also intends to iIlBtruct their attorneys to start a legal action to foreclose upon your mort~aged property IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before they begin legal proceedings against you, you will haye to pay the reasonable attorney's fees actuaBy incurred up to $50.00. Howeyer, if legal proceedings are started against you, you will haye to pay the reasonable attorney's fees actuaBy incurred even if they are over $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include their reasonable costs. If you cure the default within the THIRTY (30) DAY period. you will not be required to pay attorneys' fees. OTHER LENDER REMEDIES - The lender may also sue you personaBy for the unpaid principal balance, and aB other sums due under the Mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due plus any late charges, charges then due, reasonable attorneys' fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this Notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such sheriff's sale could be held is would be approximately five (5) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may fmd out at any time exactly what the required payment or action wiB be by contacting the lender. HOW TO CONTACT THE LENDER Name of Lender: Address: Telephone Number: Washington Mutual COLLECTION SUPPORT MAIL STOP N010201, 9451 CORBIN AVENUE, NORTHRIDGE, CA 91324 800-282-4840 EFFECT OF SHERIFF'S SALE - You should realize that a sheriff's sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the sheriff's sale, a lawsuit to remove you and your furniture and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may not seB or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that aB the outstanding payments, charges and attorneys' fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT . To seB the property to obtain money to pay off the mortgage debt, or borrower money from another lending institution to pay off this debt. . To have this default cured by any third party acting on your behalf. . To have the mortgage restored to the same position as ifno default had occurred. (However, you are not entitled to this right more than three times in a calendar year). . To assert the nonexistence of a default in any foreclosure proceeding or any other lawsuit instituted under the mortgage documents. . To assert any other defense you believe you may have to such action by the lender. . To seek protection under the federal bankruptcy law. Page four 0074570417 Washington Mqtual is attempting to collect a debt, and any information obtained will be used for that purpose. , Federal law gives you thirty days after you receive this letter to dispute the validity of this debt or any part of it. If you notify us in writinl! at the below address within the thirty day period that the debt, or any portion thereof, is disputed, we will: 1) Provide to you, upon your written request, verification of the debt or a copy of any judgment entered against you. 2) Provide to you, upon your written request, the name and address of your original creditor, ifthe original creditor is different from the current creditor Unless you dispute the debt within that thirty (30) day period, we will assume that it is valid. Sincerely, Washington Mutual N (J 'kl.. it. 1. frt Crt ..... ........ . ~ ~ ~ ~ ~ D -..J '-..l::. :rJ P- t: --.z ~-') ~) ., ( ,.,~:;";) ~j~'- o -n --i _ '. =r rn:'J r.~;~; l,J , -...l r) . () ~.u ., \':) -n (--:) I.> W :~l Q GOLDBECK McCAFFERTY & McKEEVER By: JOSEPH A. GOLDBECK, JR. AITORNEY LD. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET SlREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 A ITORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2003-4 9451 Corbin Avenue Northridge, CA 91324 Term No. 04-2059 CIVIL TERM Plaintiff vs. JONATHAN BALDARI TAMMYBALDARI 806 Hummel Avenue Lemoyne, PA 17043 Defendant( s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. GOLDBECK, McCAFFERTY & McKEEVER ?JI'~ By Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff i'::, "'~:- ~ '-' = = ...- '- c: ;;;~':: o ..,-, ::;:l fii :Li ,.- -om :D.6.:J o -1 . ;I~:n .,,)--,- :,~5fii N Ul ~ ":? en .a;::'- ,~::-- :< SHERIFF'S RETURN - REGULAR CASE NO: 2004-02059 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS BALDARI JONATHAN ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BALDARI JONATHAN the DEFENDANT , at 1940:00 HOURS, on the 1st day of July 2004 at 37 DREXEL PLACE NEW CUMBERLAND, PA 17070 by handing to JONATHAN BALDARI 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 18.00 12.58 .00 10.00 .00 40.58 So ;:::~~ R. Thomas Kline 07/07/2004 GOLDBECK MCCAFFERTY MCKEEVER 0"'_ me this b - ql~O'.;2>>t>,-{ A.D. 1_ Q ~ J.J:" rothonotary i r' day of By' a / DrpU y Sworn and Subscribed to before SHERIFF'S RETURN - NOT FOUND CASE NO: 2004-02059 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS BALDARI JONATHAN ET AL 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 BALDARI TAMMY but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , BALDARI TAMMY 806 HUMMEL AVENUE LEMOYNE, PA 17043 806 HUMMEL AVENUE LEMOYNE IS VACANT. DEFENDANT BELIEVED TO BE LIVING IN HARRISBURG. Sheriff's Costs: Docketing Service Not Found Surcharge So answe ~--- .--- 6.00 11.10 5.00 10.00 .00 32.10 R. Thomas Klirie- Sheriff of Cumberland County GOLDBECK MCCAFFERTY MCKEEVER 07/07/2004 Sworn and subscribed to before me this y~ day Of~ )..0-0 t{ A. D. nL'~LL (l ~-'u, ~ pr~ohotary ,--' SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-02059 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS BALDARI JONATHAN ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: BALDARI JONATHAN but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On July 7th , 2004 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Dep Dauphin County 6.00 9.00 10.00 48.00 .00 73.00 07/07/2004 GOLDBECK MCCAFFERTY So / . _....- ~.-:::.~_~~~ ...0;> -r '~~----" R. homas Kline Sheriff of Cumberland County MCKEEVER Sworn and subscribed to before me ,P ~~ day of ~ this )/J1J'{ A.D. q Uc h..:. ~ J ,-t. I rL-<..l.{(..... ~ f rothonotary SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-02059 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS BALDARI JONATHAN ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: BALDARI TAMMY but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On July 7th , 2004 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 07/07/2004 GOLDBECK MCCAFFERTY So answers:. . r' "" A:"?-........</---~. ---;//-~..=tr=../ R/ Thomas Kline Sheriff of Cumberland County MCKEEVER Sworn and subscribed to before me this Fe day of YJl.; ;J(JO 'f A. D. ( '\ . CJ. ~-Pu. A ~nf.' /'hothonotaryl ''''-' SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-02059 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS BALDARI JONATHAN ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: BALDARI JONATHAN but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On July 7th , 2004 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge So --- " 6.00 .00 10.00 .00 .00 16.00 07/07/2004 GOLDBECK MCCAFFERTY ,/ -;~~// -" ./f./;-::-:::: , -'~~ ...~:::.-.::.:c:'p R. homas Kllne " Sheriff of Cumberland County MCKEEVER Sworn and subscribed to before me this day of A.D. Prothonotary SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-02059 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK NATIONAL TRUST VS BALDARI JONATHAN ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: BALDARI TAMMY but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On July 7th , 2004 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 07/07/2004 GOLDBECK MCCAFFERTY So ans~ %/-~~-~-~ ... R( Thomas Kline ( Sheriff of Cumberland County MCKEEVER Sworn and subscribed to before me this day of A.D. Prothonotary R. THOMAS KLINE Sr..rill "'w O{ q[.Ul17bl'c ~~~ .... ~Jl '~1" ~ 111.. ~ 1'-.' .-.1'...... _. ''I:'~ '}"~;I?!?c=."~"".V'f" ".,.::17"/ A'~,!Y'.~ \. m hf 'V:~~dA';;;.\t,\0-r ". '--;' P,AI/i -"h,'.""" }^" ,'. <!" (I' .--"','\"1.f"-'''~U,~1 -,j ~ 'it &.~1(~:~~;~r~~~9li~ EDWARD L. SCHORPP Solicitor OFFICE OF THE SHERIFF One Courthouse Square Carlisle, Pennsylvania 17013 RONNY R ANDERSON Chief ()~;~IU[Y JODY S. SMITH Real Estate Deputy TO: Hon. Jack Lotwick Dauphin County Sheriff RE: Deutsche Bank National Trust Canpany VS Jonathan Baldari et al 04-2059 civil . Dear Sir: Enclosed please find Notice and Canplaint in Mortgage Foreclosure 1. Jonathan Baldari 2. Tcmny Baldari to be served upon 8130 Evelyn Street Hummelstown. PA 17036 in your County. Kindly make service thereof and send us your return of service. Enclosed is the advance payment wliich you requested. Very truly yours, .r~~~-~' R. Thomas Kline, Sheriff Cumberland County, Pen11s)dvania Enclosures: In Tbe Court of Common Pleas of Cumberland County, Pennsylvania Deutsche Bank National Trust Canpany vs. Jonathan Baldari et al SERVE: Jonathan Baldari No. 04-2059 civil Now, May 10, 2004 L SHERIFF OF CUMBERLAND COUNTY, P A, do , ' hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ..".-, ./ -::-:::;" .r~"'o:-..":<-1~~~ Sheriff of Cumberland County, PA Affidavit of Service Now, ,20_, at 0' clock M. served the within upon at by handing to a copy of the original and made known to the contents thereof. So answers, Sheriff of County, PA Swam and subscribed before me this_day of ,20_ COSTS SERVICE :MJLEAGE AFFIDA VIT $ $ @ffite of tlp~ ~4e:riff William T. Tully Solicitor J. Daniel Basile Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255.2660 fax: (717) 255.2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania DEUTSCHE BANK NATIONAL TRUST CO vs County of Dauphin BALDARI JONATHAN Sheriff's Return No. 4549-T - -2004 OTHER COUNTY NO. 04-2059 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for BALDARI JONATHAN the DEFENDANT named in the within COMPLAINT IN MORTGAGE FORECLOSURE and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, May 25, 2004 AS PER RESIDENT DEFT LIVES IN YORK, PA OR CUMBERLAND COUNTY. Sworn and subscribed to before me this 27TH day of MAY, 2004 So Answers, C;f~ Sheriff of Dauphin County, Pa. ~ By NOTARIAL SEAL MARY JANE SNYDER, Notary Public Highspire, Dauphin County My Commission Expires Sept 1, 2006 Deputy Sheriff Sheriff's Costs:$48.00 PD 05/13/2004 RCPT NO 194627 In The Court of Common Pleas of Cumberland County, Pennsylvania Deutsche Bank National Trust Canpany VS. Jonathan Baldari et al SERVE: Tamny Baldari No. 04-2059 civil Now, May 10, 2004 , I, SHERlFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ..../,?"""p" /~. r~~~4~ , Sheriff of Curnberland County, PA Affidavit of Service Now, , 20_, at o'clock M. served the within upon at by handing to a copy of the original and made known to the contents thereof So answers, Sheriff of COUllty, PA SWOI1l and subscribed before me this _ day of ,20_ COSTS SERVICE MILEAGE AFFIDAVIT $ $ @ffict of :Urr ~4eriff William T. Tully Solicitor J. Daniel Basile Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 1710 I ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania DEUTSCHE BANK NATIONAL TRUST CO vs County of Dauphin BALDARI JONATHAN Sheriff's Return No. 4549-T - -2004 OTHER COUNTY NO. 04-2059 AND NOW:May 25, 2004 at 6:37PM served the within COMPLAINT IN MORTGAGE FORECLOSURE upon BALDARI TAMMY by personally handing to FORREST CARBAUGH BOYFRIEND OF DEFT 1 true attested copy(ies) of the original COMPLAINT IN MORTGAGE FORECLOSURE and making known to him/her the contents thereof at 8130 EVELYN ST HBG, PA 17036-0000 Sworn and subscribed to before me this 27TH day of MAY, 2004 j7~ ~A/ Sheriff of Dauphin co~ By NOTARIAL SEAL MARY JANE SNYDER, NOllU)' Public Highspire, Dauphin Courity My Commission Expires Sept. I, 2006 Sheriff's Costs:$48.00 PO 05/13/2004 RCPT NO 194627 K COOK fl. THOMAS KLINE Shariff ~w of qf.Uln6et ~~ -v. A l<tl.lq ,'.f'~~ ~ ~,'''' "..~ J-"1; .. ",,'~ 'it"., ;i'%':~J.{ij;-;t'i,,g " ",/ ';~jt';" ,.,n,,:. '.~, ,{"',""-'" tJi,~,~,E:.ft\~:-f ~"\'\'?\~ /.,"" I '" ',' ','. '~ r'}I." "-'ill (~'f ll' "-"," :\llt.... ,.:<J"l,b1 ''t, "~~l~%~;~~L ~" ':i~5i~v ' EDWARD L. SCHORPP Solicitor OFFICE OF THE SHERIFF One Courthouse Square Carlisle, Pennsylvania 17013 RONNY F1. ANf.)Ei-1SCJi\J Ghi8f D8pul/ JODY S, SMITH Real Estate Oeputy Hon. Jack Lotwick Dauphin County Sheriff Deutsche Bank National Trust Company VS Jonathan Baldari et al 04-2059 civil ' TO: RE: Dear Sir: Enclosed please find Notice and Canplaint in Mortgage Foreclosure 1. Jonathan Baldari 2. Tcmny Baldari to be served upon 2254 N. Third Street #b Ha=isburg, PA 17110 in your County. Kindly make service thereof and send us your retum of service. Enclosed is the advance payment wJ:ich you requested. Very truly yours, .r~~~~~' R. Thomas Kline, Sheriff Cumberland County, Peilllsylvania -Enclosures: -' In The Court of Common Pleas of Cumberland County, Pennsylvania Deutsche Bank National Trust Canpany VS. Jonathan Baldari et al SERVE: Jonathan !3aldari No. 04-2059 civil Now, May 10, 2004 , L SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Dauphin COlll1ty to execute this Writ, this deputation being made at the request and risk of the Plaintiff. .......-;/ ~ ~~~.., ..-ii?"~ Sheriff of Cum berland County, PA Affidavit of Service Now, ,20_, at 0' clock M. served the within upon at by handing to a copy of the original and made known to the contents thereof So answers, Sheriff of County, PA Swam and subscribed before me this _ day of ,20_ COSTS SERVICE IY11LEAGE AFFIDAVIT $ ~ $ In The Court of Common Pleas of Cumberland County, Pennsylvania Deutsche Bank National Trust Canpany VS. Jonathan Baldari et al SERVE: Tarrmy Baldari No. 04-2059 civil Now, May 10, 2004 , r, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk ofthe Plaintiff. ~r'/ /~#. r ~~~4"~ Sheriff of Curnberlmld County, PA Affidavit of Service Now, ,20_, at o'clock M. served the within upon at by handing to a copy of the original and made known to the contents thereof. So answers, Sheriff of County, PA Swam and subscribed before me this _ day of ,20_ COSTS SERVICE MILEAGE AFFIDA VrT $ $ GOLDBECK McCAFFERTY & McKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: Kristina G. Murtha, Esq. Attorney I.D.#61858 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2003-4 9451 Corbin Avenue Northridge, CA 91324 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY vs. JONATHAN BALDARI and TAMMY BALDARI 806 Hummel Avenue Lemoyne, P A 17043 No. 04-2059 CNIL TERM TillS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. MOTION FOR SUBSTITUTED SERVICE UNDER PA.R.C.P. 430(a) Plaintiff, by and through its attorney, Kristina G. Murtha, Esq., in support of its Motion for Substituted Service, represents as follows: 1. Plaintiff is the holder of a first mortgage upon the premises 806 Hummel Avenue, Lemoyne, PA, 17043, hereinafter, the "mortgaged premises". 2. Defendants, JONATHAN BALDARI and TAMMY BALDARI, are the mortgagors and real owners of the mortgaged premises. 3. The last known address of Defendant, Tammy Baldari is 8130 Evelyn Street, Hummelstown, P A 17036. 4. The Sheriff has been unable to effect service of the Notice of Sale upon Defendant, Tammy Baldari, at her last known address after 3 attempts. 1. October 15, 204 at 8:00 P.M., No Answer. 2. October 18,2004 at 4:00 P.M., No Answer. 3. October 20,2004 at 2:10 P.M., No Answer. Service was also attempted at the Defendant's property address, 806 Hummel Avenue, Lemoyne, P A 17043. According to the certification provided by the process the property appears vacant. 5. The following investigation was conducted in a good faith attempt to ascertain the whereabouts of Defendant, Tammy Baldari. WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff to serve the Notice of Sale upon Defendant, Tammy Baldari, by posting the pre ses and certified and ,,/ L__~~/ regular mail to the Defendant's last known address. BY: Kristina G. Murtha; PLAYERS NATIONAL LOCATOR AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number: WM-0203 Attorney Firm: GOLDBECK, MCCAFFERTY & MCKEEVER Case Number: Subject: Tammy Baldari /)1)' .,--, Property Address: ue Lemoyne, Pa 17043 Last Known Address: 806 Hummel Avenue Lemoyne, PA 17043 Last Known Number: ( ) - Melissa Kozma, being duly sworn according to law, deposes and says: 1. I am employed in the capacity of Location Specialist for Players Nationall.ocator. 2. On 04/27/2004, I conducted an investigation into the whereabouts of the above named defendant(s). The results of my investigation are as follows: .~ CREDIT INFORMATION- A. SOCIAL SECURITY NUMBER(S): B. EMPLOYMENT SEARCH: We were unable to verify current employment for Tammy Baldari. C. INQUIRY OF CREDITORS: Creditors indicated the last reported address for Tammy Bald.ui is 8130 Evelyn Street, Hummelstown, PA 17036 with no valid home number. INQUIRY OF TELEPHONE COMPANY - A. DIRECTORY ASSISTANCE SEARCH: Directory assistance does not have a listing for Tammy Balda!'i. INQUIRY OF NEIGHBORS - We contacted 717-763-4156 registered at 808 Hummel Avenue and spoke with a neighbor who stated Tammy Baldari has moved from 806 Hummel Avenue, Lemoyne, PA 17043. INQUIRY OF POST OFFICE - A. NATIONAL ADDRESS UPDATE: As of April 21, 2004 the National Change of Address (NCOA) hilS no change for Tammy Baldari from 8130 Evelyn Street, Hummelstown, PA 17036. MOTOR VEHICLE REGISTRATION - A. MOTOR VEHICLE & DMV OFFICE: The Pennsylvania Department of Motor Vehicles has Tammy Baldari listed at 806 Hummel Avenue, Lemoyne, PA 17043. OTHER INQUIRIES - . A. DEATH RECORDS: As of April 21, 2004 the Social Security Administration has n(>> de.ath record on file for Tammy Baldari and/or A.K.A's under the social security number provided. B. PUBLIC LICENSES ( PILOT, REAL ESTATE, ETC. ): None Found. C. COUNTY VOTER REGISTRATION: The County Voters Registration Office has no listing for Tammy Baldari. OTHER SEARCHES - The social security number(s) provided have been verified. ADDITIONAL INFORMATION ON SUBJECT- A. DATE OF BIRTH: December 1958 ~ .. NOTARY SEAL" Krist!ne M. Scott, Netary Public St. LoUIS County, State of Missouri My Commission Expires 9/2/2006 Players National Locator 174 Clarkson Road, Suite 225 Sf. Louis, MO 63011 Phone: (636) 230-9922 Fax: (636) 230-0558 (.,QrYl- 0;).0) IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY DEUTSCHE BANK NATIONAL TRUST CO. JONATHAN BALDARI & TAMMY BALDARI (Petitioner) Plaintiff VS. (Respondent) Defendant CASE and/or DOCKET: 04 2059 I Declare that I am a Pennsylvania State Deputy Constable and/or Process Server, in and for the County of Montgomery, that I am not a party to this action, not an employee of a party to this action, or an attorney to the action, and that within the boundaries of the state were service was ,effected, I was authorized by law to perform the said service. SERVICE SERVICE UPON: TAMMY BALDARI Address: 8130 EVELYN ST. HUMMELSTON, P A 17036 On: At: Description: Approximate Age: _Height: _Weight: _Race: __Sex: _Hair:_ With the documents: NOTICE OF SHERIFF'S SALE OF REAL PUOPERTY MANNER OF SERVICE By handing a copy to: o 1.) Defendant(s) personally served 02.) Adult family member with whom said Defendant(s) reside. Name: Relationship: o 3.) Adult in charge of defendants residence. Name: Relationship: 04.) Posted Property 05.) Agent or person in charge of Place of Business. Name: Title: Comments: fV\..~ '5 fo'(' - Forl'O f CA-t.8ttvf6H, tV~(51.4..... S U"-A-"tc.. .,(, Vk t:;..- NO SERVICE Defendant was not served becx..e: _Moved _Unknown No Answer _Vacant _ Other: Service w~ttemPted on the following dates and times: ) 1.) lo/if'. Qt.! . ~twf"""" 2.) /()II~/(:1'1. ~~'p.-3.) IO/Jo(l fOY Date: Time: Date: Tune: Date: SERVER INFORMATION I(~/du/v'f ;2IP/,,,,, Time: /0 1"1' ~ ~~~J. CONSTABLE PUTY/PROCESSSERVER UNIVERSAL LAWYERS' SERVICE 93 EAST MAIN ST. BAY SHORE, NY 11706 631.666.6168 Sworn to and subscribed before me this __~_.day of _~__ 200.f Not~ -- NOTARIAl SEAl ERIC MATTHIAS AfflERBACH. NOTARY PUBLIC CITY OF TRAPPE BOROUGH. MONTGOMERY CO.. PA MY COMMISSION El\PIRES NOVEMBER 14, 2005 MEMBER, PENNSYlVANIA ASSOCIATION OF NOTARIES 10 S""'S'V From: 11/03/2004 15:06 #106 P.001/002 . SHERI FF I $ RETURN - NO'r FOUND CASE NO: 2004-02059 P COMM:ONTWBAL'l'H OF PENNSYLVANIA. COUNTY OF CUMBERLA:ND DEUTSCHE BANK NA'I'I.ONAL TRUST VS SALDARI JONATHAN ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly s~orn according to law, says, that he made 'a di~igent search and inquiry for the within named DEFENDANT BALIlARI TAMMY but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT MORT FORE , NOT FOUND , as to t.he within named DEFENDANT , BALDARI 'XAfoIlMY , . 'S06 'ijUMMHL"AvENUE . LEMOYNE, PA 17043 80 E) HUMMJi:L iWENt1E LEMOYNE IS VACANT. DEFENDANT.BELIEVED TO BE LIVING IN HARRISBURG. Sheriff's Costs: Docketing Service Not Found Sur~harge (5.00 11.10 5.00 10.00 .00 : 32.10 $0 ~nswe' ;;:? ../ . ~~----= - R. ~~- Sheriff of Cumbl;!rland County GOLDBECk MCCAFFlmTY MCKEEVER 07/07/2004 Sworn and eu~scribed to before me this d.ay of A.D. prothonotary GOLDBECK McCAFFERTY & McKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: Kristina G. Murtha, Esq. Attorney I.D.#6l858 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2003-4 9451 Corbin Avenue Northridge, CA 91324 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY vs. No. 04-2059 CNIL TERM JONATHAN BALDARI and TAMMY BALDARI 806 Hummel Avenue Lemoyne, P A 17043 VERIFICATION I, Kristina G. Murtha, Esq., Attorney for Petitioner do hereby verify that the facts set forth in the foregoing Motion for Substituted Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subje,ct to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. BY: GOLDBECK McCAFFERTY & McKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: Kristina G. Murtha, Esq. Attorney I.D.#61858 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2003-4 IN THE COURT OF COMMON PLEAS 9451 Corbin Avenue Northridge, CA 91324" OF Cumberland COUNTY vs. JONATHAN BALDARI and TAMMY BALDARI 806 Hummel Avenue Lemoyne, P A 17043 No. 04-2059 CIVIL TERM MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR SUBSTITUTED SERVICE UNDER P:Il.R.C.P. 430(a) Plaintiff has filed a Notice of Sheriff's Sale against Defendant, Tammy Baldari, which the Sheriff has been unable to personally serve upon Defendant, Tammy Baldari. As noted in the attached Motion, Plaintiff has made a good faith attempt to ascertain Defendant's whereabouts without success. Accordingly, the Court may approve alternative means ofs'ervice. See Pa.R.C.P. 430(a). CONCLUSION F or reasons stated above and in the attached Motion, the Court should enter an order allowing Plaintiff to serve the Notice of Sheriff s Sale upon Defendant, Tammy Baldari, by posting the premises and certified mail and regular mail to the Defendant's last known address. / Respectfully submitteq,'/ // Kristina G. Murtha . , <.. GOLDBECK McCAFFERTY & McKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: Kristina G. Murtha, Esq. Attorney I.D.#61858 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2003-4 9451 Corbin Avenue Northridge, CA 91324 IN THE COURT OF COMMON PLEAS Of Cumberland County vs. No. 04-2059 CNIL TERM JONATHAN BALDARI TAMMY BALDARI 806 Hummel Avenue Lemoyne, P A 17043 CERTIFICATE OF SERVIC~ Kristina G. Murtha, Esq., does hereby certify that true and correct copies ofthe foregoing Motion for Substituted Service have been served upon the Defendant, Tammy Bald,7 this 4th day of November 2004, by first class mail, postage prepaid. I / /~/ .(/ / ~/.. /[ 1/ BY: Kristina G. Murt. ,.....Esq. C) "J 0 l.';':':,:) C"' c::::) -n .r- .'- ~-i" C) ..~;.,,:. nlF '-1 i I CJ , en 1 <...J "\ '1" '-. ,,,,:';'" -.".. ~ n~1 1',) .. -:::. c..n \..0 ~ NOV 0 9 2004 ~ GOLDBECK McCAFFERTY & McKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: Kristina G. Murtha, Esq. Attorney I.D.#61858 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2003-4 9451 Corbin Avenue Northridge, CA 91324 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY vs. JONATHAN BALDARI and TAMMY BALDARI 806 Hummel Avenue Lemoyne, P A 17043 04-2059 CNIL TERM ORDER AND NOW, this t \ day O~004, upon consideration of the Plaintiffs Motion for Substituted Service under Pa.R.c.P. 430(a) and it appearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendant, Tammy Baldari, has been unsuccessful, it IS, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Notice of Sheriffs Sale upon Defendant, Tammy Baldari, by posting a copy of the Notice upon the premises 806 Hummel Avenue, Lemoyne, P A, 17043, and Plaintiff is directed to serve the Notice of Sheriff Sale by certified and regular mail to the Defendant's last known address at 8130 Evelyn Street, Hummelstown, P A, 17046, and that all further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendant's last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendant, Tammy Baldari, by sending copies of same to Defendant's last known address by certified and regular mail and /~ ~/ by posting the premises. /~ / BytOURT: J. "- fq, Ell \~...., i/"\r r:L Lr....t..tct lvt: 0;: THe P:~C]-:c;~:;~m\?Y 'l,rOf. r,'''lll I ~ t:i.h m.l~ v P.. il I: 07 CU/:.:..: . ,_ ',:JUic,ITY F'E.~ .~~\~S\ ;_\';.\f"-.l;/-\ GOLbBECK McCAFFERTY & McKEEVER BY: JosephA. Goldbeck, Jr. . Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorne for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2003-4 9451 Corbin Avenue Northridge, CA 91324 WM-0203 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE JONATHAN BALDARI TAMMY BALDARI Mortgagor(s) and Record Owner(s) Term No. 04-2059 CIVIL TERM 806 Hummel Avenue Lemoyne, P A 17043 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (~ Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: K' j"'OrV~ ~ftL()fte." ()()/)} Personal Service by the Sheriffs Office/"'UYI.pl....u< adl:iIf'(copy of return attached). - (J Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant( s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. W. Premises was posted by C'~~f'~ r>.,.r- /competent adult (copy of return attached). r f Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ~ Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified Mail attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to t Section 4904. ?1bO 3'01 '648 b484 23?b TO: BALDARI, TAMMY 'rAMMY BALDARI 8130 EVELYN STREET HUMMELSTOWN, P A 17046 SENDER: GOLDBECK MCCAFFERTY & MCKEEVER November 18, 2004 REFERENCE: BALDARI, JONATHAN I WM-0203 12/08/04 - Cumberland PS Form 3800 June 2000 RETURN Postage RECEIPT Certified Fee SERVICE . Return Receipt Fee Restricted Delivery Total Postage & Fees US Postal Service ~\ ,:;:;) .../' ~1 I"', // - ,-- Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for International Mail ...................................-....--................--...................-- ..-............-_.......~.._-_..~..-........_~.-....~..-........,.._~.-._' AFFIX POSTAGE TO MAIL PIECE TO COVER FIRST CLASS POSTAGE, CERTIFIED FEE, RETURN RECEIPT FEE AND CHARGES FOR ANY SELECTED OPTIONAL SERVICES. 1. Detach the form 3811, Domestic return receipt by tear- ing left to right across perf. Attach to mailpiece by peeling back the adhesive stripS and affixing to front of mailpiece if space permits. Otherwise affix to back of mailpiece. 2. If you do not want the receipt postmarked, stick the article # label to the right of the return address, date receipt and retain the receipt. 3. If you want this receipt postmarked, slip the 3800 receipt between the return receipt, and the mailpiece, and slide the edge of the receipt to the gummed edge of adhesive. This will hold the receipt in place to present to your mailcenter, or post office service window. (SEE IllUSTRATION) (Form 3800) ... ...cuFlrrn...... 123.......... '11M car, _ ,.... . ..1 IU 71' .....lJ.JA......... DuldD,tlDI L11lIlSI.mlnflflrt,tlnlllflnlllr Wllz PU\II Sol~tlon', Inc, 15"SOUlh MII,lon Ihl lulltl1D Flllbrook,CAUOU'4112 - ~ (fiS ---- ....,lo~~~............ David 0, Dae Leg.l Segment "arketlng Menager W.Jz Poetal SolutIon., Inc. 1588 South Minion Rd, Suite 11Q Fellbrook, CA 92028-4112 4. Enter fees for the services requested in the appropriate spaces on the front of this receipt. 5 Save this receipt and present it if you make an inquiry. - -qj.- i---l-lIfnTrmnrrll1nr.rmHlIIITlll n -- 7160 3901 98~8 3830. 3650 . , TO: BALDARI, JONATHAN JONATHAN BALDARI 37 Drexel Place New Cumberland, P A 17070 SENDER: GOLDBECK MCCAFFERTY & MCKEEVER August 16, 2004 REFERENCE: BALDARI. JONATHAN I WM-0203 12/08/04 - Cumberland US Postal Service Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for International Mail AFFIX POSTAGE TO MAIL PIECE TO COVER FIRST CLASS POSTAGE, CERTIFIED FEE, RETURN RECEIPT FEE AND CHARGES FOR ANY SELECTED OPTIONAL SERVICES. 1. Detach the form 3811, Domestic return receipt b~ tear- ing left to right across perf. Attach to mailpiece by peeling back the adhesive strips and affixing to front of mailplece if space permits. Otherwise affix to back of mailpiece. 2. If you do not want the receipt postmarked, stick the article # label to the right of the return address, date receipt and retain the receipt. 3. If you want this receipt postmarked, slip the 3800 receipt between the return receipt, and the mailpiece, and slide the edge of the receipt to the gummed edge of adhesive. This will hold the receipt in place to present to your mal/center, or post office service Window. (SEE IllUSTRATION) (Form 3800) ... >> III 141 71. .....I~."'.IIl,......,....1 O.vldODO' hg"I$.gm.nl'hr~.t'rhgl"n'I'f W.I:Poa..'SoluUl>nl,'hC 15" SoUln M''''on Ad, S~ll. 110 hllllrl"il,C"'''D2&~112 - Y04lllFtmlNlmt 123..... 9net. 11254 cay, sa. 12345 - o ---- IIM"l.I'~"",,,,,.lIH..1 Oavid O. Doe Legal Segment Marketing Uanag.r Walz Po.tal SoluUon., Inc. 1588 South Mlulan Rd. Sulta 110 FallbJook, CA $2028.4"2 4. Enter fees for the services requested in the appropriate spaces on the front of this receipt. 5. Save this receipt and present it if you make an inquiry. i II I I 111'r f' ...... .........[ II.......'!' ......... ..............u........~.~~~.. ~ '3~'30 "?"", ~ d\ '3f()>> ofP' . 1~ . . . '1l\.,^,^i "10' ","""":.c .,.,..Op.tl\ l' p.."- '2,Uee\ ~,\ ~'Je\~ V~ \10,6 \\'3.~s'o\lt'?,' sf.t\Of.". ~f.ff.~f.t\Cf... ,^CIS-'~'J~v... c~ ,^CCl\.\l\l~v...'f'll\t. GO\"\)v,'(J ~fj()A l\.\}~\}~\ \6, I ~,^.()~fj~ 10~l\.'t\\~ \\l\.,,1)~\' 1\ CU",'oe~\at\(\ \.?/O~/O ' ."'\ set'i\Ce uS ~os"" . n\ \ot ~eCe~\'" ...,.~ . s. ~ \~,&\ Cet\\\ \~U lo-i\oeo co~elage ~ \ w,ai\ ~o \\"ISllla\"lce, I \\"I\01l\a.\iO\"la 00 ~o\ use 0..............- ......-.. .~.~~~~-~. APPlY 1""'''>- I' ',) IA.GE,.,., 'OS/AGI~ 'V "'All. PI. Cf(4!?GcS" CE!?/IPIED PEE. 'ECE /0 COVE!? I, D '0. ANy S'LEe 'eru'N "C,:"8' CU,88 l"g i'''i ~'~" I,,, '""" 38" "OOPTlONA' 8:;"'NO baCk lile !,/ I 'lcross Pe ,Domestic relur VICEs, sPace, , adh, '5 I vl' Stri rf Altach to n recOipl b , 1)11n711s e'l!],., 'Ps and a{fbrin maliplece b ,I lear. < 'I to, ,%", 'm'lo ' 10 IIO'IOf i Pee'''9 '"Ie. · lOb" ifo ","I """ I;, b,Ok 01 "",.'" """.", 'I 3''''' "'01" Ih, ,~:'<, 'lthl 01 ";';;01 Po'I""",," , ' If You"" IPI. e'Urn address d.' sltck Ihe ", I;, "lth" '~,;" , 'I, '''''.1 """ 0'", ,,;,:~,, ''''''PI, ,'::::I",,~'d, M0 ., ho~ '" ""'01 ,.110 lho Po"" Ih, ""'~, 3800 ""';" Office service In PlaCe 10 P~ ed edge Of a"c' and Slide the Window eSent l VlleSlve If' ' (Sr:r: ILL US" 0 YOUr mat!Ce . IllS W,il fI'. /?/J,/ION) nte~ or POst ~~ I J t 1 ........... I I , ! t ! I i I ,. 71bO 3~01 ~a48 b481 Sb77 TO: BALDARI, TAMMY "FAMI\jIY BALDARI 8310 Evelyn Street Harrisburg, PA 17036 SENDER: GOLDBECK MCCAFFERTY & MCKEEVER September 22, 2004 REFERENCE: BALDARI, JONATHAN I WM-0203 12/08/04 - Cumberland PS Form 3800 June 2000 RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Total Postage & Fees US Postal Service Receipt for Certified Mail No Insuranee Coverage Provided Do Not Use for International Mail AFFIX POSTAGE TO MAIL PIECE TO COVER FIRST CLASS POSTAGE, CERTIFIED FEE, RETURN RECEIPT FEE AND CHARGES FOR ANY SELECTED OPTIONAL SERVICES. 1. Detach the form 3811, Domestic return receipt by tear- ing left to right across perf. Attach to mailpiece by peeling back the adhesive strips and affixing to front of mailpiece if space permits. Otherwise affix to back of mailpiece. 2. If you do not want the receipt postmarked, stick the article # label to the right of the return address, date receipt and retain the receipt. 3. If you want this receipt postmarked, slip the 3800 receipt between the return receipt, and the mailpiece, and slide the edge of the receipt to the gummed edge of adhesive. This will hold the receipt in place to present to your mailcenter, or post office service window. (SEE IllUSTRATION) I 111 141 711 .....IJ."'...M"olllI,.J Duld-D Ou L''l"S.tm.nIM.rUtln\1'''n...r W..lzPut.,SQ1Urlll/l',llIc. 15U SOlll" MillIon Ilcl SIllI,110 F.1I'roak,C",'202l'4112 - VOUI Arm NMlt '21 MIIIn.... ,._ ClIy.-'''' !L". ",,!; o .......--- II-I,L.I....~"........, Dnld O. DQ. Le"al Segment Marketing Man.".r W.lz Poetal Solution., Inc. 1SBB Soulh MInIon Rd. Sulla"O Fallbrook, CA 92028-4112 5. Save this receipt and present it if you make an inquiry. i . ............r....lr...Tir..... ....j".1.I"1.rr.'iI't1iJ.lil'nrliH:1illnrmtlr1.U...l'i.f11WV'.: 4. Enter fees for the services requested in the appropriate spaces on the front of thiS receipt. 11bO 3901 9&4& 3&30 3b74 , . TO: BALARDI. TAMMY TAMMY BALARDI 806 Hummel Avenue Lemoyne, P A 17043 SENDER: GOLDBECK MCCAFFERTY & MCKEEVER August 16. 2004 REFERENCE: BALDARI, JONATHAN I WM-0203 12/08/04 - Cumberb.nd PS Form 3800, June 2000 RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Total Postage & Fees us Postal Service Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for International Mail AFFIX POSTAGE TO MAIL PIECE TO COVER fiRST CLASS POSTAGE, CERT1FI6O FEE, RETURN RECElltT FEE AND CHARGES FOR ANY SELECTED OPTIONAL SERVICES. 1. Detach the form 3811. Domestic return receipt b~ le;lr. Illg left to right across perf. Attach to maliplece by peeling back the adhesive strips and affixing to front of mailpleco If space permits. Otherwise affix to back of rnailplcce. 2. If you do not want the receipt postmarked. stick the article # label to the nght of the return address, date receipt and retain the receipt. 3. If you want this receipt postmarked, slip the 3800 receipt between the return receipt, and the mailpiece. and slide the edge of the receipt to the gummed edge of adhesive. This will hold the receipt in place to present to your mailcenter, or post office service window (SEE ILLUSTRATION) (Form 3800l ... Y04./It 1Qrm__ 1i3....... "214 CIJ..... 12345 ,. tt:l .41 ,., ........................ O..ldl),DQ. tt!l4l1 a'\lm,.... /h,hUIlII.'lll'lt Wabp"".tSlIlul'OIlI,IIl( all SDlOlll MluW,Il1l: Sull.1l0 Fallb'1l1l!<.CAUG1'4112 - ., o --- """"/..I,...~."jlIl"J David D. OO~ l~g.l Segment Marketing Men.,.ar W.lz Poatal Soh.ltlona, Inc. 1588 South M'..lon Ad. sun. 110 Fallbtook, ell. a"On--4112 4. Enter fees for the services requested in the appropriate spaces on the front of this receipt. 5. Save this receipt and present it if you make an inquiry. 1~bO 3~1 9&4& 3&30 3681 TO: BALDARI, JONATHAN .JONATHAN BALDARI 806 Hummel Avenue Lemoyne, P A 17043 GOLDBECK MCCAFFERTY & MCKEEVER August 16, 2004 REFERENCE: BALDARI, JONATHAN I WM:-0203 12/08/04 - Cumberland SENDER: PS Form 3800, June 2000 RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery 'OJ -~ ,:, Total Postage & Fees . " ............~' ~. . "- US Postal Service 7~ MARK S'~~j;\,. I 0 <.'1 '. I '\~" ':?"h' J" :~.' "vU1' " ; ./ _ JI ~ / <!i ,----.,' -\' ,IJ.. 1\'; ",~, ---.-- Receipt for Certified Mail No Insurance Coverage Provided 00 Not Use for International Mail AFFIX POSTAGE TO MAIL PIECE TO COVER i lRST CLASS POSTAGE, CERTIFIEO FEE, REl'URN RECEIPT FEE'AND CHARGES FOR ANY SELECTED OPTIONAL SERVICES. 1. Detach the form 3811, Domestic return mceipt by tear. ing left to right across perf. Attach to mallplece by peeling back the adhesive strips and affixing to front of mailpiece if space perrnits. Otherwise affix to back of mailplece. 2. If you do not want the receipt postmarked, stick the article # label to the right of the return address. date receipt and retain the receipt. 3. If you want this receipt postmarked, slip the 3800 receipt between the return receipt, and the mailpiece, and slide the edge of the receipt to the gummed edge of adhesive. This will hold the receipt in place to present to your mallcenter, or post office service window. (SEE ILLUSTRATION) (Form 3800) .. Your FIrm .... 123 MIan SINtt. 11214 .,.,.-'- . "1 "1 7It ..N,I.&..I,.lIl.'N'&..I DnlCtD 1l(14 ~f,.IS'lIlt\tontlil'(.'!I~M.""... WeIr Pesllllh,lklIIOI'f'. hl~ Hll&Soulh",uIo!lR~ 5"il.110 hl1tlroo~.C"f20:l"1l2: - ~ o --- ll.-I.w.........lIIlo.d David D. Doe legBI Segment Marketing Manager Wah: Postal Solutions, Inc. 1588 South Minion Rd. Suite 110 Fallbfook, CA 82023.4112 4. 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CiS" ~ ::II lE a~ g~~ ~ ~~=a:Sl.lll ~ lil!!l ~ ~ 1\1'0 :I: -'a. ~- = :J: OQ) _ S' ~ iif 5. <1>'!P 1Il cC3= '" <1>:> <C ~~ _C: ffi~ o c: =0<1> (')en o~ o~ ","0 lE(') "'"en lE(') "'"en lE:I: "'";0 lEo "'";0 lE ;0, , NOV 28 2004 5:48PM HP LASERJET 3200 p. 1 IN TIIE COURT OF COMMON PLEAS, CUMBERLAND COUNTY DEUTSCHE BANK NATIONAL TRUST CO. JONATHAN BALDARI & TAMMV BALDARI (Petitioner) Plaintiff VS. (Respondent) Defendant CASE and/or OOCKET: 04-2059 I Declare that I am a Pennsylvania State Deputy Constable and/or Process Server, in and for the County of Montgomery, that [ am not a party to this action, not an employee of a party to this action, or an attorney to the action, and that within the boundaries of the state were service was effected, I was authorized by law to perfonn the said service. SERVICE SERVICE UPON: TAMMY BALDARI Address: 806 HUMMEL AVE. LEMOYNE, PA 17043 On: ldz.1--('''' At: -;',;1> p /'I' Description: Approximate Age: :....-Heigbt _Weight: _Race: _Sex: _Hair:_ With the documents: NOTICE OF SHERIFF'S SALE OF REAL PROPERTY MANNER OF SERVICE By handing a copy to: o I.) Defendant(s) personally served 02,) Adult family member with whom said Defendant(s) reside. Name: Relationship: 03.) Aduh in cbarge of defendants residence. Name: Relationship: "l!-4.) Posted Property 05.) Agent or person in charge of Place of Business. Name: Title: Comlllents: hovtS-< ({ V Ii,..( u..:t, pu~U ({ '11 ' NO SERVICE Defendant was not served because: _Moved _Unknown No Answer _Vacant Other: Service was attempted on the following dates and times: 1.) 2.) 3.) Date: Time: Date: Time: Date: SERVER INFORMATION. Time: UNIVERSAL LAWYERS' SERVICE 93 EAST MAIN ST, BAY SHORE, NY 11706 631.666,6168 ;/ZIL~ TABLE I DEPUTY I PROCESS SERVER I J C; Q-O ~ ,-# NOV 0 ~ 2004 ? GOLDBECK McCAFFERTY & McKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: Kristina G. Murtha, Esq. Attorney I.D.#61858 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2003-4 9451 Corbin Avenue Northridge, CA 91324 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY vs. JONATHAN BALDARI and TAMMY BALDARI 806 Hummel Avenue Lemoyne, P A 17043 04-2059 CIVIL TERM AND NOW, this } j ORD~ day of 0 2004, upon consideration of the Plaintiffs Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendant, Tammy Baldari, has been unsuccessful, it IS, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Notice of Sheriff's Sale upOlilbefendant, Tammy Baldari, by posting a copy of the Notice upon the prei1'lis.esiai~ Uummel Avenue, Lem.oyne, P A, 1704Jl and Plaintiff is directed to serve the Notice of Sheriff Sale by certified and regular mail to the Defendant's last known address at 8130 Evelyn Street, Hummelstown, P A, 17046, and that all further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendant's last lmown address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendant, Tammy , . Baldari, by sending copies of same to Defendant's last known address by certified and regular mail and by posting the premises. BY THE COURT: From: 11/03/2004 15:07 #106 P.002/002 AMENDED RETURN Deutsche Bank National Trust Company As Trustee for Long Beach Mortaage Loan Trust 2003-4 VS Jonathan Baldari and Tammy Baldari In The Court of Common Pleas of Cumberland County, pennsylvania Writ No. 2004-2059 Civil Term Shannon Shertzer, Deputy Sheriff, who being duly sworn according to law. states that on September 14,2004 at 7:55 o'clock PM, he served a true copy of the within Real Estate Writ, Notice ofSheri:frs Sale and. Description, in the above entitled action. upon the within named defendant, to wit: Jonathan Baldari, by making known Wlto Ruth Smith-Bald.ari. step mother of Jonathan Baldari. at 37 Drexel Place, New Cumberland, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Ron Hoover, Deputy Sheriff, who being duly swom according to law, states that on October 07,2004 at 2:01 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action. upon the property of Jonathan Baldari and Tammy Baldari located at 806 Hummel Ave., Lemoyne, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who beiDi duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Jonathan Baldari, by regular mail to his last known address of37 Drexel Place, New Cumberland, PA 17070. Thislette:r was mailed under the date of October 06, 2004 and never returned to the Sheriffs Office. ~ This _ day of ~~ R. Thomas Kline, Sheriff BY JtS d,~ J~h Real Estate Deputy Sworn and subscribed to before me 2004, A.D. Prothonotary GoUibeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg, 111 S.lndependence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2003-4 9451 Corbin Avenue Northridge, CA 91324 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW JONATHAN BALDARI TAMMY BALDARI (Mortgagor(s) and Record Owner(s)) 806 Hummel Avenue Lemoyne, P A 17043 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No, 04-2059 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2003-4, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., 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: 806 Hummel Avenue Lemoyne, P A 17043 1 ,Name and address ofOwner(s) or Reputed Owner(s): JONATHAN BALDARI 37 Drexel Place New Cumberland, P A 17070 TAMMY BALDARI 831 Evelyn Street Harrisburg, PA 17036 2, Name and address of Defendant(s) in the judgment: JONATHAN BALDARI 37 Drexel Place New Cumberland, P A 17070 TAMMY BALDARI 831 Evelyn Street Harrisburg, P A 17036 3, Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, P A 17013 PA-DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg, - Room 432 P.O, Box 2675 Harrisburg, PA 17105-2675 4, Name and address of the last recorded holder of every mortgage of record: 5, Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6, Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale, 7, Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale, TENANTS/OCCUP ANTS 806 Hummel Avenue Lemoyne, P A 17043 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief, I understand that false statements herein are made subject to the penalties of 18 Pa, C,S, Section 4904 relating to unsworn falsification to authorities, DATED: August 16.2004 r c..., ,) / . ._~ .~ .... " ,,-,) ,"~-~') ..::'\ () - l"f -,-I ~r' r (1 C) r1 ( ) I c;:; :':::/3 I, ., -~ I ( , "11 ..~ c") In -'r' (;'? C) en , I ,-< " COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS; DLjI-, 0<051 I, Robert p, Ziegler, Recorder of Deeds in and for said County and State do hereby certi that the Sheriff's Deed in which Long Beach Mtg Loan Trust 2003-4 Tr is the grantee the same hav' g been sold to said grantee on the 5th day of Jan A.D" 2005, under and by virtue of a writ Execution i ued on the 18th day of Aug, A.D., 2004, out of the Court of Common Pleas of said County as of Civil erm, 2004 Number 2059, at the suit of Long Beach Mtg Loan Trust 2003-4 Tr against Jonathan Bal ari & Tammy is duly recorded in Sheriff's Deed Book No, 267, Page 1371. IN TESTIMONY WHEREOF, I have hereunto s t my hand seal of said office this 0' 77'1 day of , A,D20ol"' My r of Deeds CounIY. CIrtIIlI, Pl\ Fi ~al_2OGI C"" AMENDED RETURN Deutsche Bank National Trust Company As Trustee for Long Beach Mortgage Loan Trust 2003-4 VS Jonathan Baldari and Tammy Baldari In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No, 2004-2059 Civil Term Shannon Shertzer, Deputy Sheriff, who being duly sworn according to law, states that on September 14,2004 at 7:55 o'clock PM, he served a true copy ofthe within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Jonathan Baldari, by making known unto Ruth Smith-Baldari, step mother of Jonathan Baldari, at 37 Drexel Place, New Cumberland, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that on October 07, 2004 at 2:01 o'clock P.M" he posted a true copy of the within Real Esta Writ, Notice, Poster and Description, in the above entitled action, upon the property of Jonathan Baldari and Tammy Baldari located at 806 Hummel Ave., Lemoyne, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Jonathan Baldari, by regular mail to his last known address of 37 Drexel Place, New Cumberland, PAl 7070. This letter was mailed under the date of October 06, 2004 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on January 05, 2005 at 10:00 o'clock A.M. He sold the same fo the sum of$1.00 to Attorney Joseph Goldbeck for Deutsche Bank National Trust Company, as Trustee for Long Beach Mortgage Loan Trust 2003-4. It being the highe t bid and best price received for the same, Deutsche Bank National Trust Company, as Trustee for Long Beach Mortgage Loan Trust 2003-4 of 9451 Corbin Avenue, Northridge, CA 91324, being the buyer in this execution, paid to SheriffR. Thomas Kine the sum of $697.48, Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer $30,00 14.49 15.00 15.00 30.00 10,00 Law Library Prothonotary Mileage Levy Postpone Sale Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed $ .50 1.00 24.42 15.00 20,00 30.00 204.95 232.51 30.42 25.00 40.50 738,79 Sworn and subscribed to before me p~~ ~' /l This ;.Ii,,-daYOf~Ad 'j ,) R. Thomas Kline, Sheriff 2005, A.D. ~-~-' a nuu.'-'--(Jfii') Svvw~ p(ot onotary BY \. C!cU ~. . , Real Estate eputy I ~- vl-- JtJ JUL'" . 12,1\) " J Li'b~ 'ii /';Q911 t Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney 1.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2003-4 9451 Corbin Avenue Northridge, CA 91324 IN THE COURT OF COMMO PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW JONATHAN BALDARI TAMMY BALDARI (Mortgagor(s) and Record Owner(s)) 806 Hummel Avenue Lemoyne, P A 17043 ACTION OF MORTGAGE FORE LOSURE Defendant( s) No. 04-2059 CIVIL TER AFFIDAVIT PURSUANT TO RULE 3129 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORT AGE LOAN TRUST 2003-4, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as oft e date the praecipe for the writ of execution was filed the following infonnation concerning the real property located at: 806 Hummel Avenue Lemoyne, PA 17043 I.Name and address of Owner(s) or Reputed Owner(s): JONATHAN BALDARI 37 Drexel Place New Cumberland, P A 17070 TAMMY BALDARI 831 Evelyn Street Harrisburg, P A 17036 2. Name and address of Defendant(s) in the judgment: JONATHAN BALDARI 37 Drexel Place New Cumberland, P A 17070 TAMMY BALDARI 831 Evelyn Street Harrisburg, P A 17036 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to b sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle. P A 17013 P A DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcem Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and wh se interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in t e property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the pro rty which may be affected by the sale. TENANTS/OCCUP ANTS 806 Hummel Avenue Lemoyne, P A 17043 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal know1e e or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. clion 4904 relating to unsworn falsification to authorities. DATED: August 16,2004 , 04-2059 CIVIL T RM . GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, JT. Attorney 1.0.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2003-4 9451 Corbin Avenue Northridge, CA 91324 IN THE COURT OF COMMON PLE S of Cumberland County Plaintiff CIVIL ACTION - LAW vs. JONATHAN BALDARI TAMMY BALDARI Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 806 Hummel Avenue Lemoyne, P A 17043 Term No. 04-2059 CIVIL TERM Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT, THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT, ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: BALDAR1. JONATHAN .JONATHAN BALDARI 37 Drexel Place New Cumberland, P A 17070 Your house at 806 Hummel Avenue, Lemoyne, PA 17043 is scheduled \0 be sold at Sheriffs Sa on Wednesday, December 08, 2004, at 10:00 AM, in Commissioners Hearing Rrn 2nd FL Courthouse to enforce the court judgment of$95,113.84 obtained by DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2003-4 against you. 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: t 04-2059 CIVIL T RM I. The sale will be cancelled if you pay to DEUTSCHE BANK NA nONAL TRUST COMP A Y, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2003-4, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgm t, 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. Yau may need an attorney to assert your rights, The sooner you contact one, the more chance au will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGH S EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fi d out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadegu e 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 fi d out if this has happened, you may call the Sheriff 01'717-240-6390. 4. If the amount due from the Buyer is not paid to the SheritT, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and th 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 thirty (30) days from the date of e Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are file with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 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 T FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 CUMBERLAND COUNTY BAR ASSOCIA nON 2 Liberty Avenue Carlisle, PA 17013 AtL THAT cl~rA!N ~ot of grouna s~tua~e in the So~ouqh of Lemoyne, Cgmb.~land COUqty, Pennsylvania, Ba1~ lot ~elng bounded and d"cribed .e follow', BBG%M~ING at a pelot on tbe SDuthe~n line of HUMmel Avenue a~ che diatanc8 0: 40 tee~ westwardly, measured from the 9outb~s.t corne~ o~ Ru~ol Avenue ond Eighth 8t~e't formerly blactberty Alley. thence in soutberlv d!rect1on, along the w..Cero line of Lot No. ~2 Block .~.. on tbe plan of lOCI hereinafter mentioned, ~SD feet to a point on ~h. nart~.rn 11na of ~eaeh Alley; 'thence'!n a westarly direction. alo09 ~be norcheto line of .aid Peach Alley, 11-1/Z feet. mQte at less, to a point; thence in a oortberly direction, along a line ~unDioq through &be oeQeer of thl pa~tit1on wall of ~he do~le ho~.. erec~.d ~n part on .aid Lot, ~50 feee to a po1nt on the Soutblrn line Of H~.l ^venuI' th.n~e in an .aste~ly ditection i~oaq the soutnern 11ne af HU~el Avenue. 17-1/2 feet. more Of 108S. to . ~oint. the place Of BEGI.NXNG. '.' . . . . . . . WRIT OF EXECUTION and/of ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-2059 Civil CIVIL ACTION - LA TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMP Y, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2003-4, Plaintiff (s) From JONATHAN BALDARI AND TAMMY BALDARI (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 om paying any debt to or for the account of the defendant (s) and from delivering any property of the defe ant (s) or otherwise disposing thereof; (3) Ifproperty 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 himlher that he/she has been added s a garnishee and is enjoined as above stated. Amount Due $95,113,84 Interest FROM 10/l/03 TO 8/16/04 AT 9,8000% LL $,50 Atty's Comm % Atty Paid $275,68 Plaintiff Paid Date: AUGUST 18, 2004 Due Prothy $1.00 Other Costs CURTIS R, LONG (Seal) B: Deputy REQUESTING PARTY: Name JOSEPH A, GOLDBECK, JR., ESQUIRE Address: SUITE 500 - THE BOURSE BLDG, 111 S, INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 Real Estate Sale #32 On September 0 l, 2004 the Sherifflevied upon the defendant's interest in the real property situated in Lemoyne Borough, Cumberland County, P A Known and numbered as 806 Hummel Ave" Lemoyne, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein, Date: September 0 l, 2004 By: "hie! S~ Real Estafe Deputy ~ ~~ ,io?&, '-~ 'I. ~ ",,', \ .~ , ,:-' r.,".,:JO 1,),.:)11> [. "7 ", o.:\~ 'C)'I'" " _,-oJ '.J , . ,~. ' " ..; .\"'~ ;1':: REAL ESTATE SALE No. 32 I Writ No. 2004-2059 I D8~~NatIOnal. . '. I' Trust Company, as nustee for , Long Beach =geLoan 1i'ust i . . ,Vs' : J8IilBthan Baldarl and . 1llmmy BaldarI . AUy: Joseph Go.Idbeck' DESCRIPTION /i' ...,.........:: .':........:...,;.:,.'.).:,.:.....:.....,...'.:. .,".;',,0' AIL '!HAT CERI'AIN Iut of &fl!und silDaIe in 1be llorough of /:.emoylre, CwJllxoJland Couitty, PennsylvaniJl, said Iut bring' bimnded and described as follows: BEGINNING at.. point on 1be Southem line of =:=a:.~::m~:Ost~ of HlI!IllJlcl Avenue JIlld Eighth Stteel fotlDel'!y Bl>cldleny Alley; 1beIIl:e in soo1berly direction, mong !be western line of Lot No. 12 Block '1!"on the plan of lots bfreinafter mentioned, 150 feet to apoint on !be nonhem line ofPeachAlley; thence in a weSlOt!y direction, along !be nortbem line of said Peach Alley. 17 _ feet, more orJ.kss, to a ]lOint, thence in a nOIlbedy directiOn, mong a line running throogb 1be center <Jf 1be parlition wall of 1be double honse erected in part on said Lot, 150 feet to a point on 1be Southem line of Hummel Avenue; thence in an easterly direction mong 1be Soutbem line of Hummel Avenue, 17 _ feet, more or less, to a point, 1bePlaceofBEGINNlNG. REAL ESTATE SALE NO, 32 Writ No, 2004-2059 Civil Deutsche Bank National Trust Company, as Trustee for Long Beach Mortgage Loan Trust 2003-4 vs, Jonathan Baldari and Tammy Baldari Atty,: Joseph Goldbeck ALL THAT CERTAIN lot of ground situate in the Borough of Lemoyne, Cumberland County, Pennsylvania, said lot being bounded and de- scribed as follows: BEGINNING at a point on the Southern line of Hummel Avenue at the distance of 40 feet westwardly, measured from the southwest cor- ner of Hummel Avenue and Eighth Street formerly Blackberry Alley; thence in southerly direction, along the western line of Lot No, 12 Block "E" on the plan of lots hereinafter mentioned, 150 feet to a point on the northern line of Peach Alley: thence in a westerly direction, along the northern line of said Peach AI- ley, 17-1/2 feet, more or less, to a point; thence in a northerly direc- tion. along a line running through the center of the partition wall of the double house erected in part on said Lot, 150 feet to a point on the Southern line of Hummel Avenue; thence in an easterly direction along the Southern line of Hummel Ave- nue, 17-1/2 feet, more or loss, to a point, the Place of BEGINNING, .