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Home My WebLink About09-4624 GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY I.D. #56129 SUITE 5000 MELLON INDEPENDENCE CENTER 701 Market Street PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF Deutsche Bank National Trust Company as Trustee, FKA Bankers Trust Company as Trustee for Holders of Mortgage Pass-Through Certificates, SACO 1, Inc., Series 1999-5, as their successors and assigns PO Box 293150 Lewisville, TX 75029 Plaintiff VS. LORI A. TRACE RONALD D. TRACE and OCCUPANTS 20 West Simpson Street Mechanicsburg, PA 17055 CIVIL ACTION: EJECTMENT IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF EJECTMENT Term 0 1 V I- I No. 0- ctilaq Defendants NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row, Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row, Carlisle, PA 17013 717-243-9400 COMPLAINT IN EJECTMENT 1. Plaintiff is Deutsche Bank National Trust Company as Trustee, FKA Bankers Trust Company as Trustee for Holders of Mortgage Pass-Through Certificates, SACO 1, Inc., Series 1999-5, as their successors and assigns, PO Box 293150, Lewisville, TX 75029. 2. Defendants are LORI A. TRACE, RONALD D. TRACE, and OCCUPANTS. 3. Plaintiff is the owner of property located at 20 West Simpson Street, Mechanicsburg, PA 17055, by virtue of a Deed from the Sheriff of Cumberland County to Deutsche Bank National Trust Company as Trustee, FKA Bankers Trust Company as Trustee for Holders of Mortgage Pass-Through Certificates, SACO 1, Inc., Series 1999-5, as their successors and assigns recorded on July 2, 2009 at instrument number 200922889. A true and correct copy of the legal description of the Property is attached to this Complaint. 4. Plaintiff is entitled to immediate possession of the Property. 5. The Defendants, LORI A. TRACE, RONALD D. TRACE and OCCUPANTS, are occupying the Property without right, and so far as the Plaintiff is informed, without claim of title. 6. Plaintiff has demanded possession of the Property from the Defendants and OCCUPANTS, who have refused to deliver up possession of the same. WHEREFORE, Plaintiff requests judgment for possession of the Property. GOLDBECK McCAFFERTY & McKEEVER By: Michael McKeever, Esq. VERIFICATION Nancy Bronson I, Authorized officer on behalf of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: C? EMC Mortgage Corporation As Attorney-In-Fact ncy Bronson Authorized Officer 84276EJ ALL THAT CERTAIN piece or parcel of land situate in the Borough of Mechanicsburg, Cumberland County, Pennsylvania, being bounded and described according to a survey made by D. P. Raffensperger, a Registered Surveyor, dated August 4, 1980, as follows, to wit: BEGINNING at a drill hole on the Northeast corner of West Simpson Street (60 feet wide) and Lamont Avenue; thence extending from said point of beginning and along the East side of Lamont Avenue North 23 degrees 16 minutes 34 seconds West the distance of 133.51 feet to a railroad spike on the South side of a public alley; thence along said alley North 71 degrees 56 minutes 46 seconds East the distance of 36.00 feet to an iron pin at the corner of lands now or formerly of Cynthia P. McNaughton being House No. 18; thence along said lands South 23 degrees 16 minutes 35 seconds East the distance of 116.00 feet to a pipe; thence continuing along the same South 21 degrees 10 minutes East the distance of 21.50 feet to a point on the North side of West Simpson Street; thence along the said side of West Simpson Street South 78 degrees 23 minutes 35 seconds West the distance of 35.85 feet to a point the place of BEGINNING. TAX PARCEL #: 16-23-0565-088 PROPERTY ADDRESS: 20 WEST SIMPSON STREET, MECHANICSBURG, PA 17055 6-) ,,, t, 2099 JUL 10 t. 111: 22 Id. -#?F sd /W? ?'CC# d?7?P39 Sheriffs Office of Cumberland County a? R Thomas Kline F{?_?} li' ?HI?` Sher Ronny R Anderson 205 16 41: Chief Deputy Jody S Smith t' [Vt/?IMI `, ; Civil Process Sergeant OFFICE ?7'F T"E s"ERIFF Edward L Schorpp Solicitor Deutsche Bank National Trust Co. I Case Number vs. 2009-4624 Lori A. Trace SHERIFF'S RETURN OF SERVICE 07/1312009 07:10 PM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Lori A. Trace, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Ejectment as not found as to the defendant Lori A. Trace. Current resident of 20 West Simpson Street Mechanicsburg, PA 17055 Ronald Trace stated the defendant has moved to Newport, PA. He does not have a current address however, the defendant has charges out of Magesterial District Judge Susan Day's Office and they possibly have a current address for the defendant. An exact address is not available. 07/13/2009 07:10 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on July 13, 2009 at 1910 hours, he served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: Ronald D. Trace, by making known unto himself personally, defendant at 20 West Simpson 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. 07/13/2009 07:10 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on July 13, 2009 at 1910 hours, he served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: OCCUPANTS, by making known unto Ronald D. Trace, adult in charge at 20 West Simpson 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: $74.00 SO ANSWERS, July 14, 2009 R THOMAS KLINE, SHERIFF By Deputy eriil GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney ID #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6319 Attorney for Plaintiff Deutsche Bank National Trust Company as Trustee, FKA Bankers Trust Company as Trustee for Holders of Mortgage Pass-Through Certificates, SACO 1, Inc., Series 1999-5, as their successors and assigns PO Box 293150 Lewisville, TX 75029 Plaintiff vs. LORI A. TRACE and RONALD D. TRACE and OCCUPANTS 20 West Simpson Street Mechanicsburg, PA 17055 Defendants Term No. 09-4624 PRAECIPE FOR JUDGMENT IN EJECTMENT Kindly enter Judgment in Ejectment in favor of the Plaintiff, Deutsche Bank National Trust Company as Trustee, FKA Bankers Trust Company as Trustee for Holders of Mortgage Pass-Through Certificates, SACO 1, Inc., Series 1999-5, as their successors and assigns and against the Defendants LORI A. TRACE, RONALD D. TRACE and OCCUPANTS for failure to file an Answer in the above action within (20) days of service. I HEREBY CERTIFY THAT ACCORDING TO rule 237. 1, written 10 day notice of Plaintiff's intention to file a Praecipe for Entry of Default Judgment was mailed to Defendants, a true and correct copy of which is attached hereto. I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is Deutsche Bank National Trust Company as Trustee, FKA Bankers Trust Company as Trustee for Holders of Mortgage Pass-Through Certificates, SACO 1, Inc., Series 1999-5, as their successors and assigns, PO Box 293150, Lewisville, TX 75029 and that the names and last known address of the Defendants are LORI A. TRACE, RONALD D. TRACE and OCCUPANTS 20 West Simpson Street, Mechanicsburg, PA 17055. GOLDBECK McCAFFERTY & McKEEVER Michael T. McKeever, Esq. Attorney for Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF EJECTMENT GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney ID #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6319 Attorney for Plaintiff Deutsche Bank National Trust Company as Trustee, FKA Bankers Trust Company as Trustee for Holders of Mortgage Pass-Through Certificates, SACO 1, Inc., Series 1999-5, as their successors and assigns PO Box 293150 Lewisville, TX 75029 Plaintiff vs. LORI A. TRACE and RONALD D. TRACE and OCCUPANTS 20 West Simpson Street Mechanicsburg, PA 17055 Defendants IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF EJECTMENT Term No. 09-4624 CERTIFICATION PURSUANT TO PA R.C.P. NO. 237 I, Michael T. McKeever, Esquire, attorney for Plaintiff, certify that a true and correct copy of the Praecipe for Judgment was sent to the following parties, via first class mail, postage prepaid: LORI A. TRACE RONALD D. TRACE OCCUPANTS 20 West Simpson Street Mechanicsburg, PA 17055 GOLDBECK McCAFFERTY & McKEEVER Michael T. McKeever, Esq. Attorney for Plaintiff DATED: September 1, 2009 Sheriffs Office of Cumberland County R Thomas Kline Sheri, at Caeaa414 Ronny R Anderson Chief Deputy Jody S Smith 494 Civil Process Sergeant OFF= OF THE Sk.OWF Edward L Schorpp Solicitor Deutsche Bank National Trust Co. Case Number VS. Lori A. Trace 20094624 SHERIFF'S RETURN OF SERVICE 07/13/2009 07:10 PM - R. Thomas Kline, Sheriff, who being duty sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Lori A. Trace, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Ejectment as not found as to the defendant Lori A. Trace. Current resident of 20 West Simpson Street Mechanicsburg, PA 17055 Ronald Trace stated the defendant has moved to Newport, PA. He does not have a current address however, the defendant has charges out of Magesterial District Judge Susan Day's Office and they possibly have a current address for the defendant. An exact address is not available. 07/1312009 07:10 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on July 13, 2009 at 1910 hours, he served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: Ronald D. Trace, by making known unto himself personally, defendant at 20 West Simpson 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. 07/13/2009 07:10 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on July 13, 2009 at 1910 hours, he served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: OCCUPANTS, by making known unto Ronald D. Trace, adult in charge at 20 West Simpson 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: $74.00 July 14, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF ??e ly/::? BY-- . Deputy erYff GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL MCKEEVER, ESQ. ATTORNEY I.D. #56129 SUITE 5000 MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF Deutsche Bank National Trust Company as Trustee, FKA Bankers Trust Company as Trustee for Holders of Mortgage Pass-Through Certificates, SACO 1, Inc., Series 1999-5, as their successors and assigns PO Box 293150 Lewisville, TX 75029 Plaintiff vs. LORI A. TRACE, RONALD D. TRACE and OCCUPANTS 20 West Simpson Street Mechanicsburg, PA 17055 Defendants DATE OF THIS NOTICE: August 18, 2009 TO: OCCUPANTS 20 West Simpson Street Mechanicsburg, PA 17055 IMPORTANT NOTICE Term No. 09-4624 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF EJECTMENT 7 ?I?MKr GOLDBECK McCAFFERTY & MWEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL MCKEEVER, ESQ. ATTORNEY I.D. #56129 SUITE 5000 MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF Deutsche Bank National Trust Company as Trustee, FKA Bankers Trust Company as Trustee for Holders of Mortgage Pass-Through Certificates, SACO 1, Inc., Series 1999-5, as their successors and assigns PO Box 293150 Lewisville, TX 75029 Plaintiff vs. LORI A. TRACE, RONALD D. TRACE and OCCUPANTS 20 West Simpson Street Mechanicsburg, PA 17055 Defendants DATE OF THIS NOTICE: August 18, 2009 TO: LORI A. TRACE and RONALD D. TRACE 20 West Simpson Street Mechanicsburg, PA 17055 IMPORTANT NOTICE Term No. 09-4624 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF EJECTMENT GOLDBECK McCAFFERTY & WKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, LORI A. TRACE, is about unknown years of age, that Defendant's last known residence is, 20 West Simpson Street Mechanicsburg, PA 17055, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: L q1110 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unworn falsification to authorities. 1. That the above named Defendant, RONALD D. TRACE, is about unknown years of age, that Defendant's last known residence is 20 West Simpson Street Mechanicsburg, PA 17055, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: i / d 0 ? ? ?? FIB" '1C (YF IM ?? O.ARY SEP -4 PM 1:51 COUNTY i4.oo P? p- co , -2 Ua?8 l8 C*.oossc ? 00 C.P. 109 - P Praecipe for Writ of Possession (ACTION OF EJECTMENT) THE COMMONWEALTH OF PENNSYLVANIA COUNTY OF Cumberland Deutsche Bank National Trust Company as Trustee, FKA Bankers Trust Company as Trustee for Holders of Mortgage Pass-Through Certificates, SACO 1, Inc., Series 1999-5, as their successors and assigns PO Box 293150 Lewisville, TX 75029 Plaintiff IN THE COURT OF COMMON PLEAS VS. LORI A. TRACE RONALD D. TRACE and OCCUPANTS 20 West Simpson Street Mechanicsburg, PA 17055 Defendants PRAECIPE FOR WRIT POSSESSION TO THE PROTHONOTARY: OF Cumberland COUNTY 09-4624 Issue the Writ of Possession in the above matter, for possession of 20 West Simpson Street Mechanicsburg. PA 17055 (describe property) SEE ATTACHED LEGAL DESCRIPTION Ejectment Quiet Title A. 5 - 116 (Rev. 10/76) GOLDBECK, McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esquire Attorney for Plaintiff a? U 4+ . r. U O H G+ on 0 w 0 w? W ? o H H N ?• O ? Y o UVa U ? ? H a H 3, oU ?? 0 U H A 0 V pu p W ? U ? ?p pa cn rn W a ?r, p P? C!1 Rj cn r+ r+ v?3? H v? a Q? d a O OF TtAS Jul SEP elm I 4'alk 00 go '14-00 K ?QO50' 42.00 two cc 230.ls C w ALL THAT CERTAIN piece or parcel of land situate in the Borough of Mechanicsburg, Cumberland County, Pennsylvania, being bounded and described according to a survey made by D. P. Raffensperger, a Registered Surveyor, dated August 4, 1980, as follows, to wit: BEGINNING at a drill hole on the Northeast comer of West Simpson Street (60 fee wide) and Lamont Avenue; thence extending from said point of beginning and along the East side of Lamont Avenue North 23 degrees 16 minutes 34 seconds West the distance of 133.51 feet to a railroad spike on the South side of a public alley; thence along said alley North 71 degrees 56 minutes 46 seconds East the distance of 36.00 feet to an iron pin at the corner of lands now or formerly of Cynthia P. McNaughton being House No. 18; thence along said lands South 23 degrees 16 minutes 35 seconds East the distance of 116.00 feet to a pipe; thence continuing along the same South 21 degrees 10 minutes East the distance of 21.50 feet to a point on the North side of West Simpson Street; thence along the said side of West Simpson Street South 78 degrees 23 minutes 35 seconds West the distance of 35.85 feet to a point the place of BEGINNING. TAX PARCEL #: 16-23-0565-088 PROPERTY ADDRESS: 20 WEST SIMPSON STREET, MECHANICSBURG, PA 17055 "W . WZ WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY, as Trustee, f/k/a BANKERS TRUST COMPANY, as Trustee for HOLDERS OF MORTGAGE PASS-THROUGH CERTIFICATES, SACO 1 INC., SERIES 1999-5, as their successors and assigns vs. No. 09-4624 Civil Term LORI A. TRACE RONALD D. TRACE and OCCUPANTS Costs Attorney's $ 190.50 Plaintiff's $ Prothonotary $ 2.00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff (s)) DEUTSCHE BANK NATIONAL TRUST COMPANY, as Trustee, f/k/a BANKERS TRUST COMPANY, as Trustee for HOLDERS OF MORTGAGE PASS-THROUGH CERTIFICATES, SACO 1 INC., SERIES 1999-5, as their successors and assigns being: (Premises as follows): 20 WEST SIMPSON STREET, MECHANICSBURG, PA 17055 (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defendant (s) and sell his/her (or their) interest therein. / Curti selk.- Long, P , 9 4 0 7 Common Pleas Court of Cumb land County, PA -ft .-, 2of2 No 09-4624 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY, as Trustee, f/k/a BANKERS TRUST COMPANY, as Trustee for HOLDERS OF MORTGAGE PASS-THROUGH CERTIFICATES, SACO 1 INC., SERIES 1999-5, as their successors and assigns VS. LORI A. TRACE RONALD D. TRACE and OCCUPANTS WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 190.50 Plff (s) $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: MICHAEL T. McKEEVER, ESQUIRE GOLDBECK, McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 215-825-6319 ID# 56129 Attorney for Plaintiff (s) Where papers may be served By virtue of this writ, on the day of . I caused the within named , to have possession of the premises described with the appurtenances, and .40 .I., . Sworn and subscribed to before me this Day of , Prothonotary So Answers, Sheriff By Deputy ALL THAT CERTAIN piece or parcel of land situate in the Borough of Mechanicsburg, Cumberland County, Pennsylvania, being bounded and described according to a survey made by D. P. Raffensperger, a Registered Surveyor, dated August 4, 1980, as follows, to wit: BEGINNING at a drill hole on the Northeast corner of West Simpson Street (60 feet wide) and Lamont Avenue; thence extending from said point of beginning and along the East side of Lamont Avenue North 23 degrees 16 minutes 34 seconds West the distance of 133.51 feet to a railroad spike on the South side of a public alley; thence along said alley North 71 degrees 56 minutes 46 seconds East the distance of 36.00 feet to an iron pin at the comer of lands now or formerly of Cynthia P. McNaughton being House No. 18; thence along said lands South 23 degrees 16 minutes 35 seconds East the distance of 116.00 feet to a pipe; thence continuing along the same South 21 degrees 10 minutes East the distance of 21.50 feet to a point on the North side of West Simpson Street; thence along the said side of West Simpson Street South 78 degrees 23 minutes 35 seconds West the distance of 35.85 feet to a point the place of BEGINNING. TAX PARCEL #: 16-23-0565-088 PROPERTY ADDRESS: 20 WEST SIMPSON STREET, MECHANICSBURG, PA 17055 Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor Deutsche Bank National Trust Co. vs. Lori A. Trace ?Q??tita cf ?umbrrl,??,? #?F`f6GEC?' TvES?+ER1?P Case Nurbber 2009-4624 SHERIFF'S RETURN OF SERVICE 09/16/2009 10:43 AM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant, to wit: Lori A. Trace, but was unable to locate her in his bailiwick. Therefore, the within Writ of Possession for defendant Lori A. Trace is being returned with no service as the defendant was NOT FOUND. Per adult son Matthew Trace, defendant Lori Nace moved to Newport, PA. 09/16/2009 10:43 AM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on September 16, 2009 at 1038 hours, she served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant, to wit: Ronald d. Trace, by making known unto Matthew Trace, Adult in Charge, at 20 West Simpson 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. 09/16/2009 10:43 AM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on September 16, 2009 at 1038 hours, she served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant, to wit: Occupants, by making known unto Matthew Trace, occupant, at 20 West Simpson 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. Defendant Matthew Trace was advised that he had 15 days to vacate the premises. So Answers, I' R. Thomas Kline, Sheriff 4Amanda Cobau Al RD s -AX- OF TNF f' , `iL1r)\!(j) A?Y 2009 SEP 18 Ali 10: 2 7 Ctr??b` rT