The URL can be used to link to this page

Home My WebLink About09-4158 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE, ON BEHALF OF THE HOLDERS OF THE HOME EQUITY ASSET TRUST 2007- 2 HOME EQUITY PASS-THROUGH CERTIFICATES, SERIES 2007-2, vs. Plaintiff, JONIRAUDABAUGH Defendants. TO: DEFENDANTS YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE ENTERED AGAINST YOU. I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: 3815 South West Temple P.O. Box 65250. Salt Lake City, UT 84115-4412 AND THE DEFENDANT: 800 Upland Street Mechanicsbum, PA 17055 CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFE CTED BY THIS LIEN IS 800 Upland Street. Mechanicsburg PA 17055 Municipality: Lower Allen I9 dd ATTORNEY FOR PLAINTIFF ATTY FILE NO.: FCP 124952 CIVIL DIVISION// NO.: eq_ 1115-ir ?/Vi/ TYPE OF PLEADING CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE FILED ON BEHALF OF: U. S. Bank National Association as trustee, on behalf of the holders of the Home Equity Asset Trust 2007-2 Home Equity Pass-Through Certificates Series 2007-2 COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG & ACKERMAN, LLC .9cott A. Dietterick, Esquire Pa. I.D. #55650 Kimberly A. Bonner, Esquire Pa. I.D. #89705 Eric Santos, Esquire Pa. I.D. #201493 Joel A. Ackerman, Esquire Pa I.D. #202729 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 (908) 233-8500 (908) 233-1390 FAX office&zucker olldber .com File No.: FCP- 124952/ad 4.4rm Zucker, Goldberg & Ackerman, LLC FCP-124952 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 ET SEQ. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF, IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. Zucker, Goldberg & Ackerman, LLC FCP-124952 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE, ON BEHALF OF THE HOLDERS OF THE HOME EQUITY ASSET TRUST 2007-2 HOME EQUITY PASS-THROUGH CERTIFICATES, SERIES 2007-2, CIVIL DIVISION NO.. Plaintiff, vs. Joni M. Raudabaugh Defendants. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim 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 SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 LAWYER REFERRAL Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Zucker, Goldberg & Ackerman, LLC FCP-124952 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. BANK NATIONAL ASSOCIATION, AS CIVIL DIVISION TRUSTEE, ON BEHALF OF THE HOLDERS OF THE HOME EQUITY ASSET TRUST NO.: 2007-2 HOME EQUITY PASS-THROUGH CERTIFICATES, SERIES 2007-2, Plaintiff, VS. Joni M. Raudabaugh Defendants. AVISO USTED HA SIDO DEMONDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro do los proximos veinte (20) dias despues de la notifacacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comperencencia escrita y redicanco en la Courte por escrito sus defensas de, y objecciones a, los demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero O propieded u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABAGADO IMMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO O NO PUEDE PAGARLE A UNO, LLAME A VAYA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 LAWYER REFERRAL Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Zucker, Goldberg & Ackerman, LLC FCP-124952 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. BANK NATIONAL ASSOCIATION, AS CIVIL DIVISION TRUSTEE, ON BEHALF OF THE HOLDERS OF THE HOME EQUITY ASSET TRUST NO.: 01- q /s F T4-- 2007-2 HOME EQUITY PASS-THROUGH CERTIFICATES, SERIES 2007-2, : Plaintiff, vs. Joni M. Raudabaugh Defendants CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And now comes U.S. Bank National Association, as trustee, on behalf of the holders of the Home Equity Asset Trust 2007-2 Home Equity Pass-Through Certificates, Series 2007-2 , by its attorneys, Zucker, Goldberg & Ackerman, LLC, and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is U.S. Bank National Association, as trustee, on behalf of the holders of the Home Equity Asset Trust 2007-2 Home Equity Pass-Through Certificates, Series 2007-2, having its principal place of business at 3815 South West Temple P.O. Box 65250, Salt Lake City, UT 84115-4412. 2. The Defendant, Joni M. Raudabaugh, is an individual whose last known address is 800 Upland Street, Mechanicsburg, PA 17055. 3. On or about November 15, 2006, Joni M. Raudabaugh executed a Note in favor of EquiFirst Corporation in the original principal amount of $118,400.00. Zucker, Goldberg & Ackerman, LLC FCP-124952 4. On or about November 15, 2006, as security for payment of the aforesaid Note, Joni M. Raudabaugh made, executed and delivered to Mortgage Electronic Registration Systems, Inc. as nominee for EquiFirst Corporation a Mortgage in the original principal amount of $118,400.00 on the premises hereinafter described, with said Mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on November 22, 2006, in Mortgage Book Volume 1973, Page 4912. A true and correct copy of said Mortgage containing a description of the premises subject to said Mortgage is marked Exhibit "A", attached hereto and made a part hereof. 5. The aforesaid Note and Mortgage was assigned by Mortgage Electronic Registration Systems, Inc. as nominee for EquiFirst Corporation to U.S. Bank National Association, as trustee, on behalf of the holders of the Home Equity Asset Trust 2007-2 Home Equity Pass-Through Certificates, Series 2007-2, plaintiff herein, pursuant to an assignment of mortgage to be recorded. 6. Joni M. Raudabaugh, single is the record and real owner of the aforesaid mortgaged premises. 7. Defendant is in default under the terms of the aforesaid Mortgage and Note for, inter alia, failure to pay the monthly installments of principal and interest when due. 8. On or about April 21, 2009, Defendant(s) were mailed a combined Notice of Homeowners' Emergency Mortgage Assistance Act of 1983 and Notice of Intention to Foreclose Mortgage, in compliance with the Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983 and Act 6 of 1974, 41 P.S. §101, et seq. Zucker, Goldberg & Ackerman, LLC FCP-124952 9. The amount due and owing Plaintiff by Defendant is as follows: Principal $115,987.26 Interest through 06/11/2009 $3,958.43 Attorneys' Fees $1,250.00 Title Search & Costs $2,500.00 Late Charges $ 337.60 Suspense Balance ($ 189.17) Escrow $2,773.47 Miscellaneous $ 67.05 Total $126,684.64 plus interest on the principal sum ($115,987.26) from June 11, 2009, at the rate of $24.47 per diem, plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due of $126,684.64, with interest thereon at the rate of $24.47 per diem from June 11, 2009, plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. Zucker, Goldberg & Ackerman, LLC FCP-124952 ZUCKER, GOLDBERG & Q-C:' RMAN BY: I Scott A. Dietterick, Esquire PA I.D. # 55650 Kimberly A. Bonner, Esquire PA I.D.#89705 Richard P. Haber, Esquire PA I.D.#202567 Eric Santos, Esquire PA I.D.#201493 Joel A. Ackerman PA I.D.#202729 Attorneys for Plaintiff 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 908-233-8500 FAX 908-233-1390 EXHIBIT A Zucker, Goldberg & Ackerman, LLC FCP-124952 CERTIFIED 74AND.JCU RE T COPY ` d!o PrqwW By. Martin Matt Swenson 500 rarest point Circle, Charlotte, WC 28273 (704) 623-4248 Return To: Rquirirat Corporation Attar Collateral m 500 rarest Paint Circle Charlotte, NC 28273 Parcel Number er {111{?1{11110? {l!{ 77 13-24-0795-015 Premism 800 Upland Street:, Mechanicsburg, PA 17055 1Spaee Above 7bh Ltae For Reeorda8 tom) oNS MORTGAGE w? need in multiple sectw= of this M[N_1oo200l00109092217 Sections 3, 11, 13, t 20 and 21. f iu n document we defined below amd other words are defined m . also provided in Section 16. 8 the Waage of words used in this docamuat art (A) Sectidty hiShmmDt" meams this docxtment, which is datod Novenbwr 15, 2006 together with all Riders to this document (B) "Borrower" is Joni M Raudabaugh and Borrower is the mortgagor under this Security Instrument (G) TAM" is Mortgage Electronic acting ?? as a nominee for won SyswxI, Inc. MFRS is a separate corporation that is soda this sec oily fit. MERS ? LeodW 8 suooemsors amd assigns. MMS is the mores address amd tclepbome number of P.O. Box. 202 MI 48501-2026, tel. (ga) 679- lots an bWX& 1090922 PENNSYLVANIA - Single family -FanMe MaWFrwMb Mac UNIFORM INSTRUMENT WITH M6t8 -OA(PA)Nosono, Fom 3039 1 4 1 Pp t of to bpe VMP M o Ig - sawdeft M, • • (D) "Leader" is Bquiffirat Corporation Leader is a Corporation organized and aistiog under the haws of North Carolina Lender's address is 500 Forest Paint Circle, Charlotte, NC 28273 (E) "Note" means the promissory note signed by Borrower and dated November 15, 2006 The Note states that Borrower owes Leader one hundred eighteen thom and four hundred and 00/300 dic (U.S. S11e, 400.00 ) plus interest. Borrower has promised to pay Dollars Payments and to pay the debt in full not later thaw December 1, 2036 ? debt in regular Periodic (F) "Property" means the property that is described below under the heading "Transfer of Rights in the D..,...?..-" ((? ``??lY'??ean" means the debt evidenced by the Note, plea interest, nay prepayment charges and late charges doe under the Note, and all sums due under this Security Inshu went, plus interest. (EQ "Ride's" means all Riders to this Security Instrument that are executed by Borrower. The following Riders are to be executed by Borrower [check bend as applicable]: F Adjustable Rate Rider Coadommmm Rider Second Home Rider Balloon Rider Planned Unit Development Rider 14 Family Rider OVA Rider Biweekly Payment Rider pis) [may] PrePaymant Penalty Rider M "AppUmble Law" means all arat Umg applicable federal, state and local statutes, ieguiasious, ord>?oes and administrative rules and ardaa (that have the effect of law) as well as all applicable final, non-appealable judicial opinions. (J ) "Community Association Davy Feu, and Assessments" means all dam fees, assessmeats and other dbarges; that an itaposed on association or Similar •B?°.'=o wer or the Property by a condominium association, homeowners ? &A or Wmil ak Transfer" means any transfer of funds, th dun on ororiginated by instrument. paper instrument, which is initiated throe or credit an account. Such term includes, computer, or Magneftc tape so as to order, instruct, or mithorin a financial institution to debit mom, ?? in 'but is not limited to, point-of-sale transfety automated taller traosfess.°ne+ wire tranakrs, and automated clearinghouse (L) "Eservw Item" means those items that are desaYbed in Section 3. 00 Mfiwdhmwm Proceeds" means any on, settlement, award of damages, or proceeds paid by any third party (other than Mi wance proceeds paid under the coverages described in Section S) for. (i) damage to, or destruction 04 the Property, (ii) Condemnation or other taking of all or any of the ProPeaY (in) conveyance in lieu of condemnation; or (n,) mi ta £ or omissi patons to. the value and/or condition of the Property. (N) the ? Insunmee" means insotenx protecting Lender against the noquyme t of, or defaoit on, (O) "Peiodle Payment" means the regularly scheduled amount due for (ii) principal and interest under the N^ Plus (u) any amounts under Section 3 of this Security Instrument, .1090922 4q-6A(PA)tosos}ot eatWc wos2 of 16 Fora 3039 1101 • '? B" mreplahm esas the Real Estate Settlement Procedures Act (12 U. &C. Saxion,2601 et seq.) and its Regulation X C.F.R. Part 3500), as they mig(it'be amended fi+ant time to tale, or my additional or Successor in this Security instrument, ¦R A on or won that ggoveraa the =&w subject matter. As used to a " node: hdoroHyRESPA lama" even if all Ldan does ? gWarss? that am y rrlabed in resod Im. (Q) "Successor in baberest of Borrower" means any party that has taken title to the Property, whether or not that party has assumed Borrower's obligations under the Note and/or this Security Instrum=L TRANSFER OF RICiH'i"5 IN THE PROPERTY This Security Instrument secures to Leader (i) the repayment of the Loan, and all renewals, extensions and modifications of the Note; and (ii) the per6ormance of Borrower' a Security Instrument and the Note. For this purpose, Borrower does chereby nwtga ovenants and agreements o? this = d MM (solely as rnomiaoe for Lender and Leader's Successors and ge• grant and i;ns) and to the =onvey to Udgas of MERS, the-following descrMed property located in the Count saoxssors and of Cumberland Y (?'rix of bteoardior 7umif?cdonl Sae Attaebted Ezbibdt A [frame of Recoc 7Yumdicgon]; which cturently has the address of 800 Upland Street Mechanicsburg ' [lea] ("Property "): (?r4r]. Peamsylvmia 171)55] TOGETHER WITH all the mtproveaients now or hereafter erected on the FnsPerty, and an a oau?s, and dditions Sh also ini res now or hereafeer a part of the "Iy- AD "Placements end eau be covered by this Security Ia8tramamt. All of the SeaaitY hatroment as the Proper ty. Borrower vodersomds and is re&rred to in this to the interests by Bonrowe: in this Woo M that holds only legal title ?m?d Secuuity Inabrunionk but, if neoaaary to comply with law or es`rtom, HERS (as wee for 7,.der and Leader's Successors and assi ) has the right ? to exeroiae any or au of those iaoere?, but not limited to. the tdw any action ropert,, and tt. regaled of including, but rot 1muted m, releasing and and c??P this Security 1090922 '?-QA(PAl(osoeloi ra.aoiie Foam 3039 1101 • • BORROWER COVENANT'S thst Borrower is lawfully seised of the estate hereby conveyed and has the right to mortgage, grant and oonvey the Property =4 that the Property is vaanamibered, compt for encumbrances of retold Borrower wa<rmts and will defend generally the title to the Property against all claims and dmwAKb, s*cd to any secs of reow& THIS SECURn Y INSTRUMENT oombines uniform oovenents for national use and non-niform covenants with limited variations by jurisdiction to coustiwte a uniform security instrument covering real Propony. UNIFORM COVENANTS. Borrower and Lender covenant and as= as follows: L Paymamt of Pri KIP2 , Intuweat, Eactow Items, Prgnyment Charges, and Late Charges. Borrower shall pay when due the principal of and interest on, the debt evidenced by the Now and any prepayment charses and late charges due under the Note. Borrower shall also pay funds for Escrow Items pursuant to Section 3. Payments due under the Note and this Security Instrument shall be made in U.S. currency. However, if any check or other iasbrument re=vW by Leader as payment under the Note or this Security Instrument a returned to Lender unpaid, Lender may require that any or all subse qu m payments due wader the Note and this Security bstrumant be made in one or more of the following forms, as selected by Leader: (a) cash; (b) money order; (c) certified check, bank check, trev=W s chock or cashier' a check, provided any such check a drawn upon an institution whose deposits are insured by a federal agency, instrumentality, or entity; or (d) Electronic Funds Transfer. Payments are deemed received by Lender when received at the location designated in the Note or at such other location as may be designated by Lender in accordance, with the notice provisions in section 15. T may return any Payer of partial payment if the payment or partial payments are insufficient to bring the Loan current. bender may accept say Payment or Partind payment insufficient to bring the Loan aurr+ent, without waiver of any rights hereunder or prejudice to its rights to refuse such payment or partial payments in the future, but Leader is not obligated to apply such paymeotx at the time such payumb are accepted If each Periodic Payment is applied as of its scheduled due date, these Lender need not pay interest on unappliied fiends. Leader may hold arch unapplied fimds until Borrower makes payment to bring the Loan current If Borrower does not do so within a reasonable period of timer, Leader shall either apply such finds or r+euun them to Harrower. If not applied earlier, such 5mds will be applied to do outstandiog principal balance under the Note immediately prior to &ncloaure. No offiet of claim which Borrower might have now or in the future against Lender shall relieve Borrower from making payments due under the Note and this Security Instrvmeert or performing the covenants and agreements seautd by this security Instrument. 2. Appilextion of Payments or Proceeds, Except as otherwise described is this Section 2, all paynbmta acoepted and applied by Lander shall be applied in the following order of priority: (a) interest tine undcf the Note; (b) principal due undo the Note; (c) amounts due under Section 3. Such payments shall be applied to each Periodic Payment in the order in which it became due Any remaining amounts sbull be applied first to late c I gee, second to any other amounts due under this Security Instrument, and than to reduce the principal balance of the Note. If Leader receives a payment firm Borrower for a delinquent Periodic payment which includes a sufficiant mount to pay any late charge due, the payment may be applied to the delinquent payment and the late charge: If mot than one Periodic Payment is outstanding, Lender may apply any payment received from Borrower to the repayment of the Periodic Payments it and to tho extent that, each payment ` ?, 2090922 bay `-1R?'-(c Ck-.- -aA(PA) (osesp, PAP 4 of to fan 3038 1101 • • j _ .. can be paid in fall. To the extent that any excess exism after the payment is.applied to the full payment of one or mote Periodic Payments, such excess may be applied to any late charges due. Voluntary prepayments shall be applied fast to any prepayment charges and then as described in the Note. Any application of payments, insurance pr o ceeds, or Miscellaneous Proceeds to principal due under the Note shall not extend or postpone the due dame, or change the amouv4 of the Periodic Payments. 3. Funds for Escrow Items. Borrower shall pay to Lender on the day Periodic Payments are due under the Note, until the Note is paid in full, a sum (the "Funds") to provide for payment of amounts due for. (a) taxes and assessments and other items which can attain priority over this Security Instrument as a lien or encumbrance on the Propaty; (b) leasehold payments or ground -rents on the Property, if any; (c) ptemiunu for any and all insurance required by Leader under Section 5; and (d) Mortgage Insurance premiums, if any, or any sums payable by Borrower to Lender in lieu of the payment of Mortgage Inuaaaaa premiums in accordance with the provisions. of Section 10. These items are called "Escrow Items." At origination or at any time during the term of the Loma, I.ender may require that Community Association Dues, Fees, and Ate, if any, be escrowed by Borrower, and such dues, fees and assessments shall be on Escrow Item. Borrows shall promptly furnish to Lender all notices of amounts to be paid under this Swoon. Borrower shall pay Lender the Funds for Escrow Items unless Leader waives Borrower's -obligation to pay the Funds for any or all Escrow Itema. Lender may waive Borrowed s obligation to pay to Lender Funds for any or all Escrow Items at my time. Any such waiver may only be in writing. In the event of such waiver, Borrower shall pay directly, when and where payable, the amounts due for any Escrow hams for which payment of Funds has been waived by bender mud,. if Leader requires, shall Aunish to Leader reompts evidencing such payment within such time period as Leads may require. Borrower's obligation to malm such payments and to provide receipts shall for all purposes be deemed to be a owe ant and agreement contained in this Security Instrument, as the phrase "covenant and agreement" is used in Section 9. If Borrower is obligated to pay Escrow Items directly, pursuant to a waiver, and Borrower fails to pay the amount due for an Escrow ham, Lender may cmcise its rights wader Section 9 and pay sack anim and Borrower shall then be obligated under Section 9 to repay to Lender any such amount. Lender may revolve the waiver as to any or all Escrow Items at any time by a notice given in accordance with Section 15 mud; upon such revocation, Borrower shall pay to Lender all Funds, and in such amounts, that are then required wader this Section 3. Lender may, at any time, collect and hold Funds in an amount (a) sufficient to permit Leader to apply the Fug at the time specified under RF.SPA, and (b) not to exceed. the maximum amount a leader can raluire under RESPA. Lender shall animate the amount of Funds due on the basis of cment data and reasonable estimates of expenditures of future Escrow Items or otherwise in accordance with Applicable Law. The Funds shall be held is an institution whose deposits are insured by a federal agency, instrumentality. or entity (including Leader, if Lender is an institution whose deposits are so insured) or in nay Federal Home Loan Bank Lender shall apply the Fund3 to pay the Escrow Items no later than the time specified under RESPA. Lender shall,not charge Borrower for holding and applying the Funds, annually ameb-zhrg the escrow account, or verifying the Escrow Items, anlesa Leader pays Borrower interest on the Funds and Applicable Law permits I.ender to maim such a charge. Unless an agreemeni is made in writing or Applicable Law requiresrotten- to be paid on the Funds, Lender shall not be required to pay Borrower any interest or emniags on the Funds. Borrower and Lender can agree in writing, however, that interest 1090922 ?) w _ tearer or A(PA) (054nat pop $ of is Form 3039 1101 • 0 ?; - shall be paid on the Funds. -Leader stall give to Borrower, `without dWne, an annual accounting of the Funds as required by RESPA If there is a surplus of Funds held in escrow, as defined under RESPA. Leader shall acco w to Borrower for the amens funds in accordance with RESPA If there is a shortage of Funds held in escrow, as defined Under RESPA. Lender shall notify Harrower as required by RESPA, and Borrower shall pay to Lender the amount necessary to make up the shortage in accordance with RESPA, but in no more than 12 monthly payments. If there is a deficiency of Funds held in escrow, as defined under RESPA, Lender shall notify Borrower as required by RESPA, and Harrower shall pay to Leader the amount necessary to make up the deficiency in accordance with RESPA, but in no more dawn 12 monthly payments. Upon payment in full of all sums secured by this Security Instrument, Lender shall promptly refimd to Borrower any Funds held by Lender. 4. Charges; Lima. Borrower shall pay all taxes, assessments, charges, fines, and impositions attributable to the Property which can attain priority over this Security Iastramea% leasehold payments or ground rents on the Property, if any, and Community Association Does, Fees, and Assessments, if any. To the extent that these items are Escrow Items, Borrower shall pay them in the moaner provided in Section 3. Borrower alai! promptly discharge any lied which has priority over this Security Instrument unless Harrower (a) Wm in writing to the payment of the obligation secured by *a lint in a manner acceptable to Lender, but only so long as Borrower is performing such agreement; (b) contests the lien in good faith by, or dcfeads sgainat enforcement of the lien in, legal procoedings which in Leaded a opinion operate to prevntt the enboreeement of the lien while those proceedings ace penning,' but only until such proceedings are concluded; or (c) aec vas from the holder of the lien an agreement satisfactory to Linder subordinating the lien to this Security Instrument. If I,eoder determines that any part of the Property is subject to a lien which can attain priority over this Serenity Instrument, Leader may give Borrower a notice identifying the lien. Within 10 days of the date on which that notice is given, Borrower shall ad* the lien or take one or more of the actions set forth above in this Section 4. Leader may require Borrower to pay a one-time charge for a real estate tax verification and/or reporting service used by Lander in connection with this Loan. 5. Property Inca wwL Borrower shall keep the improvements now ousting or hereafter erected on the Property insured agautst loss by fire, hazards included within the tam Ocamded ooverage,M and any other hazards iachudiag, but not limited to, earthquakes and floods, for which LAmder requires insuraaca This insurance aha11 be maimaiaed in the amounts (including deductible levels) and for the periods that Lender requires. What Lender re pu= pursuant to the preceding sentences can ehamge during die term of the Loan. The insurance carrier providing the umranee shall be chosen by Borrower subject to Leader a right to disapprove Borrower's choice, which right shall not be atercised unreasonably. Leader may require Borrower to pay, in connection with this Loan, either. (a) a one-time charge for flood zone determination, certification and tracking services; or (b) a one-time charge for flood zone determination and cartific at m services and subsequent charges each time remappings or similar changes occur which reasonably might affect such deitermination or cer ificatiom Borrower shall also be responsible for the payment of any fee imposed by the Federal Emergency Management Agency in connection with the review of any flood zone determination resulting fivm an objection by Borrower. 1090922 e,r J `F- a-aAtPAl roseslo, h"Gm d 16 Form 3039 1101 0 R. ..,...: _..., If Borrower fuuu7s to maintain of the .`• any coverages described above, Lender may obtain insurance ooverag. at Lenders option and Borrower's expense, header is under no obligation to purchase say juticular type or secant of oovaaSa Tie, such coverage shall cover Leader, but might or might not protect Harrower. Borrowds equity in the Property, or the contents of the Property, against any risk, hazard or liability and might provide greater or lesser coverage than was previously in effect. Borrower acknowledges that the cost of the insurance coverage so obtained might significantly exceed the cost of insurrsuce that Borrower could have obtained. Any amounts disbursed by Leader under this Section 5 shall become additional debt of Borrower aewred by this Security Instru meaL These amounts shall bear interest at the Note rate from the data of disbursement and shall be payable, with such interest, upon notice from Lender to Borrower requesting payment. All insurance policies required by Leader and renewals of such policies shall be subject to Lenders right to disapprove such policies, shall include a.standard mortgage clause, and shall name Deader as mortgagee and/or as an additional loss payee. Leader shall have the right to hold the policies and renewal certificates. If Leader requires, Borrower shall promptly give to Lender all receipts of paid premiums and renewal notices. If Borrower obtains any form of insurance coverage, not otherwise required by Leader, for damage to, or destanction 04 the Property, such Policy shall i In& a standard mortgage clause and shall name Lender as mortgagee and/or as an additional loan payee. • In the event of loss, Borrower shall give prompt notice to the insurance carrier and Leader. Leader may maim proof of loss if not made promptly by Borrower. Unless Lender and Borrower otherwise agree. in whiting, any insuramoe proceeds, .whether or not the underlying insurance was required by L wider, shall be applied to region or repair of the Property, if the restoration or repair is economically feasble and Lender 6 security is not lessened. During such repair and restoration period, Lender shall have the right to hold Such insurance Proceeds until Lender has had 'an opportunity to inspect such Property to ensure the work has been completed to Lender, s nuafae bon, provided that such mspccbon ahall be undertol= 1Y• Lender may disburse proceeds for the repairs and restoration in a single payment or in a envies of progress payments w the work is completed. Unless an agreement is made in writing or Applicable Law requires interest to be paid on such ias trance proceeds, Leader shall not be required to pay Borrower any interest or turnings on such proceeds, Fees for public adjusters, or other third parries, retained by Borrower shall not be paid out of the insurance proceeds and shall be the sole obligation, of Borrower. If the restoration or requair is, not econonricxrlly feasible or Leader's security world be lessened, the insurance proceeds shall be applied to the sums secured by this Security Ineatmeat, whether or not them due, with the excess, if any, paid to Borrower. Seech immnm prooeedS shall due applied in the order provided for in Section 2. ' If Borrower abandons the Property. Lender may file, negotiate and settle any available. insuraonce claim and related matters. If Borrower does not respond within 30 days to a notice from Lender that the insurance carrier has offcred to settle a claim, then Leader may negotiate and settle the claim. The 30-day period will begin when the notice is given. In either event, or if Laeder acquires the property under Section 22 or otherwise, Borrower hereby assigns to Linder (a) Borrowers rights to nay insurance proceeds in an amount not to exceed the amounts unpaid under the Note or this Security Instrumen% and (b) any other of Borrowe e s rights (other than the right to any refund of unearned premiums paid by Borrower) under all insurance policies covering the property, insofar as such rights are applicable to the coverage of the Propcty. I ender may use the mwranex proceeds either to repair or restore the Property or to Pay amounts unpaid under the Note or this Security instrument, whether or not then due. 1090922 4%-$A(PA) psost oi ?.?a?s Form 3039 1101 • Wilk ,,?<. •.. •...•6. Ooarpanry. Borrower stall occupy, establish, and use the Property as Borrower's primal """' residence within 60 days after the execution of this Security Imt uament and. shall continue to occupy the Property as Borrowers principal residence for st least one year after the date of occupancy, unless Leader otherwise agrees in writing, which consent shall not be unreasonably withheld, or unless extenuating circumstances and which are beyond Borrrorowee a control 7. Preservation, Maintenance and Proftedon of the Property; Inspections. Borrower shall not destroy, damage or impair the Property, allow the Property to deteriorate or commit waste on the Property. Whether or not Borrower is residing in the Property, Borrower shall maintain the Property in order to prevent the Property from deteriorating or decreasing -in value due to its condition. Unless it is determined pursuant to Section 5 that repair or restoration is not economically fessible, Borrower shall Promptly repair the Property if damaged to avoid further deterioration or damages If insurance or condemnation proceeds are paid in connection with damage to, or the taking of, the property, Borrower shall be re sponabble for repairing or restoring tin Property only if Lunde has released proceeds for such purposes. Leader may disburse proceeds for the repairs and restoration in a single payment or in a series of progress payments as the work is. completed. If the insurance or condemnation proceeds are not sufficient to repair or restore the Property. Borrower is not relieved of Borrower's obligation for the completion of such repair or restoration Leader or its agent may make reasonable .=tries upon sad imperious of the Property. if it has reasonable cearse3, Lender may inspect the interior of the improvements on the Property. Lender shall give. Bormwer notice at the rummer of or prior to such an interior inspection specifying such reasonable curse: 8. Borrowers Loan AppUmdon. Borrower shall be in detwit IC during the Loan application process, Borrower or any persons or entities acting at the direction of Borrower or with Borrower: s knowledge or consent gave materially'f bas misleading, or insomrate information or statements to Lender (or failed to provide Lender with material information) in connexion with the Loan. Material rgrwentatiuns include, but are not limited to, representations concerning Borrowers occupancy of the . Property as Borr ower's xmcdpat residence. 9. Protection of Lender's Interest in the Property and Rights Under this Security Instrarneet U (a) Bormwcr oils to perform the eovrasnts and agreements contained in this Security Instrument, (b) theme is a legal proceeding that might significantly' affect Lender s interest in the Property and/or rights under this Security Inatrerme ut (such as a proceeding in bmknqftT, probate:, for condemnation or forfeiture, for . eafor+oement of alien which may attain priority over this Security Instrument or to enforce laws or regulations), or (c) Borrower has abandoned the.Property, then-Lender may do and pay for whatever-is reasonable oi• appropriate to protect Lenders interest is the Property and rights under this Security Instrument, including protecting and/or assessing the value of the Property, and securing and/or repairing the Property. Lender's actions can include, but are not limited to: (a) Paying any sums secured by a lien which has priority over this Security Instrument; (b) appearing in eom t; and (c) paying reasonable attorneys' foes to protect its interest in the Property and/or rights under this Security Instrument, including its seeued position in a bankruptcy proceeding. Securing the Property includes, but is not limited to, entering the Property to make repairs, change Iodcs, replace or board up doors and windows, drum water from pipes, elimmate building or other code violations or dangerous conditions, and have utilities toraed .on or off. Althumgh Leader may take action under this Section 9, Leader does not have to do so and is not under any ditty or obliption to do so. It is agreed that Leader incur no liability for not taking any or all actions anthorized under this Section 9. 1090922 eaarr 4ft$A(PA)c0ssn8t a v.s of is Foray 3039 110t • • _._Any amounts disbursed by Leader under this Section 9 shall become additional debt of Borrower ? - secured by this Security Instrument. These -can shall bear interest at the Note rate fionr the date of disbursement and shall be payable, with-each interest, upon notice from Lender to Borrower requesting payer If this Security Instrument is on a leasehold, Borrower shall.co mply with all the provisions of the lease. If Borrower acquires foe title to the Property, the leasehold and the fee title shall not merge unless Leader agrees to the merger in writing. 10. Mortgage Insurance. If Leader required Mortgage Insurance as a condition of making the Loan, Borrower shall pay the premiums required to maintain the Mortgage Insurance in effect. It for any reason, ` elm Mortgage Insurance coverage required by Lender ceases to be available fiom the mortgage insurer that previously provided such insurance, and Borrower was required to make separately designated payments toward the premiums for Mortgage Insurance, Borrower shall pay the premiums required to obtain coverage substantially equivalent to the Mortgage Insurance previously in of em at a cost substantially equivalent to the cost to Borrower of the Mortgage Inacuaaoe prmously in effaect, from an alternate mortgage insurer seecW by Leader. If substantially equivalent Mortgage Insurance coverage is not available, Borrower shall continue to pay to I.eoder the amount of the separately designated payments that were due when the iastuanco coverage ceased to be in effect Leader will accept, use and retain these payments as a name-re6indable loss reserve in lieu of Mortgage Insurastm Such loss reserve shall be non-ref+naable, notwitl nd ng the fact that the LA= is ultimately paid in fuel, and Leader " not be required to pay Borrower any interest or earnings on such loss reserve. I ender can no longer require leas reserve paymeuta if Mortgage Insurance coverage (in the amount and for the period that Lander requires) provided by an insurer selected by Lender again becomes available, is . obtained, and Lander requires separately designated payments toward the premiums for Mortgage Iosuanoe. If Lender required Mortgage Im mw6 as a condition of making the Loan and Borrower was required to make designated payments toward the premiums for Mortgage Insurance, Borrower shall pay the promiums required to maintain Mortgage Insurance in effect, or to provide a non-refundable loss reserve, until taad& a requirement fit Mortgage Imrua = ends in accordance with my written agreement between Borrower and I an providing for such termination or until termination is required by Applicable Law. Nothing in this Section 10 affects Borrower' a obligation to pay interest at the rate provided in the Note. Mortgage Insuaaco reimburses Lender (or my entity that purchases the Note) for certain losses it may mcur if Borrower does. not repay the Loan as agreed. Borrower is not a party to the Mortgage Insurance. Mortgage insurers evaluate their total risk on all arch insurance in force from time to time, and may enter into agreements with other pectins that share or modify their risk, or reduce losses. These ggteemem are on terms and conditions that are satisfactory to the mortgage insurer and the other party (or parties) to these agreements. These agraanrnts may require the mortgage issuer to make payments using any source of finds that the mortgage insurer may have available (which may include brads obtained fium Mortgage Insurance premiums). As a result of these agreements, Lender, any purchaser of the Note, another kroner, any refnsrer, any other entity, or any affiliate of any of the foregoing, may receive (directly or indirectly) amounts that derive from (or might be chaeaetu mod as) a portion of Borrower's payments for Mortgage Insurance, in atchange far sharing or modifying the mortgage iaauree s risk or reducing losses. If such agreement provides that an affiliate of Lender talon a share of the insurer's risk in exc hop for a share of the premiums paid to the insurer, the arrangement is often termed "captive reinsurance." Further: (a) Any such agreements wBl not affect the amounts that Borrower has agreed to pay for Mortgage Insurance, or any other trans of the loan. Such apeements will not hwrewe the amount Borrower will owe for Mortgage Lance, and they will not a udde Borrower to any redone. 1090922 10, JP Qj-6A(PA)e0504p1 Paget a is Foray 3039 1101 VERIFICATION Kimberly A. Bonner, Esquire hereby states that she is attorney for PLAINTIFF in this matter, that Plaintiff is outside the jurisdiction of the court and or the Verification-could not be obtained within the time allowed for the filing of the pleading, that he is authorized to make this verification pursuant to Pa. R. C. P. 1024 (c) and that the statements made in the foregoing pleading in the Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of his knowledge, information and belief. Furthermore, it is the undersigned's intention to substitute a verification from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unworn falsification to authoritie Kimberly A. Bonner, Esquire ??? PA I.D..#89705 Dated: O v C-S) 2009 ,mill 18 Fri 1: 01 VA. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. Bank National Association, as trustee, on CIVIL DIVISION behalf of the holders of the Home Equity Asset Trust 2007-2 Home Equity Pass-Through NO.: 09-4158 Certificates, Series 2007-2 , Plaintiff, vs. Joni M. Raudabaugh Defendants. PRAECIPE TO SUBSTITUTE VERIFICATION PURSUANT TO PaR.C.P. 1024(c) To the Prothonotary: Please substitute the Verification of Counsel attached to Plaintiff's Complaint in the above captioned-matter with the attached Verification of Plaintiff . ZUCKER BERG & ACKERMAN, LLC BY: Dated: July 1, 2009 Scott . Dietterick, Es ' e; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Eric Santos, Esquire; PA I.D. #201493 Joel A. Ackerman, Esquire; PA I.D. #202729 Attorneys for Plaintiff FCP-124952/ad 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Zucker, Goldberg & Ackerman, LLC FCP-124952 VERIFICATION MERLOBEL CU&TOW j MOCUMent Control Of%W (title), depose and say subject to the penalties of 18 Pa.C.S.A., sec. 4904 relating to unsworn falsification to authorities that the facts set forth in the foregoing pleading are true and correct to the best of my information, knowledge and belief. By: Select Portfoli Servicing, Inc. Name: " Title: MERLOBEL CUSIT Cl AIACUfnent Co" OOMW Zucker, Goldberg & Ackerman, LLC F CP-124952 FILE 2009 JUL ' 6 t2. 12 CU,4 ,ia. F Al Sheriffs Office of Cumberland County R Thomas Kline Sher yatp at cuipbc Ronny R Anderson Chi D t go ` ef epu y Jody S Smith Civil Process Sergeant CE 'Q` "'s $"ERicF Edward L Schorpp Solicitor US Bank National Association vs. Joni M. Raudabaugh Case Number 2009-4158 SHERIFF'S RETURN OF SERVICE 07/07/2009 06:30 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on July 7, 2009 at 1830 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Joni M. Raudabaugh, by making known unto Rick Brehm, Husband of defendant at 800 Upland Street Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $46.00 July 08, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF De ty Sheriff- C7 r-3 C? r r? -rt 110 _r_ ? 7F' '- -- M f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE, ON BEHALF OF THE HOLDERS OF THE HOME EQUITY ASSET TRUST 2007-2 HOME EQUITY PASS-THROUGH CERTIFICATES, SERIES 2007-2 , Plaintiff, vs. Joni M. Raudabaugh CIVIL DIVISION NO.: 09-4158 Sheriff Sale #: TYPE OF PLEADING Pa. R.C.P. RULE 3129.2(C) AFFIDAVIT OF SERVICE OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST Defendants. CODE: FILED ON BEHALF OF: U.S. Bank National Association, as trustee on behalf of the holders of the Home Equit Asset Trust 2007-2 Home Equity Pass-Through Certificates, Series 2007-2 COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire PA I.D. #55650 Kimberly A. Bonner, Esquire- PA I.D. #89705 Joel A. Ackerman, Esquire- PA I.D. #202729 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 (908) 233-8500 (908) 233-1390 FAX office(a~zucker olg doerg com File No.: FCP- 124952/ml Zucker, Goldberg & Ackerman, LLC FCP-124952 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. BANK NATIONAL ASSOCIATION, AS CIVIL DIVISION TRUSTEE, ON BEHALF OF THE HOLDERS OF THE HOME EQUITY ASSET TRUST NO.: 09-4158 2007-2 HOME EQUITY PASS-THROUGH CERTIFICATES, SERIES 2007-2 , Plaintiff, vs. Joni M. Raudabaugh Defendant. Pa.R.C.P. RULE 3129(c) AFFIDAVIT OF SERVICE OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST I, Marie Lindner, a paralegal with the firm of Zucker, Goldberg & Ackerman, LLC, attorneys for Plaintiff, U.S. Bank National Association, as trustee, on behalf of the holders of the Home Equity Asset Trust 2007-2 Home Equity Pass-Through Certificates, Series 2007-2 ,being duly sworn according to law depose and make the following Affidavit regarding the service of Plaintiff's Notice of Sheriff's Sale of Real Property in this matter on Defendant/Owner and Other Parties of Interest as follows: 1. Defendant, Joni M. Raudabaugh, is the record owner of the real property. 2. On or about 9/28/09, Joni M. Raudabaugh, was served with Plaintiff's Notice of Sheriffs Sale of Real Property Pursuant to Pa. R.C.P. 3129, personally by the Sheriff of Cumberland County, at the address of the mortgaged premises, being 800 Upland Street, Mechanicsburg PA 17055. A true and correct copy of said Notice and Return of Service are marked Exhibit "A", attached hereto and made a part hereof. 3. On or about 10/23/09, Plaintiff s counsel served all other parties in interest with Plaintiff s Notice of Sheriff's Sale according to Plaintiff s Affidavit Pursuant to rule 3129.1, via First Class U.S. Mail, Postage Pre-Paid, with a Certificate of Mailing. True and correct copies of Zucker, Goldberg & Ackerman, LLC FCP-124952 said Notices and Certificates of Mailing are marked Exhibit "B", attached hereto and made a part hereof. Finally, the undersigned deposes and says that the Defendant/Owner and all other Parties of Interest were served with Plaintiffls Notice of Sheriff's Sale of Real Property in accordance with Pa.R.C.P. 3129.2. ZUCKER, GOLDBERG & ACKERMAN, LLC Attorneys for Plaintiff Dated: November 13, 2009 µF MARIE LINDNE Paralegal/Legal Assistant Sworn to an~bs~ribe~i before day otary MY COMMIS Gamaltefte Geffrard A NOTARY PUBLIC OF NEW JERSEY My commision Expires on 9/26J2013 Zucker, Goldberg & Ackerman, LLC FCP-124952 .•e i ~C . {,,7,~.... . ., ;:tip {isr'•~..i<°T :flb.fJ 'ti-^i EXHIBIT A Zucker, Goldberg & Ackerman, LLC FCP-124952 Sheriff s Office of Cumberland County R'fhoraas Kline Sheriff' ttitr ~t tr'srutiir.~~ Ronny R Anderson ~~~ y~ft~ Chief Deputy ~ ~ '` ~~4 iY~, a'~': Jody S Smith `- ' <' Civil Process Sergeant ~~a"~` or rr~M ~-~~~€ Rdward L Schorpp Solicitor US Bank National Association vs. Joni M. Raudabaugh SHERIFF'S RETURN OF SERVICE Case Number 2009-4158 09/28/2009 05:58 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on 09-28-09 at 9758 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Joni M. Raudabaugh, located at 800 Upland S#reet, Mechanicsburg, Cumberland County, Pennsylvania according to faw. 09/28!2009 05:58 PM - Naah Cline, Deputy Sheriff, who being duly sworn according to law, states that on 09-28-09 at 1758 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Joni M. Raudabaugh, by making known unto, Jon M. Raudabaugh, personally, of 800 Upland Street, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personalty the said true and correct copy of the same. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. BANK NATIONAL ASSOCIATION, A~ TRUSTEE, CIVIL DIVISION ON BEHALF OF THE HOLDERS OF THE HOME EQUITY ASSET TRUST 2007-2 HOME EQUITY PASS-THROUGH NO.: 09-4158 CERTIFICATES, SERIES 2007-2, . Plaintiff, vs. Toni M. Raudabaugh , Defendant. NOTICE OF SHERIFF'S SALE . OF REAL, PROPERTY PURSUANT TO PENNSYLVANIA RULE OF UVIL PROCEDURE,~129 Joni M. Raudabaugh . 800 Upland Street 7160 X901 9x48 4.22 +317~iJ Mechanicsburg, PA 17055 s _ ~ ~ a TAKE NOTICE: ;':. That the Sheriff 5 Sale of Reai Property (Real Estate} will be held at the Cumberland County Courthouse, l Courthouse Square, Carlisle, PA 17013 on 12/09/2009 at 10:OOam prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. {SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"}. The LOCATION of your property to be sold is: 800 Upland Street, Mechanicsburg, PA, 17055 The JUDGMENT under ar pursuant to which your property is being sold is docketed to: No. 09-158 THE NAMES} OF THE OWNER(S) OR REPUTED OWNERS} OF THIS PROPERTY ARE: :~ : - -Joni M. Raudabaugh Zucker, Goldberg & Ackerman, LLC FC:P-124952 A SCHEDULE OF D15TRIBUTION, being a list of the persons and/or governmental or corporate entitles or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of the proceeds of sale in accordanceswith this schedule will, in fact, be made unless someone objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Cammon Pleas of Cumberland County, One Courthouse Square, Carlisle, PA 17013-3387. THIS PAPER IS A NOTICE OF~THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY G'. It has been issued because there is a Judgment against you. It may cause your property to beheld, to be sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act.promptly. YOU SHOULD TAKE TH15 PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE lawyer Referral Service of the Cumberland County Bar Assoaatian Cumberland County Sar Association 32 S. Bedford Street r•~. Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE• 1. You may file a petition with the Court of Common Pleas of Cumberland County to open thb'Judgmen# if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal detect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price orforother proper cause. This petition must be filed before the Sheriffs Deed is delivered. S Zucker, Goldberg & Ackerman, LLC FCP-124952 3. A petition or petitions raising the legal issues or rights mentioned In the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or vn the creditor before presentation to the Court and a proposed order or ruse must be attached to the petition. if a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courtl~puse Square, Carlisle, PA 17013- 3387, before presentation of ~~ pe;Ition ~ Court. AN, I.LC Dated: August 7, 2009 BY: ~ ~,] "~ Scott ietteric c, sq PA I.D. #55fi50 Kimbe A. Bonner, Esquire; PA.I.D. #89705 Eric Santos, Esquire; PA I.D. #201493 Joei A. Ackerman, Esquire; PA I.D. #202729 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 Ffle No.: FCP-124952 {908) 233-8500; (908) 233-1390 FAX VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. Zucker, Goldberg & Ackerman, LLC FCP-124952 Exhfblt "A" LEGAL DESCRIPTION ALL THOSE CERTAIN LOTS OR PARCELS OF GROUND SITUATE IN LOWER ALLEN TOWNSHIP, GUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE WESTERN LINE OF UPLAND STREET, SAID POINT BEING AT THE NORTHEAST CORNER OF LOT NO. 1, BLOCK "J' ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG THE WESTERN LINE OF UPLAND STREET SOUTH TWENTY-ONE (21) DEGREES THIRTY (30) MINUTES EAST A DISTANCE OF SEVENTY-FIVE (75) FEET TO A POMT ON THE DIVIDING LINE BETWEEN LOTS NO.3 AND 4, BLOCK "J", ON THE HEREINAFTER MENTIONED PLAN QF LOTS; THENCE ALONG THE DIVIDING LINE BETWEEN LOTS N0.3 AND 4, SOUTH SIXTY-EIGHT (68}DEGREES THIRTY-EIGHT (38} MINUTES WEST ONE HUNDRED SDC AND FIFTYSIX(106.56) ONE-HUNDREDTH FEET TO A POINT THENCE NORTH TWENTY-TWO (22} DEGREES THIRTY (30) MINUTES WEST A DISTANCE OF SEVENTY-FIVE (75) FEET TO A POINT AT THE NORTHWEST CORNER.OF LOT NO, 1, BLOCK "T' ON THE HEREINAFTER MENTIONED PLAN OF LOTS: THENCE ALONG THE SOUTHERN LIN>a OF LINDEN AVENUE (UNOPENED) NORTH SDCTY-EIGHT (68} DEGREES THIRTY (30) MINITTES EAST A DISTANCE OF ONE HUNDRED SEVEN AND EIGHTY-SEVEN ONE-HUNDREDTHS (107.87} FEET TO A POINT, THE PLACE OF BEGDVNING. BEING LOTS NO. I, 2 AND 3, BLOCK "J", OF THE PLAN OF LOTS OF HARRISBURG MANOR, LOCATED IN LOWER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA IS SURVEYED BY A. B. RUPP, C. E. OF MACHANICSBURG, PENNSYLVANIA AND PLOTTED BY WILLIAM MCCORMICK OF PHILADELPHIA, PENNSYLVANIA, SAID MAP OR PLAN HAS BEEN FILED ON RECORD WITH THE RECORDER OF DEEDS OFFICE FOR CUMBERLAND COUNTY ON AUGUST 14, 1925 IN PLAN BOOK 2, PAGE 50. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AT~D NUMBERED AS 800 UPLAND STREET, MECHANICSBURG, PA, 17055. BEING THE SAME PREMISES WHICH JOHN R KENNEDY AND DORIS J. KENNEDY, BY DEED DATED NOVEMBEh 14, 2006 AND RECORDED NOVEMBER 22, 2006 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 277, PAGE 3533, GRANTED AND CONVEYED UNTO JONI M. RAUDABAUGH, SINGLE. TAX MAP NO.: 13-24-0795-OIS. :7 ~. Zucker, Goldberg 8c Ackerman, LLC FCP-124952 EXHIBIT B Zucker, Goldberg & Ackerman, LLC FCP-124952 U~tT~D ST/1FES o~P~~q~ 7 ®ias. DfrNEY BOVyEg 'I'bis Certificate of Mailing p`ovida evidence thu mail has been proeented m IJSPS6 for 0 2 1 hq $ O ~ ~ o0 andintemationalmail. ~ 0004282036 OCT23 2009 Frem: SCOtt A. Dietterick, Esquire MAILED FROM ZIPCODE 07092 c/o Zucker, Goldberg & Ackerman, L ., 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 FCP-124952/jde T°~ MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR EQUIFIRST CORPORATION P.O.2026, FLINT MI 48501 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000.9065 .. L1~1[I.TE~~~.~1F~S fTl~Lr.,~~~1~l~f This Certifiate of Mu7ing pmvida evidww that mail has been p7etemed to USPS~ for mailing. Thi S and intemationd mail. Ftom: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 FCP-124952/jde ~"' EQUIFIRST CORPORATION 500 FOREST POINT CIRCLE CHARLOTTE, NC 28273 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 Postmark Here 0'~P~ ~p~ ~a • ~~ 0 04282036 OCOT 23 20 g MAILED FROM ZIP CODE 07092 r, .3 ~~~ ~~ i ~ ~ ~~ Page 1 of 4 Y g~A~ ~T `2t` 'C 4~0. `~ e !~A~IJ~ 7 ®rtrut¢r ewvEs U~lTE~ S~/~T~:~ 02 ~M ~ 01.10° . 0004282036 OCT23 2009 1~C~S7J~L ~,€I~V~CE~ Mq~LED FROM ZIPCODE 07092 This Certificate of Meiling provides evidence that mail has been presented to I7SP5® for maili~. 7 and international mail. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 FCP-124952i)de T°' CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 ~9~sT _ ~ ~~ . ~ i~~ll TES ~7~T'~~.. ~ ~ o~'~„~,E,t ~ . z ®- - ffi,~~ S~/l a ~ 01'~~0° -- -- 02 1M OGT 23 2009 This Certifiate ofMailing provides evidence waz tttsil hss been praseo[ad b USPS6 for maihag. Th~ 000 428203 6 ZIP GoDE 0 7 092 and intemationel mail. MAID F~jONII Brom: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 FCP-124952rde T°` COMMONWEALTH OF PENNSYI..VANIA Postmark ~~i~~E~~(3~ DEPARTMENT OF WELFARE ~~~~~' P.O. Box 2675 Harrisburg, PA 17105 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 0~~ 2 ~ 2i~09 Page 2 of 4 UANTED SThTES ~~osr~c s~~vrc~ y~~ ~rq ~® ~ l ~® ~ ® gTNEV BOVYES oz ,M $01.10° 0004282036 OCT23 2009 MAILED FROM 21PGODE 07092 This Certigcete of Mailing provides evidence that mail has ban preunted to USPS®Car mai. and intonational mail. P'°"` Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 FCP-124952rde ~°~ CUMBERLAND COUNTY DOMESTIC RELATIONS P°st~k OFFICE /w~ Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 County of P.Q.: CUMBERLAND PS Form 3817, Apri12007 PSN 7530-02-0OOA065 L~l1~lTEDS7,/~T~S ~'~~F~L ~~1Ci This Cettifieste of Mailing provides evidence abet mail has been preeeMnd to USPS® for mailing and international mail. Pre"` Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 301 .~ P0.ST g~ ~~~ • ~ ~~..+~~t 1 ~ 1M ~~T~3 2009 ti .0004282036 ZIPG~E Oi092 MAILED FROM Mountainside, NJ 07092 FCP-124952rde T°` PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION P°~`'` Dept. 280601 Harrisburg, PA 17128-0601 County of P.Q.: CUMBERLAND PS Form 3817, Apri12007 PSN 7530-02-000-9065 Page 3 of 4 /STE T D ~ ' T S UNl E ~ s 10° ~ 01 AUST~L 3ER1~lC~ . ~ 0 2 , M { 000428203& OCT 23 2009 Thia Certificate of Meiling pr°vides evide~ that mail has been prexnted w USPS® form MAILED FROM ZIP CODE 0 7 0 9 2 a~ international mail. F'°m` Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 FCP-124952/jde T°` UNKNOWN TENANT OR TENANTS 800 Upland Street Mechanicsburg, PA 17055 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 i1~~TED~Sl~~`~.S t~+t~~T~L 5~`R~~~~ 17da Certificate of Maigng pmvidea evideaca that mail has been presorted m USPS®Gu mailing. Thia h' and imemational mail. F'°'n` Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 301 PostmaFlff~era.: ..~_ ~ . v „ .~ ^ ~ ti ~:,: ti {, .'s l.E~~ ~:~1.,' ~frS ~T :~a~~~~o - ~ ~ 01.10 ~ 0004282038 dCY 23 2009 • +~ MptLEDFROMZIPGODE 07092 Mountainside, NJ 07092 FCP-I24452/jde '~` UNKNOWN SPOUSE 800 Upland Street Mechanicsburg, PA 17055 County of P.Q.: CUMBERLAND Ps Form 3817, April 2007 PSN 7530-02-000-9065 ~v~-~~ Page 4 of 4 s ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE, ON BEHALF OF THE HOLDERS OF THE HOME EQUITY ASSET TRUST 2007-2 HOME EQUITY PASS-THROUGH CERTIFICATES, SERIES 2007-2 , Plaintiff, vs. Joni M. Raudabaugh Defendant. CIVIL DIVISION NO.: 09-4158 NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C.P. 3129(b) TO: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 UNKNOWN SPOUSE 800 Upland Street Mechanicsburg, PA 17055 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 UNKNOWN TENANT OR TENANTS 800 Upland Street Mechanicsburg, PA 17055 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR EQUIFIRST CORPORATION P.O. 2026, FLINT MI 48501 PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 EQUIFIRST CORPORATION 500 FOREST POINT CIRCLE CHARLOTTE, NC 28273 Zucker, Goldberg & Ackerman, LLC FCP-124952 124952D 1004C 10222009P 1 ~~ TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in: the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 On 12/09/2009 at 10:00am, the following described real estate which Joni M. Raudabaugh, single are the owners or reputed owners and on which you may hold a lien or have an interest which could be affected by the sale of: 800 Upland Street, Mechanicsburg, PA 17055 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A") Zucker, Goldberg & Ackerman, LLC FCP-124952 124952D1004C10222009P2 ~~ ~ The said Writ of Execution has been issued on a judgment in the action of U.S. Bank National Association, as trustee, on behalf of the holders of the Home Equity Asset Trust 2007-2 Home Equity Pass-Through Certificates, Series 2007-2 Plaintiff vs. Joni M. Raudabaugh, et al Defendant(s) at EX. NO. 09-4158 in the amount of $128079.43 plus interest and costs. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from the sale date. Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. If you have any questions or comments with regard to the Sheriffs Sale or this Notice, you should contact your attorney as soon as possible. ZUCK ER G QLDB ERG & ACK ERIVIAN LLC Dated: October 22, 2009 By: Scott A. Dietterick, Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 File No.: FCP-124952 (908) 233-8500; (908) 233-1390 FAX Zucker, Goldberg & Ackerman, LLC FCP-124952 124952D1004C10222009P3 + -. Exhibit "A" LEGAL DESCRIPTION ALL THOSE CERTAIN LOTS OR PARCELS OF GROUND SITUATE IN LOWER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE WESTERN LINE OF UPLAND STREET, SAID POINT BEING AT THE NORTHEAST CORNER OF LOT NO. 1, BLOCK "J' ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG THE WESTERN LINE OF UPLAND STREET SOUTH TWENTY-ONE (21) DEGREES THIRTY (30) MINUTES EAST A DISTANCE OF SEVENTY-FIVE (75) FEET TO A POINT ON THE DIVIDING LINE BETWEEN LOTS NO. 3 AND 4, BLOCK "J", ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG THE DIVIDING LINE BETWEEN LOTS NO. 3 AND 4, SOUTH SIXTY- EIGHT (68) DEGREES THIRTY-EIGHT (38) MINUTES WEST ONE HUNDRED SIX AND FIFTYSIX(106.56) ONE-HUNDREDTH FEET TO A POINT THENCE NORTH TWENTY-TWO (22) DEGREES THIRTY (30) MINUTES WEST A DISTANCE OF SEVENTY-FIVE (75) FEET TO A POINT AT THE NORTHWEST CORNER OF LOT NO, 1. BLOCK "J" ON THE HEREINAFTER MENTIONED PLAN OF LOTS: THENCE ALONG THE SOUTHERN LINE OF LINDEN AVENUE (UNOPENED) NORTH SIXTY-EIGHT (68) DEGREES THIRTY (30) MINUTES EAST A DISTANCE OF ONE HUNDRED SEVEN AND EIGHTY-SEVEN ONE-HUNDREDTHS (107.87) FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOTS NO. 1, 2 AND 3, BLOCK "J", OF THE PLAN OF LOTS OF HARRISBURG MANOR, LOCATED IN LOWER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA IS SURVEYED BY A. B. RUPP, C. E. OF MACHANICSBURG, PENNSYLVANIA AND PLOTTED BY WILLIAM MCCORMICK OF PHILADELPHIA, PENNSYLVANIA, SAID MAP OR PLAN HAS BEEN FILED ON RECORD WITH THE RECORDER OF DEEDS OFFICE FOR CUMBERLAND COUNTY ON AUGUST 14, 1925 IN PLAN BOOK 2, PAGE 50. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 800 UPLAND STREET, MECHANICSBURG, PA, 17055. BEING THE SAME PREMISES WHICH JOHN R. KENNEDY AND DORIS J. KENNEDY, BY DEED DATED NOVEMBER 14, 2006 AND RECORDED NOVEMBER 22, 2006 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 277, PAGE 3533, GRANTED AND CONVEYED UNTO JONI M. RAUDABAUGH, SINGLE. TAX MAP NO.: 13-24-0795-015. Zucker, Goldberg & Ackerman, LLC FCP-124952 124952D1004C10222009P4 Y Ir` :- . ~rY ~~~~; r ,. ~-~~ .- , . ~;_ - ~, ,. , ~~; ~? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV~IIA ~_.;'' U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE, CIVIL DIVISION ON BEHALF OF THE HOLDERS OF THE HOME EQUITY ASSET TRUST 2007-2 HOME EQUITY PASS- NO.: 09-4158 THROUGH CERTIFICATES, SERIES 2007-2 , Sheriff Sale #: °: Plaintiff, vs. Joni M. Raudabaugh TYPE OF PLEADING N ;...~ -n C ~ -n u '~ - r.`~ W -~ -o -~~~ -. S `.:,~~ Pa. R.C.P. RULE 3129.2(C) AFFIDAVIT OF SERVICE OF DEFENDANT/OWNER AND Defendants. OTHER PARTIES OF INTEREST CODE: FILED ON BEHALF OF: U.S. Bank National Association as trustee on behalf of the holders of the Home Eauitv Asset Trust 2007- 2 Home EQUity Pass-Throush Certificates Series 2007-2 COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire PA t.D. #55650 Kimberly A. Bonner, Esquire- PA I.D. #89705 Joel A. Ackerman, Esquire- PA I.D. #202729 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 (908) 233-8500 (908)233-1390 FAX officeC~zucker~oldbere.com File No.: FCP-124952/ml Zucker, Goldberg & Ackerman, LLC FCP-124952 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE, CIVIL DIVISION ON BEHALF OF THE HOLDERS OF THE HOME EQUITY ASSET TRUST 2007-2 HOME EQUITY PASS-THROUGH NO.: 09-4158 CERTIFICATES, SERIES 2007-2 , . Plaintiff, vs. Joni M. Raudabaugh Defendant. Pa.R.C.P. RULE 3129(c) AFFIDAVIT OF SERVICE OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST I, Marie Lindner, a paralegal with the firm of Zucker, Goldberg & Ackerman, LLC, attorneys for Plaintiff, U.S. Bank National Association, as trustee, on behalf of the holders of the Home Equity Asset Trust 2007-2 Home Equity Pass-Through Certificates, Series 2007-2 ,being duly sworn according to law depose and make the following Affidavit regarding the service of PlaintifYs Notice of Sheriffs Sale of Real Property in this matter on Defendant/Owner and Other Parties of Interest as follows: 1. Defendant, Joni M. Raudabaugh, is the record owner of the real property. 2. On or about 6/26/10, Joni M. Raudabaugh, was served with Plaintiffs Notice of Sheriff's Sale of Real Property Pursuant to Pa. R.C.P. 3129, personally by the Sheriff of Cumberland County, at the address of the mortgaged premises, being 800 Upland Street, Mechanicsburg PA 17055. A true and correct copy of said Notice and Return of Service are marked Exhibit "A", attached hereto and made a part hereof. 3. On or about 4/23/10, Plaintiffs counsel served all other parties in interest with Plaintiffs Notice of Sheriff's Sale according to Plaintiff's Affidavit Pursuant to rule 3129.1, via First Class U.S. Mail, Postage Pre-Paid, with a Certificate of Mailing. True and correct copies of said Notices and Certificates of Mailing are marked Exhibit "B", attached hereto and made a part hereof. Zucker, Goldberg & Ackerman, LLC FCP-124952 Finally, the undersigned deposes and says that the Defendant/Owner and all other Parties of Interest were served with Plaintiff's Notice of SherifYs Sale of Real Property in accordance with Pa.R.C.P. 3129.2. ZUCKER, GOLDBERG & ACKERMAN, LLC Attorneys for Plaintiff Dated: August 2, 2010 ...--- MARIE LI DNER Paralegal/Legal Assistant Sworn to and subscribed before me this 2nd day of August, 2010 otary Public MY COMMISSION EXPIRES: A NOTARY PUBLI ~ (~W,~RgEy ~Y Commission Expires 7/27/2014 Zucker, Goldberg & Ackerman, LLC FCP-124952 ] 4.-' "1 4~~ EXHIBIT A Zucker, Goldberg & Ackerman, LLC FCP-124952 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~4~ptr a# ~e~~~h~ !R ~,, .~~ AFfYCE of TkE S~F£RIFF Jody S Smith Chief Deputy Richard W Stewart Solicitor US Bank National Association vs, Case Number Joni M. Raudabaugh 2009-4158 SHERIFF'S RETURN OF SERVICE 06/23/2010 06:05 PM -Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on 6-23-201C at 1802 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Joni M. Raudabaugh, located at, 800 Upland Street, Mechanicsburg, Cumberland County, Pennsylvania according to law. 06/26/2010 12:30 PM -Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on 6-26-201C at 1230 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Joni M. Raudabaugh by making known unto, Rick Brehm, husband of defendant, at, 800 Upland Street, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $898.42 July 02, 2010 i~? Cotnt<ySutte Sheriff, TeleosoR, trx, SO ANSWERS, --~..r RON R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. Bank National Association, as trustee, on CIVIL DIVISION behalf of the holders of the Home Equity Asset Trust 2007-2 Home Equity Pass-Through NO.: 09-415 8 Certificates, Series 2007-2 , , Plaintiff, , vs. Joni M. Raudabaugh Defendant. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Joni M. Raudabaugh 800 Upland Street Mechanicsburg, PA 17055 TAKE NOTICE: That the Sheriffs Saie of Real Property (Real Estate) will be held at the Cumberland County Courthouse, 1 Courthouse Squaze, Carlisle, PA 17013 on 09/08/2010 at 10:00am prevailing Local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A") The LOCATION of your property to be sold is: 800 Upland Street, Mechanicsburg, PA, 17055 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 09-4158 THE NAMES} OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Joni M. Raudabaugh Zucker, Goldberg & Ackerman, LLC FCP-124952 A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to' be disbursed by the Sheriff (for example to banks that hold mortgagcs and municipalities that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, One Courthouse Square, Carlisle, PA 17013-3387. THIS PAPER IS A NOTICE OF THE 'T'IME AND PLACE OF THE SALE OF YOUR PROPERTY. It has been issued because there is a Judgment against you. It may cause your property to be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. CO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE. Lawyer Referral Service of the Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 {717) 249-3166 THE LEGAL RIGHTS YQL~IVIAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. Zucker, Goldberg. & Ackerman, LLC FCP-124952 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 7013-3387 fore presentation of the petition to the Court. LLC Dated: April 1, 2010 BY: Scott -etterick, squire; PA I.D. #55650 Kimbe y .Bonner, Esquire; PA.I.D. #89705 Joel A. kerman, Esquire; PA I.D. #202729 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 File No.: FCP-124952 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. Zucker, Goldberg & Ackerman, LLC FCP-124952 Exhibit "A" LEGAL AESCRIPTION ALL THOSE CERTAIN LOTS OR PARCELS OF GROUND SITUATE IN LOWER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE WESTERN LINE OF UPLAND STREET, SAID POINT BEING AT THE NORTHEAST CORNER OF LOT NO. I, BLOCK "J' ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG THE WESTERN LINE OF UPLAND STREET SOUTH T'VVENI'Y-ONE {21) DEGREES THIRTY (30) MINUTES EAST A DISTANCE OF SEVENTY-FIVE (75) FEET TO A POINT ON THE DIVIDING LINE BETWEEN LOTS N0.3 AND 4, BLOCK "T', ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG THE DIVIDING LINE BETWEEN LOTS N0.3 AND 4, SOUTH SIXTY-EIGHT (68) DEGREES THIRTY- EIGHT (38) MINUTES WEST ONE HUNDRED SIX AND FIFTYSIX(106.56) ONE-HUNDREDTH FEET TO A POINT THENCE NORTH TWENTY-TWO (22) DEGREES THIRTY (30} MINUTES WEST A DISTANCE OF SEVENTY-FIVE (75) FEET TO A POINT AT THE NORTHWEST CORNER OF LOT NO, 1. BLOCK "J" ON THE HEREINAFTER MENTIONED PLAN OF LOTS: THENCE ALONG THE SOUTHERN LINE OF LINDEN AVENUE (UNOPENED) NORTH SIXTY-EIGHT (68) DEGREES THIRTY (30) MINUTES EAST A DISTANCE OF ONE HUNDRED SEVEN AND EIGHTY-SEVEN ONE-HUNDREDTHS (107.87} FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOTS NO. I, 2 AND 3, BLOCK "T', OF THE PLAN OF LOTS OF HARRISBURG MANOR, LOCATED IN LOWER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA IS SURVEYED BY A. B. RUPP, C. E. OF MACHANICSBURG, PENNSYLVANIA AND PLOTTED BY WILLIAM MCCORMICK OF PHILADELPHIA, PENNSYLVANIA, SAID MAP OR PLAN HAS BEEN FILED ON RECORD WITH THE RECORDER OF DEEDS OFFICE FOR CUMBERLAND COUNTY ON AUGUST 14,1925 IN PLAN BOOK 2, PAGE 54. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 800 UPLAND STREET, MECHANICSBURG, PA, 17055. BEING THE SAME PREMISES WHICH JOHN R. KENNEDY AND DORIS 3. KENNEDY, BY DEED DATED NOVEMBER 14, 2006 AND RECORDED NOVEMBER 22, 2006 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 277, PAGE 3533, GRANTED AND CONVEYED UNTO JONI M. RAUDABAUGH, SINGLE. TAX MAP NO.: 13-24-0795-015 Zucker, Goldberg 8c Ackerman, LLC FCP-11A952 t .. , :, . I . ~~~ .~3 ~ fps P.~taaee. rlm.ra Ms ern pewat.d a verso l6. q~ f 9 -~r1_ ~ t ~~~~ ~~ Rrrsio+res 02 ,M ~ o~.~o~ 0004282038 APR 23 2010 MAILED FROM ZPCODE 01092 Scott A. Dietterick, Esquiie~ c% Zucker, Goldberg & Ackerman, LLC 204 Sheffield Street, Suite 301 Mountainside, NJ 07092 FCP-124952rde TEAM D '~' MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR EQUIFIRST CORPORATION y~~~``\~ S00 FOREST POINT CIRCLE . CHARLOTTE, NC 28273 ~~ 2 ~ '~Q~ County of P.Q.: CUMBERLAND .~..:,~ PS Form 3817, April 2007 PSN 7530-02-000-9065 ,.. _ fir ~` sawnrs~w,ra . .:::. ~'~ `~~ `~~ . _ ~o~ ,M x'01.10° reucati6r~;,r~r.~u,~p„~Id.,.V;d.e,e,~,~~,~~~~~~~ ~ 00042.82036 ~tPR 23 ~ 2010 nd ~°"'~°"~'°'~~' ~~ FROM ZIP CODE 0 70 92 `'""r` Scott A. Dietterick, Esquire ~ ~ - _ c% Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 FCP-1249S2rde TEAM D '~` MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, '" INC. AS NOMINEE FOR EQUIFIRST CORPORATION ,~ P.O.BOX 2026, FLINT MI 48501-2026 ~ County of P.Q.: CUMBERLAND PS Form 3817, April 2007 P5N 7530-02-000-9065 ~ r,~~~ Page 1 of 4 :: f~~~~..~ Tib Cotiiloeoe dblu7ias woeide.eldaaoa rbe weH M been pneared m USPSO fj aad fooenrdoeel auLL i '`~'°' Scott A. Dietterick, Esquire .. ~~ ~ ~~.~~ _~ 02 ,M ~ 01.10° 0004282038 APR 23 2010 MAILED FROM ZfPCOOE 0 7092 clo Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 FCP-124932rde TEAM D '~` CUMBERLAND COUNTY TAX CLAIM BUREAU ~ Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 County of P.Q.: CUMBERLAND_ PS Form 3817, Apri12007 PSN 7530-02-000-9065 ~~~~ ~ 1 I I MWSI ~~~~ i5ie c.enw.otMe~ies Povides e~idmoe dr[ a.u `.e bees presented m USPSO1hr eai8ns Th4 bm m and ietsnetlew ar11. F°°` Scott A. Dietterick, Esquire c% Zucker, Goldberg & Ackerman, LLC ~~ by , / • ~~ ~~ •r. wn~r ~ow~ 02 1M ~ Q~.e'r~ 0004282038 APR 23' 2010 MAILED FROM ZB'CODE 0 7092. 200 ShefEeld Street, Suite 301 Mountainside, NJ 07092 FCP-124932rde TEAM D T'' COMMONWEALTH OF PENNSYLVANIA ~ ~ ~~S~c~=E~~O' DEPARTMENT OF WELFARE ~~-~ P.O. Box 2675 Harrisburg, PA 17105 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 ~~~ Page 2 of 4 i • _~~ 02 iM +~. . :•r• 000 42820 3 6 ~ O i'F1~ ~~~~~•.~~~~ ~ MAILED FROM ZIPCOD~ ~ 10 , 11w Catllla~s orM~y poridM aid.ee, dut m,x Aa bw praaad b uSPS~ for md~' 0 7092 ! rd he~mdawt iaiL j `'"" Scott A. Dietterick, Esquire c% Zucker, Goldberg 8c Ackerman, LLC 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 FCP-124952rde TEAM D '~` CUMBERLAND COUNTY DOMESTIC RELATIONS P°'°°"'`~4~~_~_ ~ U OFFICE -"a~i~y ~ti'~ Domestic Relations Section , ~,.; :r ~ ~~~ 13 N. Hanover Street PO Box 320 ~~, ~ fte~~ Carlisle, PA 17013 ~ r~• ~>1 County of P.Q.: CUMBERLAND PS Form 3817, Apri12007 PSN 7330-02-000-9063 i ,', .ir~,4r1 • zo, o ~ ~~~:~~ ..~_.~.'~~.-~.. voo~a2az03~ ~~ 0.1092 '. 13i. c.~dn~war ~ma «baw. eAu ~ a.. ee.. pra.Ae.a m usesm to auuia~. Thl. Poc, . .~a ~..u~..i ~. ; `'"°'~ Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 FCP-124952rde TEAM D ~" PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION ~°''°'°'`~°`° Dept. 280601 Harrisburg, PA 17128-0601 County of P.Q.: CUMBERLAND PS Form 3817, Apri12007 PSN 7330-02-000-9065 ti$~rl~~o ~`'\~~,. I~PR 2 3~ 20~ ~J,..a Page 3 of 4 i ~. I . ~ ~ .~,..~. wnar.owFs ,~.f~~7=,~~ ~ ~ spa ~~ ~f,J 02 1M Apo 23 2010 . ' ~~~~~~~~•~~~~+~~-!+~ 00042820~3M ~+COE1E 07092 rr'+c.~.aoisrpt MAILED end Ua:rllontl auil. ~ piovidM sYid~ tlrt nrq Ms 6Mn pa~enbd b USP90lbr md6pa, . '~"' Scott A. Dietterick, Esquire -_-...~ ~ . ....___..._ - -- 1 c% Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 ' FCP-124952/jde TEAM D '~: UNKNOWN TENANT OR TENANTS P°°~"4~~~ ,,, f ~~ ~,, 800 Upland Street '`' ~'~ ;~ Mechatricsburg, PA 17055 ~, ~ County of P.Q.: CUMBERLAND `: ~' ~' ~. ~ ~'~ ~ 1 ~ r PS Form 3817, April 2007 PSN 7330-02.000-9065 (~~ ~~ t!f` . +. I ~ „_..., ~ ~~'.~.~= .a2 1M $ 01-'I~ ~ 0004282038 ApR23 201 ~ ~ :: MAILED PROM ~~ 0 7082 '~ ; , I _._._..._. _ .- . , -- . rb.c.ueao.at ..w«p. u.: mri e.. ee.. ~e ~ useaeta m.~y,,mr ~ ~r a w.a ~a~.w;~ ..a ~ ~~ "`°°` Scott A. Dietterick, Esquire. c% Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 301 ~5^CF[EC~y'~ ., Mountainside, NJ 07092 ~ ~~~~'~ FCP-124952Tde TEAM D A ~R 2 3 "' UNKNOWN SPOUSE ~~ s1~ 800 Upland Street ~ ~~+~ ~~ Mechanicsburg, PA 17055 ~ ~~~ County of P.Q.: CUMBERLAND PS Form 3817, Apri12007 PSN 7530-02-000-9065 Page 4 of 4 EXHIBIT B Zucker, Goldberg & Ackerman, LLC FCP-124952 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE, CIVIL DIVISION ON BEHALF OF THE HOLDERS OF THE HOME EQUITY ASSET TRUST 2007-2 HOME EQUITY PASS-THROUGH NO.: 09-4158 CERTIFICATES, SERIES 2007-2 , , Plaintiff, vs. Joni M. Raudabaugh Defendant. NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C.P. 3129(b) TO: CUMBERLAND COUNTY TAX CLAIM BUREAU UNKNOWN SPOUSE Cumberland County Courthouse 800 Upland Street One Courthouse Square Mechanicsburg, PA 17055 Carlisle, PA 17013 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 UNKNOWN TENANT OR TENANTS 800 Upland Street Mechanicsburg, PA 17055 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR EQUIFIRST CORPORATION 500 FOREST POINT CIRCLE CHARLOTTE, NC 28273 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR EQUIFIRST CORPORATION P.O.BOX 2026, FLINT MI 48501-2026 CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 Zucker, Goldberg & Ackerman, LLC FCP-124952 124952D1004C04232010P1 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in: the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 On 09/08/2010 at 10:00am, the following described real estate which Joni M. Raudabaugh, single are the owners or reputed owners and on which you may hold a lien or have an interest which could be affected by the sale of: 800 Upland Street, Mechanicsburg, PA 17055 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). Zucker, Goldberg & Ackerman, LLC FCP-124952 124952D1004C04232010P2 The said Writ of Execution has been issued on a judgment in the action of U.S. Bank National Association, as trustee, on behalf of the holders of the Home Equity Asset Trust 2007-2 Home Equity Pass-Through Certificates, Series 2007- 2 Plaintiff vs. Joni M. Raudabaugh, et al Defendant(s) at EX. N0.09-4158 in the amount of $128079.43 plus interest and costs. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from the sale date. Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. If you have any questions or comments with regard to the Sheriff's Sale or this Notice, you should contact your attorney as soon as possible. ZUCK ER Ci OL13B E1tG & ACK ERMAN LLC Dated: Apri123, 2010 B~` Scott A. Dietterick, Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 File No.: FCP-124952 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com Zucker, Goldberg & Ackerman, LLC FCP-124952 124952D1004C04232010P3 Exhibit "A" LEGAL DESCRIPTION ALL THOSE CERTAIN LOTS OR PARCELS OF GROUND SITUATE IN LOWER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE WESTERN LINE OF UPLAND STREET, SAID POINT BEING AT THE NORTHEAST CORNER OF LOT NO. 1, BLOCK "J' ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG THE WESTERN LINE OF UPLAND STREET SOUTH TWENTY-ONE (21) DEGREES THIRTY (30) MINUTES EAST A DISTANCE OF SEVENTY-FIVE (75) FEET TO A POINT ON THE DIVIDING LINE BETWEEN LOTS N0.3 AND 4, BLOCK "J", ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG THE DIVIDING LINE BETWEEN LOTS N0.3 AND 4, SOUTH SIXTY-EIGHT (68) DEGREES THIRTY-EIGHT (38) MINUTES WEST ONE HUNDRED SIX AND FIFTYSIX(106.56) ONE-HUNDREDTH FEET TO A POINT THENCE NORTH TWENTY-TWO (22) DEGREES THIRTY (30) MINUTES WEST A DISTANCE OF SEVENTY-FIVE (75) FEET TO A POINT AT THE NORTHWEST CORNER OF LOT NO, 1. BLOCK "J" ON THE HEREINAFTER MENTIONED PLAN OF LOTS: THENCE ALONG THE SOUTHERN LINE OF LINDEN AVENUE (UNOPENED) NORTH SIXTY-EIGHT (68) DEGREES THIRTY (30) MINUTES EAST A DISTANCE OF ONE HUNDRED SEVEN AND EIGHTY-SEVEN ONE-HUNDREDTHS (107.87) FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOTS NO. 1, 2 AND 3, BLOCK "J", OF THE PLAN OF LOTS OF HARRISBURG MANOR, LOCATED IN LOWER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA IS SURVEYED BY A. B. RUPP, C. E. OF MACHANICSBURG, PENNSYLVANIA AND PLOTTED BY WILLIAM MCCORMICK OF PHILADELPHIA, PENNSYLVANIA, SAID MAP OR PLAN HAS BEEN FILED ON RECORD WITH THE RECORDER OF DEEDS OFFICE FOR CUMBERLAND COUNTY ON AUGUST 14, 1925 IN PLAN BOOK 2, PAGE 50. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 800 UPLAND STREET, MECHANICSBURG, PA, 17055. BEING THE SAME PREMISES WHICH JOHN R. KENNEDY AND DORIS J. KENNEDY, BY DEED DATED NOVEMBER 14, 2006 AND RECORDED NOVEMBER 22, 2006 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 277, PAGE 3533, GRANTED AND CONVEYED UNTO JONI M. RAUDABAUGH, SINGLE. TAX MAP NO.: 13-24-0795-015 Zucker, Goldberg & Ackerman, LLC «Field2»-«Field 1» «Field 1 »D 1004C02/12/2008P4 • SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FILED-C-CF?CF Sheriff „r? R{ , ? .. _ ., Jody S Smith "P 1 S AM 8: 3 2 Chief Deputy j ? Richard W Stewart M, F Solicitor OFFICE 4; CU+1Ir?..'i I?GJUiv11 PENNSY1VANA US Bank National Association Case Number vs. Joni M. Raudabaugh 2009-4158 SHERIFF'S RETURN OF SERVICE 06/23/2010 06:05 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on 6-23-201C at 1802 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Joni M. Raudabaugh, located at, 800 Upland Street, Mechanicsburg, Cumberland County, Pennsylvania according to law. 06/26/2010 12:30 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on 6-26-201C at 1230 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Joni M. Raudabaugh by making known unto, Rick Brehm, husband of defendant, at, 800 Upland Street, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 09/07/2010 As directed by Scott A Dietterick, Attorney for the Plaintiff, Sheriffs Sale Continued to 10/6/2010 09/07/2010 Property sale removed from 10/6/2010 sale. 09/07/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ is returned STAYED, per letter of instruction from Attorney Scott Dietterick on 9/7/10 SHERIFF COST: $941.40 SO ANSWERS, September 14, 2010 RON R ANDERSON, SHERIFF ek-v 7etq9i ri CO("ItySUIte She;"!ft. le!,-osof(_ na IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. Bank National Association, as trustee, on behalf of the holders of the Home Equity Asset Trust 2007-2 Home Equity Pass-Through Certificates, Series 2007-2 , : CIVIL DIVISION : NO.: 09-4158 Plaintiff, vs. Joni M. Raudabaugh Defendant. AFFIDAVIT PURSUANT TO RULE 3129.1 U.S. Bank National Association, as trustee, on behalf of the holders of the Home Equity Asset Trust 2007-2 Home Equity Pass-Through Certificates, Series 2007-2, Plaintiff in the above action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 800 Upland Street, Mechanicsburg, PA 17055. Name and Address of Owner(s) or Reputed Owner(s): JONI M. RAUDABAUGH, SINGLE 800 Upland Street Mechanicsburg, PA 17055 2. Name and Address of Defendant(s) in the Judgment: JONI M. RAUDABAUGH 800 Upland Street Mechanicsburg, PA 17055 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE, ON BEHALF OF THE HOLDERS OF THE HOME EQUITY ASSET TRUST 2007-2 HOME EQUITY PASS-THROUGH CERTIFICATES, SERIES 2007-2 Plaintiff luckar. Goldberg & Ackerman. LL(' F(T-124952 4. Name and Address of the last record holder of every mortgage of record: U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE, ON BEHALF OF THE HOLDERS OF THE HOME EQUITY ASSET TRUST 2007-2 HOME EQUITY PASS- THROUGH CERTIFICATES, SERIES 2007-2 Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR EQUIFIRST CORPORATION 500 FOREST POINT CIRCLE CHARLOTTE, NC 28273 AND P.O.BOX 2026, FLINT MI 48501-2026 5. Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 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: COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 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: CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 UNKNOWN TENANT OR TENANTS 800 Upland Street Mechanicsburg, PA 17055 Zucker. Goldberg K Ackerman, [,LC FCP-1249-5' UNKNOWN SPOUSE 800 Upland Street Mechanicsburg, PA 17055 PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I and stand that a statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relatin to Wsyf"sification to authorities. LLC Dated: April 1, 2010 BY, Scott A. tteric c, quire; PA I.D. #55650 Kimberl . Bonner, Esquire; PA.I.D. #89705 Joel A. A erman, Esquire; PA I.D. #202729 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 File No.: FCP-124952 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com Zucker, Goldberg & Ackerman, LLC (CP-12d95? Exhibit "A" LEGAL DESCRIPTION ALL THOSE CERTAIN LOTS OR PARCELS OF GROUND SITUATE IN LOWER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE WESTERN LINE OF UPLAND STREET, SAID POINT BEING AT THE NORTHEAST CORNER OF LOT NO. 1, BLOCK "J' ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG THE WESTERN LINE OF UPLAND STREET SOUTH TWENTY-ONE (21) DEGREES THIRTY (30) MINUTES EAST A DISTANCE OF SEVENTY-FIVE (75) FEET TO A POINT ON THE DIVIDING LINE BETWEEN LOTS NO.3 AND 4, BLOCK "J", ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG THE DIVIDING LINE BETWEEN LOTS NO.3 AND 4, SOUTH SIXTY-EIGHT (68) DEGREES THIRTY- EIGHT (38) MINUTES WEST ONE HUNDRED SIX AND FIFTYSIX(106.56) ONE-HUNDREDTH FEET TO A POINT THENCE NORTH TWENTY-TWO (22) DEGREES THIRTY (30) MINUTES WEST A DISTANCE OF SEVENTY-FIVE (75) FEET TO A POINT AT THE NORTHWEST CORNER OF LOT NO, 1. BLOCK "J" ON THE HEREINAFTER MENTIONED PLAN OF LOTS: THENCE ALONG THE SOUTHERN LINE OF LINDEN AVENUE (UNOPENED) NORTH SIXTY-EIGHT (68) DEGREES THIRTY (30) MINUTES EAST A DISTANCE OF ONE HUNDRED SEVEN AND EIGHTY-SEVEN ONE-HUNDREDTHS (107.87) FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOTS NO. 1, 2 AND 3, BLOCK "J", OF THE PLAN OF LOTS OF HARRISBURG MANOR, LOCATED IN LOWER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA IS SURVEYED BY A. B. RUPP, C. E. OF MACHANICSBURG, PENNSYLVANIA AND PLOTTED BY WILLIAM MCCORMICK OF PHILADELPHIA, PENNSYLVANIA, SAID MAP OR PLAN HAS BEEN FILED ON RECORD WITH THE RECORDER OF DEEDS OFFICE FOR CUMBERLAND COUNTY ON AUGUST 14, 1925 IN PLAN BOOK 2, PAGE 50. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 800 UPLAND STREET, MECHANICSBURG, PA, 17055. BEING THE SAME PREMISES WHICH JOHN R. KENNEDY AND DORIS J. KENNEDY, BY DEED DATED NOVEMBER 14, 2006 AND RECORDED NOVEMBER 22, 2006 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 277, PAGE 3533, GRANTED AND CONVEYED UNTO JONI M. RAUDABAUGH, SINGLE. TAX MAP NO.: 13-24-0795-015 Zucker, Goldberg & Ackerman, LLC F (T-124952 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. Bank National Association, as trustee, on CIVIL DIVISION behalf of the holders of the Home Equity Asset Trust 2007-2 Home Equity Pass-Through NO.: 09-4158 Certificates, Series 2007-2 , Plaintiff, VS. Joni M. Raudabaugh Defendant. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Joni M. Raudabaugh 800 Upland Street Mechanicsburg, PA 17055 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, I Courthouse Square, Carlisle, PA 17013 on 09/08/2010 at l 0:00am prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A") The LOCATION of your property to be sold is: 800 Upland Street, Mechanicsburg, PA, 17055 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 09-4158 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Joni M. Raudabaugh Zucker, Goldberg & Ackerman, LLC FCP-124952 A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, One Courthouse Square, Carlisle, PA 17013-3387. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. It has been issued because there is a Judgment against you. It may cause your property to be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE. Lawyer Referral Service of the Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. Zucker, Goldberg & Ackerman, LLC FCP-124952 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 7013-3387 efore presentation of the petition to the Court. ? -I , LLC Dated: April 1, 2010 BY: Scott A ' etterick, Esquire; PA I.D. #55650 Kimbe y . Bonner, Esquire; PA.I.D. #89705 Joel A. kerman, Esquire; PA I.D. #202729 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 File No.: FCP-124952 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. Zucker, Goldberg & Ackerman, LLC FCP-124952 Exhibit "A" LEGAL DESCRIPTION ALL THOSE CERTAIN LOTS OR PARCELS OF GROUND SITUATE IN LOWER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE WESTERN LINE OF UPLAND STREET, SAID POINT BEING AT THE NORTHEAST CORNER OF LOT NO. 1, BLOCK "J' ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG THE WESTERN LINE OF UPLAND STREET SOUTH TWENTY-ONE (21) DEGREES THIRTY (30) MINUTES EAST A DISTANCE OF SEVENTY-FIVE (75) FEET TO A POINT ON THE DIVIDING LINE BETWEEN LOTS NO.3 AND 4, BLOCK "J", ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG THE DIVIDING LINE BETWEEN LOTS NO.3 AND 4, SOUTH SIXTY-EIGHT (68) DEGREES THIRTY- EIGHT (38) MINUTES WEST ONE HUNDRED SIX AND FIFTYSIX(106.56) ONE-HUNDREDTH FEET TO A POINT THENCE NORTH TWENTY-TWO (22) DEGREES THIRTY (30) MINUTES WEST A DISTANCE OF SEVENTY-FIVE (75) FEET TO A POINT AT THE NORTHWEST CORNER OF LOT NO, 1. BLOCK "J" ON THE HEREINAFTER MENTIONED PLAN OF LOTS: THENCE ALONG THE SOUTHERN LINE OF LINDEN AVENUE (UNOPENED) NORTH SIXTY-EIGHT (68) DEGREES THIRTY (30) MINUTES EAST A DISTANCE OF ONE HUNDRED SEVEN AND EIGHTY-SEVEN ONE-HUNDREDTHS (107.87) FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOTS NO. 1, 2 AND 3, BLOCK "J", OF THE PLAN OF LOTS OF HARRISBURG MANOR, LOCATED IN LOWER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA IS SURVEYED BY A. B. RUPP, C. E. OF MACHANICSBURG, PENNSYLVANIA AND PLOTTED BY WILLIAM MCCORMICK OF PHILADELPHIA, PENNSYLVANIA, SAID MAP OR PLAN HAS BEEN FILED ON RECORD WITH THE RECORDER OF DEEDS OFFICE FOR CUMBERLAND COUNTY ON AUGUST 14, 1925 IN PLAN BOOK 2, PAGE 50. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 800 UPLAND STREET, MECHANICSBURG, PA, 17055. BEING THE SAME PREMISES WHICH JOHN R. KENNEDY AND DORIS J. KENNEDY, BY DEED DATED NOVEMBER 14, 2006 AND RECORDED NOVEMBER 22, 2006 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 277, PAGE 3533, GRANTED AND CONVEYED UNTO JONI M. RAUDABAUGH, SINGLE. TAX MAP NO.: 13-24-0795-015 Zucker, Goldberg & Ackennan, LL,C FCP-124952 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-4158 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due U.S. BANK NATIONAL ASSOCIATION, as Trustee, on behalf of the holders of the HOME EQUITY ASSET TRUST 2007-2 HOME EQUITY PASS- THROUGH CERTIFICATES, SERIES 2007-2, Plaintiff (s) From JONI M. RAUDABAUGH (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 $128,079.43 L.L. Interest from 8/8109 to Date of Sale -- $14,094.72 Atty's Comm % Atty Paid $1,178.29 Plaintiff Paid bate: 4/6/10 (Seal) REQUESTING PARTY: Name: JOEL ACKERMAN, ESQUIRE Due Prothy $2.00 Other Costs David D. Buell Prothonotary By: Deputy Address: ZUCKER, GOLDBERG & ACKERMAN, LLC 200 SHEFFIELD STREET, SUITE 301 MOUNTAINSIDE, NJ 07092 Attorney for: PLAINTIFF Telephone: 908-233-8500 Supreme Court ID No. 202729 On June 14, 2010 the Sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA, Known and numbered as, 800 Upland Street, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 145 2010 By: ?s Real Estate Coordinator Z :Z" v Z I?c'? C'.:u The Patriot.News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE atr iotwXtw s 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. PUBLICATION COPY This ad ran on the date(s) shown below: 07/09/10 07/16/10 M 07/23/10 .?Y t/ Sworn to and Subscribed before m4tl is 05 dory of August, 2010 A 1). Notary Public T f)j'?-Zia--; ±;F pj:: iyV'"/t VANTA 1 Sherrie L, K3sner, rJO;ar?' Pubii, C [over Paxt011 'rW -, Dauphul County my Commiss_iOr' Expires Plav. 2E, 2011 Member, Pennsv'va?Na As ?ci.?tio~of Nntar+es 2009.4158 Civil Term US Bank NageniM Assoc cn as TrusLae for JP MarW 2606- Si Vs Joni M. Faudabaugh Atty: Scott A Dietterick AU THOSE CERTAIN LOTS OR PARCELS OF GROUND SITUATE IN LOWER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING XL A POINT IN THE WESTERN LINE OF UPLAND STREET, SAID POINT BEING AT THE NORTHEAST CORNER OF LOT NO. 1, BLOCK "J' ON THE HEREINAFTER MENTIONED PLAN 01 LOTS; THENCE ALONG THE WESTERN LINE OF UPLAND STREET SOUTH TWENTY-ONE (21) DEGREES THIRTY (30) MINUTES EAST A DISTANCE OF SEVENTY-FIVE (75) FEET TO A POINT ON THE DIVIDING LINE BETWEEN LOTS NO.3 AND 4, BLOCK "J", ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG THE DIVIDING LINE BETWEEN LOTS NO. 3 AND 4, SOUTH SIXTY-EIGHT (68) DEGREES THIRTY-EIGHT (38) MINUTES WEST ONE HUNDRED SIR AND FIFTYSIX(106.56) ONE-HUNDREDTH FEET TO A POINT THENCE NORTH TWENTY-TWO (22) DEGREES THIRTY (30) MINUTES WEST A DISTANCE OF SEVENTY-FIVE (75) FEET TO A POINT AT THE NORTHWEST CORNER OF LOT NO, 1. BLOCK "T" ON THE HEREINAFTER MENTIONED PLAN OF LOTS: THENCE ALONG THE, SOUTHERN LINE OF LINDEN AVENUE (UNOPENED) NORTH SIXTY-EIGHT (68) DEGREES THIRTY (30) :MINUTES EAST A DISTANCE OF ONE HUNDRED SEVEN AND EIGHTY-SEVEN ONE-HUNDREDTHS (107.87) FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOTS NO. 1.2 AND 3, BLACK "J", OF THE PLAN OF LOTS OF HARRISBURG MANOR, LOCATED IN LOWER ALLEN TOWNSHIP. C1IMBERLANDCOUNTY.PENNSYLVANIA IS SURVEYED BY A. B. RUPP. C. E. 01 M4CHANICSBURG, PENNSYLVANIA AND PLOTTED BY WILLIAM MCCORMICK OF PHILADELPHIA, PENNSYLVANIA, SAID MAP OR PLAN HAS BEEN FILED ON RECORD WITHTHE RECORDER OF DEEDS OFFICE FOR CUMBERLAND COUNTY ON AUGUST 14. 1925 IN PLAN BOOK 2, PAGE j11. HAVING 'THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 800 UPLAND STREET, MECHANICSBURG, PA, 17055. BEING THE SAME PREMISES WHICH IOHN R. KENNEDY AND DORIS J. KENNEDY, BY DEED DATED NOVEMBER 14. 2006 AND RECORDED NOVEMBER _2, 2006 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 277. PAGE 3533. GRANTED AND ('ONVEYEDUNTOJONIM.RAUDABAUGH, iINGLF. IAX MAP NO.: 13-24-0795-015 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA . ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a-legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 16, July 23, and July 30, 2010 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. isa Marie SWORN TO AND SUBSCRIBED before me this 30 day of Jul 2010 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH. CUMBERLAND COUNTY My Commission Expires Apr 28.2014 NO. 299"In C" US Bank National Association as Trustee for JP Morgan 2005-S 1 vs. Joni M. Raudabaugh Atty.: Scott A. Dietterick ALL THOSE CERTAIN lots or parcels of ground situate in Lower Al- len Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point in the western line of Upland Street, said point being at the northeast corner of Lot No. 1, Block "J' on the herein- after mentioned plan of lots; thence along the western line of Upland Street South twenty-one (21) degrees thirty (30) minutes East a distance of seventy-five (75) feet to a point on the dividing line between Lots No. 3 and 4, Block "J", on the hereinafter mentioned plan of lots; thence along the dividing line between Lots No. 3 and 4, South sixty-eight (68) degrees thirty-eight (38) minutes West one hundred six and fiftysix(106.56) one-hundredth feet to a point thence North twenty-two (22) degrees thirty (30) minutes West a distance of seventy-five (75) feet to a point at the northwest corner of Lot No, 1. Block "J" on the hereinafter mentioned plan of lots: thence along the southern line of Linden Avenue (unopened) North sixty-eight (68) degrees thirty (30) minutes East a distance of one hundred seven and eighty-seven one-hundredths (107.87) feet to a point, the place of Beginning. BEING Lots No. 1, 2 and 3, Block "J", of the plan of lots of Harrisburg Manor, located in Lower Allen Township, Cumberland County, Pennsylvania is surveyed by A. B. Rupp, C. E. of Machanicsburg, Pennsylvania and plotted by William McCormick of Philadelphia, Pennsylvania, said map or plan has been filed on record with the Recorder of Deeds Office for Cumberland County on August 14, 1925 in Pion Book 2, Page 50. HAVING THEREON ERECTED a dwelling house being known and numbered as 800 Upland Street, Mechanicsburg, PA, 17055. BEING the same premises which John R. Kennedy and Doris J. Ken- nedy, by deed dated November 14, 2006 and recorded November 22, 2006 in and for Cumberland County, Pennsylvania, in Deed Book Volume 277, Page 3533, granted and con- veyed unto Joni M. Raudabaugh, single. TAX MAP NO.: 13-24-0795-015. r+ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. & AIL kl"-CYIa? CIVIL DIVISION P'5%6 a-l-OY1 Plaintiff, vs. NO.: 09-4158 Joni M. Raudabaugh; Defendant(s). PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: tzi s, N) C) CD - ca - = -? rv 2> Please mark the judgment filed at the above-captioned term and number satisfied without prejudice. Respectfully submitted: ZUCKER, GOLDBERG & ACKERMAN, LLC BY: ? t? 6 f? ? C ? Dated: February 22, 2012 Scott A. sett r k, Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh Levy Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Attorneys for Plaintiff FCP-124952/ka 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com L?. F+ S 135 9 14 ?_l I Lie) Zucker, Goldberg & Ackerman, L.L,C PCP-124952