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HomeMy WebLinkAbout09-2518Phelan 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 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 203924 THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RZ3 1100 VIRGINIA DRIVE P.O. BOX 8300 FORT WASHINGTON, PA 19034 Plaintiff V. BRINKLEY L. TUCKER, JR REBEKAH L. LAUGHMAN 805 FRONT STREET, NEW CUMBERLAND, PA 17070-2032 Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. ;_5? Gx??tel? CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 203924 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 #: 203924 Plaintiff is THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RZ3 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: BRINKLEY L. TUCKER, JR REBEKAH L. LAUGHMAN 805 FRONT STREET, NEW CUMBERLAND, PA 17070-2032 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 07/18/2005 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A NOMINEE FOR HOMECOMINGS FINANCIAL NETWORK, INC. which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1916, Page 1192. 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. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 01/01/2009 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 File #: 203924 by written notice sent to Mortgagor, the entire principal balance and all interest due 6. thereon are collectible forthwith. The following amounts are due on the mortgage: Principal Balance $113,210.15 Interest $3,491.16 12/01/2008 through 04/21/2009 Attorney's Fees $1,300.00 Cumulative Late Charges $169.52 07/18/2005 to 04/21/2009 Cost of Suit and Title Search 750.00 Subtotal $118,920.83 Escrow Credit $0.00 Deficit $877.62 Subtotal 877.62 TOTAL $119,798.45 7. 8 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 #: 203924 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. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $119,798.45, together with interest from 04/21/2009 at the rate of $24.76 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: 1,1rV11L1 L en T. Phe , Esquire ancis nan, 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 Joshua I. Goldman, Esquire i o t 2-r S7( q-7 Attorneys for Plaintiff File #: 203924 LEGAL DESCRIPTION ALL THAT CERTAIN lot or parcel of land situate in the Borough of New Cumberland, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the Northern line of Front Street on the dividing line between Lots Nos. 2 and 3, Block'B', on the hereinafter mentioned Plan of Lots, thence in a Northerly direction along said dividing line one hundred (100) feet to a twenty feet alley; thence in a Westerly direction along the Southern line of said alley fifty (50) feet to a point on the dividing line between Lots Nos. 3 and 4, Block'B', on said Plan of Lots; thence in a Southerly direction along said last mentioned dividing line one hundred (100) feet to Front Street; thence in an Easterly direction along the Northern line of Front Street fifty (50) feet to the point or place of BEGINNING. BEING Lot No. 3, Block 'B' as shown on Plan No. 5, Rosemont Addition to the Borough New Cumberland, said Plan being recorded in the Cumberland County Recorder's Office in Plan Book 3, at Page 64. PROPERTY BEING; 805 FRONT STREET PARCEL# 25-25-0006-432 File M 203924 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. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. 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. Atto ey for lainriff )PSH14 T. 6w-bmA+"' 1Q DATE: 1-1-- Z 1-09 File #: 203924 4D t 7' Ff ?,r;, rr} 12 g. sd p? Q?y CC," 7 9 8' 7 ,ems aa- vo? ?- Sheriffs Office of Cumberland County R Thomas Kline 0V of Cuint,, Edward L Schorpp Sheriff Solicitor Ronny R AndersonJody S Smith Chief Deputy OFFICE V '"E s,tERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/27/2009 01:09 PM - R. Thomas Kline, Sheriff, who being duly swom according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Brinkley L. Tucker, Jr., but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Brinkley L. Tucker, Jr.. Per the New Cumberland Postmaster the defendants mail has been forwarded to 5326 Belgrado Drive Canal Winchester, Ohio 43110. 04/27/2009 R. Thomas Kline, Sheriff, who being duly swom according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Rebekah L. Luaghman, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Rebekah L. Luaghman. Per the New Cumberland Postmaster the defendants mail has been forwarded to 5326 Belgrado Drive Canal Winchester, Ohio 43110. SHERIFF COST: $70.20 April 29, 2009 2009-2518 The Bank of New York Mellon Trust Co. VS Brinkley L. Tucker, Jr. SO ANSWERS, _ R THOMAS KLINE, SHERIFF c Q CJ -r ly ». -c 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 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RZ3 Plaintiff VS. BRINKLEY L. TUCKER, JR REBEKAH L. LAUGHMAN Defendant(s) ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION : NO. 09-2518-CIVIL-TERM : CUMBERLAND COUNTY PHS #: 203924 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. Phelan Hallinan & Schmieg, LLP Attorney for Pla' tiff 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 Joshua I. Goldman, Esquire Courtenay R. Dunn, Esquire Date: 6-3-09 PHS #: 203924 VERIFICATION Jeffrey Stephan ISO Limited Signing MCff hereby states that he/she is of HOMECOMINGS FINANCIAL, LLC, servicing agent for Plaintiff, THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RZ3, 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 unsworn falsification to authorities. N Jeffrey Stephan DATE: I Title: Limited Signing Officer Company: HOMECOMINGS FINANCIAL, LLC Loan:7424610764 File #: 203924 Tucker 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 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RZ3 Plaintiff VS. BRINKLEY L. TUCKER, JR REBEKAH L. LAUGHMAN Defendant(s) ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION : NO. 09-2518-CIVIL-TERM : CUMBERLAND COUNTY CERTIFICATE OF SERVICE I hereby certify that a true 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: . • BRINKLEY L. TUCKER, JR 805 FRONT STREET, NEW CUMBERLAND, PA 17070-2032 REBEKAH L. LAUGHMAN 805 FRONT STREET, NEW CUMBERLAND, PA 17070-2032 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 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 Joshua I. Goldman, Esquire Courtenay R. Dunn, Esquire Date: 6-3-09 fit. "?c E OF THr: F n s I' Qy 2009 JUN -S PM 3= 5 4 CUtP i a=+V'Y INA AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL PHS # 203924 ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RZ3 DEFENDANT SERVICE TEAM/ BRINKLEY L. TUCKER, JR COURT TERM: REBEKAH L. LAUGHMAN COURT NO.: SERVE BRINKLEY L. TUCKER, JR AT: TYPE OF ACTION 5326 BELGRADO DRIVE XX Mortgage Foreclosure CANAL WINCHESTER, OH 43110 XX Civil Action SERVED Served and made known to L ?W J LE Y Defendant on the Jjday of IWY , 200 9 , at , o'clock M., at u e j S??L Belgr, 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: / Description: Age 3 Height S ? Weight ..? Race ASex 11V Other / I, 1 24/,F,nan? a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Foreclosure Complaint 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 j? ? vv before me this day ` A. aY P(ie . Q.... N. of , 2 009- LISA M. CANTER Notary Public, State of Ohio Not }?,_„ .,?• .' `O : My Commission Expiries Od 30,1011 ?•.• ,• . Recorded in Fairfield County 'SERVED On the day of , 200, at o'clock . M., Defendant NOT FOUND because: Vacant _ Bad Address _ Moved No Answer Service Refused Other: Sworn to and subscribed before me this day By: Does Not Reside (Not Vacant) ,T-1-2 Flo f Notary: ATTORNEY FOR PLAINTIFF Lawrence T. Phelan, Esq., Id. No. 32227 FILE?-0 7RCE OF THE pPTI-11HOMOTARY 2009 JUN -8 PM 4: {7 CUIt N.r _ . <i CI LINTY PEA IvSYLVANA AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RZ3 DEFENDANT BRINKLEY L. TUCKER, JR REBEKAH L. LAUGHMAN PHS # 203924 SERVICE TEAM/ N X P COURT TERM: COURT NO.: Q 9 -a5/ Ci ?i L ,?74'zX-4 SERVE REBEKAH L. LAUGHMAN AT: TYPE OF ACTION 5326 BELGRADO DRIVE XX Mortgage Foreclosure CANAL WINCHESTER, OH 43110 XX Civil Action SERVED Served and made known to ba k& -Defeunddant anto oc ? ??';n the 1 f day of 10A,10", 200 at o'clock g? M., at of 3t 1. 73e t• Y?r, 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: Description: Age Height Weight /S3- Race &/ Sex /1"' Other I, &b raa-4,-e ?K a competent adult, being duly sworn according to law, depose and state that I personally handed a true and coggrA dopy of the Foreclosure Complaint in the manner as set forth herein, issued in the captioned 4ate and at the address indicated above. Sworn to and subscribed Nalyu, before me this day "" ' *= iyly Comm to of Ohio sc?j ? ?}nc isaion Expires Oct 30 2011 of VOCIM, 200PL. 9j? w? .....?.: RecOrded in Fairriekl County to () - 191 fl, No On the day of because: _ Vacant _ Bad Address No Answer Service Refused Other: Sworn to and subscribed before me this day of I . By: Notary: NOT SERVED 200, at o'clock _. M., Defendant NOT FOUND Moved _ Does Not Reside (Not Vacant) ATTORNEY FOR PLAINTIFF Lawrence T. Phelan, Esq., Id. No. 32227 BLED-OMF CE OF THE PROTHONOTARY 2009 JUN -8 PM 4: 17 PEr NSYW` NIA 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 Attorney for Plaintiff Philadelphia, PA 19103 215-563-7000 THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RZ3 . CUMBERLAND COUNTY . COURT OF COMMON PLEAS . CIVIL DIVISION : No. 09-2518-CIVIL-TERM VS. BRINKLEY L. TUCKER, JR REBEKAH L. LAUGHMAN PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND NSSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against BRINKLEY L. TUCKER, JR and REBEKAH L. LAUGHMAN, 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 $119,798.45 Interest - 04/22/2009 to 06/26/2009 $1,634.16 TOTAL $121,432.61 I hereby certify that (1) the Defendants' last known a r ss is 5326 BELGRADO DRIVE CANAL WINCHESTER, OH 43110, and (2? that t' e has been given in accordance with Rule 237.1, copy attached. '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 Jere R. Davey, Esquire Lauren R. Tabas, EsquirQ33 Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Joshua I. Goldman, Esquire Courtenay R. Dunn, Esquire Andrew C. Bramblett, Esquire Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: fie' J-q' Q PHS # 203924 PROTHONOTARY THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RZ3 Plaintiff V. BRINKLEY L. TUCKER, JR REBEKAH L. LAUGHMAN Defendant(s) TO: BRINKLEY L. TUCKER, JR 5326 BELGRADO DRIVE CANAL WINCHESTER, OH 43110 DATE OF NOTICE: June 9, 2009 COURT OF COMMON PLEAS CIVIL DIVISON NO. 09-2518-CIVIL-TERM CUMBERLAND COUNTY 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. M"ORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. PHS # 203924 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. Office of the Prothonotary Cumberland County Bar Association Cumberland County Courthouse 32 South Bedford Street 1 Courthouse Square Carlisle, PA 17013 Carlisle, PA 17013 17) 249-3166 (717) 240-6195 A By: Lawrencg TPTielan, 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 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 203924 Y THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RZ3 Plaintiff V. BRINKLEY L. TUCKER, JR REBEKAH L. LAUGHMAN Defendant(s) TO: REBEKAH L. LAUGHMAN 5326 BELGRADO DRIVE CANAL WINCHESTER, OH 43110 DATE OF NOTICE: June 9, 2009 COURT OF COMMON PLEAS CIVIL DIVISON NO. 09-2518-CIVIL-TERM CUMBERLAND COUNTY 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. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. PHS # 203924 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. Office of the Prothonotary Cumberland County Bar Association Cumberland County Courthouse 32 South Bedford Street 1 Courthouse Square lisle, PA 17013 Carlisle, PA 17013 7)249-3166 (717) 240-6195 y 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 Courtenay R. Dunn, Esq., Id. No. 206779 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 203924 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 THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RZ3 Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 09-2518-CIVIL-TERM VS. BRINKLEY L. TUCKER, JR REBEKAH L. LAUGHMAN VERIFICATION OF NON-MILITARY SERVICE The undersigned attorney, hereby verifies that he/she is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she 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 BRINKLEY L. TUCKER, JR is over 18 years of age and resides at 805 FRONT STREET, NEW CUMBERLAND, PA 17070-2032. (c) that defendant REBEKAH L. LAUGHMAN is over 18 years of age and resides at 805 FRONT STREET, NEW CUMBERLAND, PA 17070-2032. This statement is made subject to the penalt's of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. / Jrawrence T. Phelan, Esquire Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jee me R. Davey, Esquire ,yn3? ``?9 '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 Joshua I. Goldman, Esquire Courtenay R. Dunn, Esquire Andrew C. Bramblett, Esquire Attorney for Plaintiff FILED-i;FFi"'E' OF THE P,,3Ta i N,.)TAFY 2049 JUN 29 Ph 12; 4 9 CUI+?;?,,r ;.1`•`1:1 .:t?.?,,?1V11 t'E115YLVANU? R ?a7 31 Noh,e-s m cL,1 ek (Rule of Civil Procedure No. 236) - Revised THE BANK OF NEW YORK MELLON : CUMBERLAND COUNTY TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF G -a-9 - 69 NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP CIVIL DIVISION 2005RZ3 VS. BRINKLEY L. TUCKER, JR REBEKAH L. LAUGHMAN 805 FRONT STREET COURT OF COMMON PLEAS : No. 09-2518-CIVIL-TERM NEW CUMBERLAND, PA 17070-2032 Notice is given that a Judgment in the above captioned matter has been entered against you on By: If you have any questions concerning his/?datter please contact- -44£?TY '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 Jen?rte R. Davey, Esquire auren R. Tabas, Esquir Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Joshua I. Goldman, Esquire Courtenay R. Dunn, Esquire Andrew C. Bramblett, Esquire Attorney or Party Filing 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 "THIS 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 ONLYENFORCEMENT OFA LIENAGAINST PROPERTY. ** .~ . JUL 14 2010 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA ~ ~ ~ , G o ; , --~~ THE BANK OF NEW YORK ~;.. ~ ~ `," ~ ~ ~? MELLON TRUST COMPANY, ~'- ~ - tc NATIONAL ASSOCIATION FKA -r= ' ~ ~ _ ~ } THE BANK OF NEW YORK TRUST COMPANY, N.A. AS $''"- . ~= ~ ~ ~ ~' SUCCESSOR TO JPMORGAN -- '~ c-- `=~" -~+ CHASE BANK N.A. AS ~~ :..~ ~~-' .x,. -~' -< TRUSTEE FOR RAMP 2005RZ3 c.:: Civil Division vs. No.09-2518-CIVIL-TERM BRINKLEY L. TUCKER, JR. : REBEKAH L. LAUGHMAN ORDER AND NOW, this ~~ day of 2010, upon consideration of Plaintiff s Motion for Service Pursuant to Special Order of Court, it is hereby ORDERED and DECREED that said Motion is GRANTED. It is further ORDERED and DECREED that Plaintiff may obtain service of the Notice of Sale and all future pleadings on Defendant(s), BRINKLEY L. TUCKER, JR. and REBEKAH L. LAUGHMAN, by: 1. Posting of the premises: 805 FRONT STREET, NEW CUMBERLAND, PA 17070- 2032. 2. First class mail to BRINKLEY L. TUCKER, JR. and REBEKAH L. LAUGHMAN at the last known address, 5326 BELGRADO DRIVE, CANAL WINCHESTER, OH 43110, and the mortgaged premises located at 805 FRONT STREET, NEW CUMBERLAND, PA 17070-2032; and 3. Certified mail to BRINKLEY L. TUCKER, JR. and REBEKAH L. LAUGHMAN at the last known address, 5326 BELGRADO DRIVE, CANAL WINCHESTER, OH 43110 and the mortgaged premises located at 805 FRONT STREET, NEW CUMBERLAND, PA 17070-2032; and 4. Publication in accordance with PA. R.C.P. 430. B 203924 ~ . J, 'C~p;cs rti.a.`led 7~is'~/r~ 2 ~L ~, z Cc: BRINKLEY L. TUCKER, JR. and REBEKAH L. LAUGHMAN 805 FRONT STREET NEW CUMBERLAND, PA 17070-2032 203924 • 3 Ia IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RZ3 Plaintiff, v. BRINKLEY L. TUCKER, JR REBEKAH L. LAUGHMAN Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS ~ ~_ ~ - CIVIL DIVISION ~ ~ -~~-, c._. ~ -_~ No. 09-2518-CIVIL-TERMS ~ ~~~ c' ~ ~ r-. ~ ~ , +. :_ ..,.. 3 _ ,_ .- ~ -- - -y~ r `, ~ 4r C= 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 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is t~ched hereto Exhi~t "A". rence T. Phelan, E ., Id. No. 32227 ancis S. Hallinan, E ., Id. No. 62695 aniel G. Schmieg, Esq., Id. No. 62205 ^ ichele 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 Attorney for Plaintiff Date: Q' \~ IMPORTANT TICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the alaintiff 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 # 203924 1 i ,~ 1iU i2 ~\ . F C C C C r 0 I' ~' 0 a° ~~ K ~~ c ~ ~ ~l ,~'~ a a ~° ~ ;~ ~~:~~_ ~~~a F fhb °'~a°> z¢o SdS ,~ S ~ ~ z so Ls L ~ooarz woa~ arrow ~8 °~ ~ ~ ~~ OLOZ S02idV 9SZLLZb000 ' WL ZO r ' ' ~ ~~ ~ a• ~ ... ~ a . ~ '~~ ~~ 8 ~ ~ ~ ~ .k. ~ H ~ V 0 ~ 0 ' ~ „ ~~ 8 N ~ '~ e , ffi N o ~~ $, 9 ~' a ~ ~ ~ M ~ ~ a ~ xx h ~~'F~ F `' ~ ty 4 ~ a °~ w ~~ O o N ~ ~ w o ~ ~ ° ~,~' v u~d A. o ~ _ ~ ~i rs , ~ a a ~ ~ "= p~ U p, W ° ~'v~i ° i~ °° o ~~wvN ~ c~a; ~ a L 7 V W o c>o ~V ~.,~r °3 ~ .~w0~a i ~ ~ A ~ i `.` ~.~~,C ~~o~ py O ~ ~ d ~"~ Gr] S ~ O . _d ~.~ O Gl :~ ., Yom. '~,:Q ~'1+~1 ~ ~ ._. z ~ ~oo~ g~~, ~ ~lu..,:t~ o ~c uA~o;~ a ~.d. g~ ~v~r~~..a: ~~ g~ ~~~wNt~ ~ ~ ~ ~ z* ~~ ~ ~ ~ ~ o ~ z H s o ~s ~ 3ao~diz woa~ a~rory , o~oz cz inr sszcczbooo • ' w oZ~~ZQ ~ WL Z o r r senor •~ua '~~- C ~ ~;. ,~ o ~~ ,'P ~d ~~1~ Q z-- is ~~ '_ ~,~ i:~~: w Q O O N a w as w a w a O~ b d d o U ~ w o ~ o, a w ~~ ~ ~ ~~ > N a~i ,~.; ~ w ~~, ~ w ~' a aaN ~ ~ ~o, ~Z~oZ~~>~ z d ~ ~~°"•`vW~aW~wFxCx7 '~aaci•~'°~w~~aazx x~ ~ ~ °v`W~3u~xw~ ~--~ ~~ ~pgodpg0°o~oF a~Ooazrs:00v3ac~~`''vo. N ~C G ~ i~ # z* ~~ U 'D '~ y 'b H v ~°,„ y ~~VJ a~ z¢o ~~ N 'V N O~ O N a cry Q w F a * I* I* I~ (* F# I# I# I* I* I* I# lip MI~I'~I~I~I~I~I°I~I~I~I~I~ V S - W ~~ ~ w ~O =o ~- u w s ~.= ~'._° E°~E~ ~~~ X ~ ~~~JY, ~'~ x ~ 2 ~ ~`~°~', u E ~-y ,c T ~ ~ ~ m c ., o a o 'm E T~a ~•~ o r ~••-°v~3 go ~ . e C ~ ~ ~+ ~ ai E °"._s ~wE~ u ~~ c ~ ~_ E ~ ~ N U ~' b u u w ~ > > $ o ~ ~ ~ N o ~ ~ % ~ pp c ~p~qO ~•O ~co~iy,'E G H 0..~ ~w o ~'o 0 G . ~ • ~ ~ N o~_~a ~~~~~~ ~~~~~ _~-~a YY E o s 3 F° a H w n l-~ OG 0 E w' k .s C ~° ao o c 4 ~~ F oC y a c/j ~~ THF, BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RZ3 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION N0.09-2518-CIVIL-TERM CUMBERLAND COUNTY v. BRINKLEY L. TUCKER, JR REBEKAH L. LAUGHMAN Defendant(s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RZ3, 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 805 FRONT STREET, NEW CUMBERLAND, PA 17070-2032. 1. 2. 3. 4. 5. Name and address of Owner(s) or reputed Owner(s): Name BRINKLEY L. TUCKER, JR REBEKAH L. LAUGHMAN Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE Address (if address cannot be reasonably ascertained, please so indicate) 5326 BELGRADO DRIVE CANAL WINCHESTER, OH 43110 5326 BELGRADO DRIVE CANAL WINCHESTER, OH 43110 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) RBS CITIZENS, NA 480 JEFFERSON BOULEVARD, #RJE350 WARWICK, RI 02885 RBS CITIZENS, NA C/O WILLIAM T. MOLCZAN, ESQ. 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 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) 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. 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 United States Internal Revenue Special Procedures Branch Federated Investors Tower U.S. Department of Justice U.S. Attorney for the Middle District of PA 805 FRONT STREET NEW CUMBERLAND, PA 17070-2032 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 13th Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 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. July 28, 2010 By: Phelaallinan & Schmieg,'~,LP ^ La nce 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 eetal 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 Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esp., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Est., Id. No. 58745 Sheetal R. Shah-Jani, Esq. Id. No. 81760 Jenine R. Davey, Esq., Id ?Io. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq. Id. No. 202331 Jay B. Jones, Esq. Id. ?1o. 86657 Peter J. Mulcahy, tsq, 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 THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW FORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RZ3 V. Plaintiff, r r p+? 7_ CU"J "?UI?C1Y V rA CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 09-2518-CIVIL-TERM BRINKLEY L. TUCKER, JR. REBEKAH L. LAUGHMAN 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 BRINKLEY L. TUCKER, JR. & REBEKAH L. LAUGHMAN on JULY 21, 2010, in accordance with the Order of Court dated JULY 14, 2010. The property was posted on JUNE 25, 2010. Publication was advertised in CUMBERLAND LAW JOURNAL on JULY 30, 2010 & in THE SENTINEL on JULY 23, 2010. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to the unsworn falsification to authorities. r,,, -, (' tit r u PHELAN H LINAN & S MIEG, LLP By: Lawrence T. Phelan, 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 ?fieetal R. Shah-Jani, Esq., Id. No. 81760 Jenme 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 Attorneys for Plaintiff 7178 2417 6099 0062 2764 4 / KXC RESTRICTED DELIVERY BRINKLEY L. TUCKER, JR 805 FRONT STREET NEW CUMBERLAND, PA 17070-0000 --fold here (regular) -- fold here (6x9) --fold here (regular) -rac'c & Confirm Page 1 of 1 i °""' U3VITEDSrATES i PCISTA SERVICE S Home I Help I Sign In Track & Confirm FAQs Traci & Confirm Search Results Label/Receipt Number: 7178 2417 6099 0062 2764 Class: First-Class Mail® Service(s): Return Receipt Electronic Status: Delivered Your item was delivered at 11:34 am on July 23, 2010 in PHILADELPHIA, PA 19103. Tack & Confirm Enter Label/Receipt Number. Detailed Results: • Delivered, July 23, 2010,11:34 am, PHILADELPHIA, PA 19103 • Arrival at Unit, July 22,2010,1:04 pm, PHILADELPHIA, PA 19104 • Acceptance, July 21, 2010, 4:33 pm, PHILADELPHIA, PA 19102 • Electronic Shipping Info Received, July 21, 2010 Notification Options Track & Confirm by email . Gax 3 Get current event information or updates for your item sent to you or others by email, Return Receipt (Electronic) Verify who signed for your item by email. Site lap Custom.et Service Forms Gov't Services Careers privy Polcy Tern s of Use &isoiess. ?ustorner Gatew Copyright,,?-) 2010 LISPS. All Rights Reserved. No FEAR Act EEO Data FOsA http://trkcnfrm l .smi.usps.com/PTSIntemetWeb/InterLabellnquiry.do?strOrigTrackNum==... 09/02/2010 7178 2417 6099 0062 2771 4 / KXC RESTRICTED DELIVERY BRINKLEY L. TUCKER, JR 5326 BELGRADO DRIVE CANAL WINCHESTER, OH 43110-0000 --fold here (regular) -- fold here (60) --fold here (regular) a UNI TED S TATES POSTAL SERVICE. Date Produced: 08/09/2010 PHELAN HALLINAN & SCHMIEG The following is the delivery information for Certified MaiITM item number 7178 2417 6099 0062 2771. Our records indicate that this item was delivered on 08/06/2010 at 10:37 a.m. in FAIRFIELD, PA, 17320. The scanned image of the recipient information is provided below. Signature of Recipient Address of Recipient: ffe Q'A Thank you for selecting the Postal Service for your mailing needs. If you require additional assistance, please contact your local post office or Postal Service representitive. Sincerely, United States Postal Service The customer reference number shown below is not validated or endorsed by the United States Postal Service. It is solely for customer use. Customer Reference Number: 62961 7178 2417 6099 0062 2788 4 / KXC RESTRICTED DELIVERY REBEKAH L. LAUGHMAN 805 FRONT STREET NEW CUMBERLAND, PA 17070-0000 --fold here (regular) -- fold here (60) --fold here (regular) UShS - Trac,c & Confirm Page 1 of 1 UN11_EDSTAT'ES '' POSTAL SAKE"i Home I Help I Sign In Track_& Confirm FA Qs Track & Confirm Search Results Label/Receipt Number: 7178 2417 6099 0062 2788 Class: First-Class Mail® Service(s): Return Receipt Electronic Status: Delivered Your item was delivered at 8:13 am on July 28, 2010 in PHILADELPHIA, PA 19103. Detailed Results: • Delivered, July 28, 2010, 8:13 am, PHILADELPHIA, PA 19103 • Arrival at Unit, July 26,2010,1:06 pm, PHILADELPHIA, PA 19104 • Forward Expired, July 23, 2010, 8:35 am, NEW CUMBERLAND, PA • Acceptance, July 21, 2010, 4:33 pm, PHILADELPHIA, PA 19102 • Electronic Shipping Info Received, July 21, 2010 1Vniicmion Options Track & Confirm by email Get current event information or updates for your item sent to you or others by email. G€r> ) Return Receipt (Electronic) Verify who signed for your item by email. Go>' Sde_tyEa (uric rif r SE> v!n= Farms. rov't_Service_. careersrw Say f ql cy errns of l gc_ f3iiyines5 tAst.c>mPr, C'{ew.y Cppyright(t> 2010 USP5. All Rights Reserved. No FEAR Act EEO Data f OiA Track & Confirm Enter Label/Receipt Number. http://trkcnfrm 1. smi.usps.com/PTSIntemetWeb/InterLabelInquiry.do9strOrigTrackNum==... 09/02/2010 7178 2417 6099 0062 2795 4 / KXC RESTRICTED DELIVERY REBEKAH L. LAUGHMAN 5326 BELGRADO DRIVE CANAL WINCHESTER, OH 43 1 1 0-0000 --fold here (regular) -- fold here (60) --fold here (regular) USPS - Trac c & Confirm Page 1 of 1 OSTAL SERM& Home I Help I Sign In Track B.Confirm FA Qs Track & confirm Search Results Label/Receipt Number: 7178 2417 6099 0062 2795 Class: First-Class Mail® Service(s): Return Receipt Electronic Status: Delivered Your item was delivered at 1:09 pm on August 12, 2010 in PHILADELPHIA, PA 19103. Track & Confirm Enter Label/Receipt Number. Detailed Results: • Delivered, August 12, 2010, 1:09 pm, PHILADELPHIA, PA 19103 • Notice Left, August 12, 2010, 9:12 am, PHILADELPHIA, PA 19103 • Unclaimed, August 07, 2010, 3:23 pm, CANAL WINCHESTER, OH • Notice Left, July 23, 2010,1:38 pm, CANAL WINCHESTER, OH 43110 • Arrival at Unit, July 23, 2010, 7:00 am, CANAL WINCHESTER, OH 43110 • Acceptance, July 21, 2010, 4:33 pm, PHILADELPHIA, PA 19102 • Electronic Shipping Info Received, July 21, 2010 Nuf fication Optiofis Track & Confirm by email Get current event information or updates for your item sent to you or others by email. Go> Return Receipt (Electronic) Verify who signed for your item by email. "Goa $+te NIaP.C..cistn+r car Scxyice. F{>rrns (,ov'f__Sf?rnc:es. Careers Copyright(:) 2010 LISPS. All Rights Reserved. No FEAR Act EEO Data FOi Go> Privacy PO icy Tc;+ms_gf_ se ri.r : , „^;; car C ate!way. http://trkcnfrm 1. smi. usps. comIPTSIntemetWeb/InterLabelInquiry. do?strOrigTrackNum==... 09/02/2010 PLAINTIFF THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RZ3 DEFENDANT BRINKLEY L. TUCKER, JR REBEKAH L. I.AUGHMAN SERVE REBEKAH L. ?,AUGHMAN AT: 805 FRONT STREET NEW CUMBERLAND, PA 17070-2032 ****PLEASE POST PER COURT ORDER**** NHS 0 203924 SERVICE TEAM/ iin COURT NO.: 09-2518-CIVIL-TERM TYPE OF ACTION XX Notice of Sheriff's Sale SALE DATE: 09/0812010 SERVED S rved and made known to REBEKAH L. LAUGHMAN , DQ ndant on the 'day of L- 20 at 'i; , , o'c:lock,4. M., at 305 EAONt ST_ NEW 'MMRWiLA 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. -0t Description: Age _ Height Weight Race Sex Other 1, N{ c b .44p 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 set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and su scribed before me this " day -- of k, 20 L0 l P _ #i? Notary:: By: NOTSERVED - Ob the . d of 20_ , at - o'clock . M., Defendant NOT FO'U qD beeotuse - ? Vacant. .. ` Bad Address _ Moved _ Does Not Reside (Not Vacant) No Answer on at at Service Refused Other: l Sworn to and subscribed , t before me this day iii Notary: , 9.1 AI?IfAL6Y FOR PLAINTIFF' !......_.__..._._._ _._...._...._.....__..._.......,._.:_._..._..?R6AQ6LZ Fsq., Id.Na32227 Framis S. 11a11buo, Esq, ld. N. 62695 Dank-1 G. Schmk& Fig, Id. Nu 62205 Mwbde M. Bradford, Es%, Id. No. 69849 Judith T.RmWk%FAq, W. N. 59745 Sbedal P- Sluh-bti, Fsq, W. N. 81760 Jame R. Dnwy, Es¢, Id. N. 87077 Lauren R. Tabus, Esq., W. N. 93337 Vhds Srirattara, Esq, W. No. 202331 Jay B. Jars, Fsq, W. No. 86657 Peter J. Molody, Fsq, hL No. 61791 Andmr L Sphad, Esq, hi. Nu M439 Job- Md:®nues, Fsq., Id Nu 90134 Ch -lane P. Flakes, Fs¢, Id. No. WW Joshua L GOMnm4 Fsq, Id. No. 206817 Corohany R. Duna, Esc, Id. N. 206779 Aodr C Brasbhti, Fsq, M. No. 2KWS One Amu (:ante at Suburban Station 1617 John F. Keawdy Bhd, Saito I4o0 Philedrlphia, PA 19103-1814 (215)563.7010 AFFIDAVIT OF SERVICE CUMBERLAND COUNTY AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK PHS # 203924 TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RZ3 DEFENDANT SERVICE TEAM/ iin BRINKLEY L. TUCKER, JR COURT NO.: 09-2518-CIVIL-TER.M REBEKAH L. LAUGHMAN SERVE BRINKLEY L. TUCKER, JR AT: TYPE OF ACTION 805 FRONT STREET XX Notice of Sheriffs Sale NEW CUMBERLAND, PA 17070-2032 SALE DATE: 09/08/2010 ****PLEASE POST PER COURT ORDER**** SERVED Served and made known to BRINKLEY L. TUCKER. JR , Defendant on the ? day of _ u t 20 IC! , at ?, o'clock 4. M., at 96 FRogT Sr krw eyA(3F. 2Wt4P,9An 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. V Other. AY!5 t? Description: Age ___ Height Weight Race Sex Other 1, P4-A1 Lb A10 Q_ a competent adult, being duly sworn according to law, depose and state that I personally Pj'PED +gwcbe l 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 a:.i 1, day f! of _7 R_L_?I 20 ?t 1 Not, y ? NOT SERVED c_ day 20_, at _ o'clock M.. Defendant NOT FOUND tx°caese: - 0a t - Bad Address . moved. - Does Not Reside (Not Vacant) No Answer on at at Service Refused Other: Sworn to and subscribed before rue this day of -fib= By: Notary: ATTORNEY FOR PLALNTIFF Uv,renee T. Phehu,, Fay., Id. Na 32227 Francis S. H.11-, Esq. M Nu. 62695 Dared G. Sdmnle& Fay., Id. No. 62285 Micbdc M. Bradford, Esq., Id. N. 6%" J-M T. Romano, Esq., Id N. 58745 SbWW R. Shah-Jere, Faq, Id. Na 81760 J.1. R. Drier, Esq., M. No. 87077 lamm R. Tabu, Fay, Id. N. 93337 Vivek Srivastava, Esq, Id. No. 202331 Jay B. Jom,s Esq., T& N. 86657 Petry J. Otulmhv, Egg, W. Na. 61791 Andrew L Spkacl,, E q, Id. N. 84439 Jaime McG„haeas, F-,%, Id. N. 90134 Cla4soeuhme P. FMW.% Esq., Id. N. 94620 Joshua L Goklumur, Esq, Id. No. 206017 Coun-y R. Dmm Fay., Id. N. 206779 Andrew C. Betunbidt, Esq.,, Id. No. 206375 One Peen Cemer at suburban Station 1617 John F. Kennedy Blvd, Suite 1408 PhLbKWphia, PA /91031814 1215) 5637000 ,4) r v, .P w N p ? oo J O? Cn J? W N z? C s? Z0 z00td C??t???dyyy M a y w r 2 r ?x cc" e l n - l mz > z `' m ? x ? ? W o n w n 0 0 r $ 01.68° oaz ? a m f ^s a b a b ox A ?z n= A'+ to y ?r W ?z C Q° 0 0 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. 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 3 0, 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. l? isa Marie Coyne., itor SWORN TO AND SUBSCRIBED before me this 30 day of July, 2010 Notary NOTARIAL SEAL :00ROUaN, BORAH A COLLIN8 Nobly Public ARLISLE CUMBERLAND COUNW My Co?nh W Expires Apr 28, 201 j CUMBERLAND LAW JOURNAL NOTICE OF SHERIFF'S SALE PHELAN HALLINAN & SCHMIEG, LLP In the Court of Common Pleas of Attorneys for Plaintiff Cumberland County, Pennsylvania July 30 NO. 09-2518 CIVIL-TERM THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION fka THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RZ3 VS. BRINKLEY L. TUCKER, JR. & REBEKAH L. LAUGHMAN NOTICE OF SHERIFF'S SALE OF REAL PROPERTY NOTICE TO: BRINKLEY L. TUCKER, JR. & REBEKAH L. LAUGHMAN Being Premises: 805 FRONT STREET, NEW CUMBERLAND, PA 17070-2032. Being in NEW CUMBERLAND Township, County of CUMBERLAND, Commonwealth of Pennsylvania. Parcel Number 1: 25-25-0006- 432. Improvements consist of residen- tial property. Sold as the property of BRINKLEY L. TUCKER, JR. & REBEKAH L. LAUGHMAN. Your house (real estate) at 805 FRONT STREET, NEW CUMBER- LAND, PA 17070-2032 is scheduled to be sold at the Sheriff's Sale on SEPTEMBER 8, 2010 at 10:00 A.M. at the CUMBERLAND County Court- house to enforce the Court Judg- ment of $121,432.61 obtained by, THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL AS- SOCIATION fka THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RZ3 (the mortgagee), against the above premises. PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland inel, of Tames Kleinldaus Director of Sales and MS nd says on that HEtSENT NEL adwspaper State aforesaid, being duly sworn, depose y of general circulation in the Borough ?ne which date THE SENTINEL has been,regularly established December 13th, 188, issued in said County, and that the printed hed in the regular editions andhssuE of notice or puication exactly the same as was printed and published THE SENTINEL on the following day(s): Tuly 23, 2010 COPY OF NOTICE OF PUBLICATION NOTICE OF SHERIFF'S SALE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-2518-CIVIL-TERM THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RZ3 vs. BRINKLEY L. TUCKER, JR. & REBEKAH L. LAUGHMAN NOTICE TO: BRINKLEY L. TUCKER, JR. & REBEKAH L. LAUGHMAN NOTICE OF SHERIFF'S SALE OF REAL PROPERTY" Being Premises: 805 FRONT STREET, NEW CUMBERLAND, PA 17070-2032 Being in NEW CUMBERLAND Township, County of CUMBERLAND Commonwealth of Pennsylvania Parcel Number 1:25-25-0006-432 Improvements consist of residential property. Sold as the property of BRINKLEY L. TUCKER, JR. & REBEKAH L. LAUGHMAN Your house (real estate) at 805 FRONT STREET. NEW CUMBERLAND. PA 17070-2032 is scheduled to be sold at the Sheriff's Sale on SEPTEMBER $. 2010 at 10;,00 AM, at the CUMBERLAND County Courthouse to enforce the Court Judgment of $121.432.61 obtained by, THE BANK QF NEW YORK MELLON TRUST COMPANY NATIONAL ASSOCIATION ACA THE BANK QF NEW YORK TRUST COMPANY NN=A. A-$ SUCCESSOR M JPMORGAN CHASE BANK N.A. . AS TRUSTEE FOR RAMP 020 5RZ3 (the mortgagee), against the above prern*" PHELAN HALLINAN & SCHMIEG, LLP Attorney for Plaintiff Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. Sworn to and subscribed before me this Notary Public My commission expires: NOTARIAL SEAT BAMBI ANN HECKENOORN Notary Public a CARLISLE BOROUGH, CUMBERLAND CNN ^{ ' omr- Fxpves Jan 27. 2014 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson "_ ~ ~'~ Th~~~~ ~ Tt~~3NOTAft Sheriff Y ~~,~„~~ ~~ ~t~l~~~~r~y~ 1~1(l ACT 20 A~3 9~ 45 Jody S Smith Chief Deputy ~>- ~-;~~ , Y a -~ ~,_ ~r: C€1~i~~R~APdD CQU-vTY Richard WStewart - F'~~S~f~Vl~~1A Solicitor c+r~tc~ ~.~F Tt~~ ~„ER~F~ The Bank of New York Mellon Case Number vs. Brinkley L. Tucker, Jr. (et al.) 2009-2518 SHERIFF'S RETURN OF SERVICE 05/07/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice of Sale and Description in the following manner: The Sheriff mailed a notice of the action by certified mail, return receipt requested to the within named defendant Brinkley L. Tucker, Jr. to wit: to his last known address of, 5326 Belgrade Drive, Canal Winchester, OH 43110. The return receipt card was signed by, Rebecca Tucker, on July 3, 2010, and returned to the Cumberland County Sheriff s Office 05/07/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice of Sale and Description in the following manner: The Sheriff mailed a notice of the action by certified mail, return receipt requested to the within named defendant(s), to wit: Rebekah L. Laughman to her last known address of, 5326 Belgrade Drive, Canal Winchester, OH 43110. 06/24/2010 10:47 AM -Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on 6-24-2010 at 1042 hours, she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Brinkley L. & Rebekah L. Tucker, Jr., locatec at, 805 Front Street, New Cumberland, Cumberland County, Pennsylvania according to law. 09/07/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice of Sale and Description in the following manner: The Sheriff mailed a notice of the action by certified mail, return receipt requested to the within named defendant to wit: Rebekah L. Laughmen, 5326 Belgrade, Drive, Canal Winchester, OH 43110. The mail piece was returned "Unable to Forward" on July 14, 2010, to the Cumberland County Sheriffs Office. 09/09/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on 9/8/10 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Daniel Schmieg on behalf of The Bank of New York Mellon Trust Company, National Association, F/IVA The Bank of New York Trust Company, N.A., As Successor to JPMORGAN Chase Bank, N.A., as Trustee for RAMP 2005RZ3, 1100 Virginia Drive, Fort Washington, PA 19034, being the buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of $ 802.99 Bankruptcy petition #xxxxx filed by xxxxx stays further execution. Sheriff sale cancelled. SHERIFF COST: $802.99 October 14, 2010 (c) GountySuite Sheriff, Teleosoft Inc. SO ANSWERS, ' RON R ANDERSON, SHERIFF ~~oaPd~ ~sa ~~~, (,~ ~ 7f G3S ~ a~~'~7~ ~` THE BANK OF-1~W 1~ORK MELLON TRUST COM~'ANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RZ3 Plaintiff v. BRINKLEY L. TUCKER, JR REBEKAH L. LAUGHMAN Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION N0.09-2518-CIVIL-TERM CUMBERLAND COUNTY AFFIDAVIT PURSUANT TO RULE 3129.1 THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 200587.3, 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 805 FRONT STREET, NEW CUMBERLAND, PA 17070.2032. 1. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) BRINKLEY L. TUCKER, JR 5326 BELGRADO DRIVE CANAL WINCHESTER, OH 43110 REBEKAH L. LAUGHMAN 5326 BELGRADO DRIVE CANAL WINCHESTER, OH 43110 2. Name and address of Defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real properly to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) None. 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) 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 i Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT Domestic Relations of Cumberland County 805 FRONT STREET NEW CUMBERLAND, PA 17070-2032 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare United States Internal Revenue Special Procedures Branch Federated Investors Tower U.S. Department of Justice U.S. Attorney for the Middle District of PA P.O. Box 2675 Harrisburg, PA 17105 13th Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 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. March 31, 2010 ~) C By: 1'~ c Attorney or 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 ^ 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. 8665? ^ Pe er J. Mulcahy, Esq., Id. No. 61791 ^ drew 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 THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RZ3 COURT OF COMMON PLEAS CIVIL DIVISION N0.09-2518-CIVIL-TERM Plaintiff vs. BRINKLEY L. TUCKER, JR REBEKAH L. LAUGHMAN Defendant(s) CUMBERLAND COUNTY NOTICE OF SHERIFF'S 5ALE OF REAL PROPERTY TO: BRINKLEY L. TUCKER, JR REBEKAH L. LAUGHMAN 5326 BELGRADO DRIVE CANAL WINCHESTER, OH 43110 * *THIS FIItM 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, TH1S 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 805 FRONT STREET, NEW CUMBERLAND, PA 17070-2032 is scheduled to be sold at the Sheriff s 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 $121,432.61 obtained by THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RZ3 (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 ar 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 Iegal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. ~! 1. If the Sheriff s Sale is.not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 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 ca11215-563-7000. 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 prepazed 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 aut 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 N0.09-2518-CIVIL-TERM THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RZ3 vs. BRINKLEY L. TUCKER, JR REBEKAH L. LAUGHMAN owner(s) of property situate in the BOROUGH OF NEW CUMBERLAND, Cumberland (Municipality) County, Pennsylvania, being 805 FRONT STREET, NEW CUMBERLAND, PA 17070-2032 (Acreage or street address) Parcel No. 25-25-0006-432 Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $121,432.61 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 LEGAL DESCRIPTION ALL THAT CERTAIN lot or parcel of land situate in the Borough of New Cumberland, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the Northern line of Front Street on the dividing line between Lot Nos. 2 and 3, Block'B', on the hereinafter mentioned Plan of Lots; thence in a Northerly direction along said dividing line One Hundred (100) feet to a Twenty feet alley; thence in a Westerly direction along the Southern line of said alley Fifty (50) feet to a point on the dividing line between Lot Nos. 3 and 4, Block'B', on said Plan of Lots; thence in a Southerly direction along said last mentioned dividing line One Hundred (100) feet to Front Street; thence in an Easterly direction along the Northern line of Front Street Fifty (50) feet to the point or Place of BEGINNING. BEING Lot No. 3, Block'B' as shown on Plan No. 5, Rosemont Addition to the Borough of New Cumberland, said Plan being recorded in the Cumberland County Recorder's Office in Plan Book 3, page 64. HAVING THEREON ERECTED a one story frame dwelling house known and numbered as 805 Front Street, New Cumberland, Pennsylvania. TITLE TO SAID PREMISES IS VESTED IN Brinkley L. Tucker, Jr., single man and Rebekah L. Laughman, single woman, as joint tenants with the right of survivorship, by Deed from Elizabeth F. Cramer, a single woman, dated 07/15/2005, recorded 07/27/2005 in Book 270, Page 387. PREMISES BEING: 805 FRONT STREET, NEW CUMBERLAND, PA 17070-2032 PARCEL NO.25-25-0006-432 . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 09-2518 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION f/k/a THE BANK OF NEW YORK TRUST COMPANY, N.A., as Successor to JPMORGAN CHASE BANK N.A., as Trustee for RAMP 2005RZ3, Plaintiff (s) From BRINKLEY L. TUCKER, JR and REBEKAH L. LAUGHMAN (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 $121,432.61 L.L. Interest from 6/27/09 to Date of Sale ($20.24 per diem) -- $8,885.36 Atty's Comm Atty Paid $919.50 Plaintiff Paid Date: 4/1/10 Due Prothy $2.00 Other Costs Dav d D. Buell, Prothonotary (Seal) REQUESTING PARTY: By: Name: JAIME McGUINNESS, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP ONE PENN CENTER, SUITE 1400 1617 JFK BOULEVARD PHILADELPHIA, PA 19103 Deputy Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 90134 V' On June 14, 2010 the Sheriff levied upon the defendant's interest in the real property situated in New Cumberland Borough, Cumberland County, PA, Known and numbered as, 805 Front Street, New Cumberland, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 14, 2010 By: ~~~ ~~ Real Estate Coordinator PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. 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 Cazlisle 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 regulazly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regulaz editions and issues of the said Cumberland Law Journal on the following dates, vlz: July 16 Julv 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. ~-rlc lto. ~-aaia ct.tl .The Bank of New York Mellon F/K/A The Bank of New York as Successor to JPMorgan Chase Bank, As Trustee for the Benefit of the Certificateholders of Equity One ABS, Inc. Mortgage Pass-Through Certificates, Series 2004-2 vs. Brinkley L. Tucker, Jr. Rebekah L. Laughman Atty.: Daniel G. Schmieg THE BANK OF NEW YORK MEL- LON TRUST COMPANY, NATIONAL ASSOCIATION FKA THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RZ3 vs. BRINKLEY L. TUCKER, JR A j KJ A BRIAN TUCKER, REBEKAH L. LAUGHMAN A/K/A REBEKAH BLACKSTONE A/K/A REBEKAH LAUGHMAN A/K/A RE- BEKAH L. TUCKER. 805 P`RONT STREET, NEW CUM- BERLAND, PA 17070-~32. Parcel No. 45-25-0006-432. isa Marie Co e, Editor SWORN TO AND SUBSCRIBED before me this 30 of July. 2010 Notary NOTARIAL SEAL DEBORAH A COILINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commbaion Expires Apr 28, 2014 ~ The Patriot-News Co. 2020 TechnolAgy P~Cwy Suite 300 Mechanicsburg, P~- 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE the ~latriot 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 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither 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. o~ ~Q~ ireT~nnl rc')PY This ad ran on the dates} shown below: Writ No. 2009-2518 Civil Term 07/09/10 Tha Bank of New York McNon F/K/A The Bank of New York as 07/16/10 Successor to JPMorgan Chase ~3ank, As Trustee for the Benefit of the Certificateholders of 07/23/10 Equity One ABS, Inc. Mortgage Pass-ThroughCertfficates, Series 2004-2 VS /~ ~ Brinkley L. Tucker, Jr. bscribe efore m this~jf•Ja -of August, 2010 A. D. Sworn to and Rebekah L. Laughmen J s ~~ Atty: Daniel G Schmieg • . ~ , 9 ~ ' THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION Notary PUbIIC I'KP, THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP2005RZ3 COMNiONWERIL~`~ C1F l'E;AdE~4SYL'~Aiti~ti vs. Notaria9 Sea! .•~ BRINKLEY L. TUCKER, JR A/K/A BRIAN SheMe L Kisser, Notary Pub1iG TUCKER Lower Parton Twp,, l7auph4n County REBEKAH L. LAUGHMAN A/K/A My Commission Exp Irk ~5 2011 REBEKAHBLACKSTONEAlK/AREBEKAH ~ - Member, Pennsyivanla Assaciatlan of° ~o~sr;a~ LAUGHMAN A/K/A REBEKAH L. TUCKER 805 FRONT STREET, NEW CUMBERLAND, PA 17070-2032 PazcelNo.25-25-0006-432 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which RAMP 2005RZ3 Tr is the grantee the same having been sold to said grantee on the 8th day of September A.D., 2010, under and by virtue of a writ Execution issued on the 1st day of April, A.D., 2010, out of the Court of Common Pleas of said County as of Civil Term, 09 Number 2518, at the suit of RAMP 200RZ3 Tr against Brinkley L Tucker Jr & Rebekah L Lauahman is duly recorded as Instrument Number 201030013. IN TESTIMONY WHEREOF, I have h eunto set my hand and seal of said office this ~ day of A.D. ~ D 10 of Deeds Reool(fera~ Oe~ d.nbede~d OauilX O~A~N. Pr- try damiorlE~irastlrfi~tNond~f~FJen.2o14