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Home My WebLink About09-6614IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION - LAW DEUTSCHE BANK NATIONAL TRUST CIVIL Division COMPANY, AS TRUSTEE OF THE RESIDENTIAL ASSET SECURITIZATION Case Number: pQ _ 40(,01q TRUST 2006-A14CB, MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2006-N UNDER THE POOLING AND SERVICING AGREEMENT DATED OCTOBER 1, 2006 PLAINTIFF Type of Pleading VS Complaint in Mortgage Foreclosure RALPH B. ZEIDERS AND GLORIA J. ZEIDERS DEFENDANTS Code and Classification: Filed on Behalf Of: CERTIFICATE OF LOCATION Plaintiff 01vo-zM 1814 LETCHWORTH DRIVE Counsel of Record: CAMP HILL, PA 17011 Daniel J. Mancini, Esquire LOWER ALLEN TOWNSHIP Attorney at Law 201 A Fairview Drive PARCEL No: 13-23-0547-206 Monaca, PA 15061 (724) 728-4233 0 By: DANIEL J. MANCINI, ESQ. PA I.D. No. 39353 Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 manci ni lawfirm@attorneydanielmancini. com IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST CIVIL Division COMPANY, AS TRUSTEE OF THE RESIDENTIAL ASSET SECURITIZATION Case Number: TRUST 2006-A14CB, MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2006-N UNDER THE POOLING AND SERVICING AGREEMENT DATED OCTOBER 1, 2006 PLAINTIFF VS MORTGAGE FORECLOSURE RALPH B. ZEIDERS AND GLORIA J. ZEIDERS DEFENDANTS CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Services, 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 mancinilawfirm@attomeydanielmanci ni. com IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST CIVIL Division COMPANY, AS TRUSTEE OF THE RESIDENTIAL ASSET SECURITIZATION Case Number: TRUST 2006-A14CB, MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2006-N UNDER THE POOLING AND SERVICING AGREEMENT DATED OCTOBER 1, 2006 PLAINTIFF VS MORTGAGE FORECLOSURE RALPH B. ZEIDERS AND GLORIA J. ZEIDERS DEFENDANTS AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSAPJO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSAPJO QUE USTED, 0 SU ABOGADO, .REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION ONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU ARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y EQUERIRA 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 IMMEDIATEAM ENTE. Lawyer Referral Services, 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 manci ni lawfi rm@attomeydani elmancini.com IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF THE RESIDENTIAL ASSET SECURITIZATION TRUST 2006-A14CB, MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2006-N UNDER THE POOLING AND SERVICING AGREEMENT DATED OCTOBER 1, 2006 PLAINTIFF VS CIVIL Division Case Number: 0 9- 4 L I Y MORTGAGE FORECLOSURE RALPH B. ZEIDERS AND GLORIA J. ZEIDERS DEFENDANTS L'ul -roll 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 UNTI 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. Daniel J. Mancini, Esq. Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 7284233 mancini lawfirm@attorneydanielman ci ni. com IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF THE RESIDENTIAL ASSET SECURITIZATION TRUST 2006-A14CB, MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2006-N UNDER THE POOLING AND SERVICING AGREEMENT DATED OCTOBER 1, 2006 PLAINTIFF VS CIVIL Division Case Number: O' Y- ?, G /c/ 0- ,_a 7? MORTGAGE FORECLOSURE RALPH B. ZEIDERS AND GLORIA J. ZEIDERS DEFENDANTS COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is: DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF THE RESIDENTIAL ASSET SECURITIZATION TRUST 2006-A14CB, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-N UNDER THE POOLING AND SERVICING AGREEMENT DATED OCTOBER 1, 2006, whose address is c/o Mancini & Associates, 201 A Fairview Drive, Monaca, PA 15061. 2. Defendants are RALPH B. ZEIDERS AND GLORIA J. ZEIDERS, whose last known address is 1814 LETCHWORTH DRIVE, CAMP HILL, PA 17011. RALPH B. ZEIDERS AND GLORIA J. ZEIDERS are the mortgagors and the recorded owners of the mortgaged property hereinafter described. 3. On or about, October 2, 2006, RALPH B. ZEIDERS AND GLORIA J. ZEIDERS borrowed $120,000.00 and in the enforcement of said debt executed and delivered a mortgage upon the premises hereinafter described to the lender MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR INDYMAC BANK, F.S.B., this mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County in Mortgage Record Book 1968, Page 3694. This mortgage is incorporated herein by reference in accordance with Pa. R.C.P. 1019 (g).Your plaintiff, DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF THE RESIDENTIAL ASSET SECURITIZATION TRUST 2006-A14CB, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-N UNDER THE POOLING AND SERVICING AGREEMENT DATED OCTOBER 1, 2006 is now the current owner of said mortgage, and the assignment evidencing this ownership will be sent for recording at a later date. 4. The land subject to the Mortgage is 1814 LETCHWORTH DRIVE, CAMP HILL, PA 17011, and is more particularly described in Exhibit "A", which is attached hereof and part of this Complaint. 5. The Mortgage is in default because monthly payments of principal and interest upon said mortgage due November 1, 2008, and each month thereafter are due and unpaid, and by the terms of said Mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. Unpaid Principal Balance $ 117,484.05 Interest at $22.13 per diem $ 8,084.56 From 10/01/08 to 10/01/09 (based on contract rate of 6.875%) Rec. Corp. Adv. $ 000.00 Escrow Advance $ 319.59 Accrued Late Charges $ 315.36 Bad Check Fees $ 00.00 Attorney's Fee $ 5,874.20 Total $ 132,077.76 ** Together with interest at the per diem rate noted above after November 1, 2008 and other charges and costs to date of Sheriff's Sale. The Attorney's Fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable, or that are actually incurred by Plaintiff. 6. No judgment has been entered upon said Mortgage in any jurisdiction. 7. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 or 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant on August 7, 2009, via certified and regular mail, in accordance with the requirements of those acts. 8. Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. 9. The Defendants have either failed to meet the time limitations as set forth under the Combined Act 6/91 Notice or have been determined by the Pennsylvania Housing Finance Agency not to qualify for Mortgage Assistance. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure `IN REM' for the aforementioned total amount due together with interest at the rate of 6.875% ($22.13 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described. Daniel J. ancini, Esq. Attorney Bar: PA 39353 EXHIBIT A ALL that certain lot or parcel of land situate in Lower Allen Township, Cumberland County, Pennsylvania, bounded and described in accordance with a plan of survey made by Ernest J. Walker, Professional Engineer, dated January 24, 1967, as follows: BEGINNING at a point on the Northerly side of Letchworth Olive (Fifty feet wide) at the line dividing Lots Nos. 21 and 22, Block d, on the hereinafter mentioned plan of lots, said point being Forty and Two-TeMhs feet (40.2) East of the intersection of the Northern line of Letchworth Drive with the projected center line of Nineteenth Street; thence along said dividing line North We degrees West ad distance of Two Hundred Forty-Eight and Ninety-Six One-Hundredths feet (248.96') to a point; thence extending North seventy-three degrees nine minvW East a distance of Forty-Nine and Sixty-Eight One-Hundredths feet (49.68') to a point; thence extending South sever, degrees twenty-nine minutes East a distance of Two Hundred Fifty-Sbe and Nine-Tenths feet (256.9') to a point on the Northerly side of Letchworth ,give; thence in a Westerly direction along the Northerly side of Letchworth Drive on the arc of a circel on a line curing to the rights having a radius of One Hundred Sixty-Fire feet (165'), the arc distance of Twenty Seven and Eighty-Three One-Hundredths feet to a point of tangent thence extending South eighty-fire degrees West Bull along the Northerly side of Letchworth Chive a distance of Thirty-Two and Seventeen One Hundredths feet (32, l7n) to a point, the place of BEGINNING. BONG Lot No. 22, Section D on Plan No. 5 of Highland Estates which Plan is recorded in Plan Book 4, Page 100, Cumberland County Records. HAVING thereon erected a one story stone dwelling known as 1814 Letchworth Drive- I Cry: ry t'1:s to be recorded In Curnberland County PA ",. Recorder of Deeds Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 manci ni lawfirm@attorneydanielmancin i. com IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST CIVIL Division COMPANY, AS TRUSTEE OF THE RESIDENTIAL ASSET SECURITIZATION Case Number: TRUST 2006-A14CB, MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2006-N UNDER THE POOLING AND SERVICING AGREEMENT DATED OCTOBER 1, 2006 PLAINTIFF VS MORTGAGE FORECLOSURE RALPH B. ZEIDERS AND GLORIA J. ZEIDERS DEFENDANTS VERIFICATION Daniel J. Mancini, Esq., hereby states that he is the attorney for Plaintiff in this matter, that He is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Further, counsel submits that Plaintiff is outside the court's jurisdiction and verification cannot be obtained with the time allowed for filing the pleading. It is counsel's intention to substitute a verification from Plaintiff. Dated this 1 ST Day of October, 2009 t?) Daniel J. ncini, Esq. Attorney Bar: Pa 39353 0 OF THE kED-OFF p T ! N'JTApt 2009 OCT -5 PM 12: 3 9 CUMBERLA,4 _ ??,UMY Pi,.NNSYLVARA $'78.50 Pa Arn c?. (0?43 Z14.3a 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 Company vs. Ralph B. Zeiders OFF OF °rE -ERIFF Case Number 2009-6614 SHERIFF'S RETURN OF SERVICE 10/27/2009 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: Gloria J. Zeiders, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Gloria J. Zeiders. Deputy's were advised the defendant is residing at 2748A Green Street Harrisburg, PA 17102. 10/27/2009 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: Ralph B. Zeiders, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Ralph B. Zeiders. Deputy's were advised the defendant is residing at 2748A Green Street Harrisburg, PA 17102. SHERIFF COST: $81.00 October 27, 2009 FILED-40F.CE CF TY;E pp'- ip; ',', 1004 CC7 28 Aft 9: 4 3 eulvsc? !ia r e'?? } ?` it ?f VJ r????i`Vlhi SO ANSWERS, R THOMAS KLINE, SHERIFF FlL~D-i~t^~~C~ c~~ ~E ~~?0?~-'O~QT'R~Y Daniel Mancini & Associates Daniel J. Mancini, Esq. PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724)728-4233 mancinilawfirm@attorneydanielmancini.com ZOl~ fE8 -5 P~ 2= 00 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF THE RESIDENTIAL ASSET SECURITIZATION TRUST 2006-A14CB, MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2006-N UNDER THE POOLING AND SERVICING AGREEMENT DATED OCTOBER 1, 2006 PLAINTIFF VS CIVIL Division Case Number: 09-6614 CIVIL TERM MORTGAGE FORECLOSURE RALPH B. ZEIDERS AND GLORIA J. ZEIDERS DEFENDANTS PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint for Mortgage Foreclosure in the above matter. DANIEL J. MANCINI, ESQUIRE ATTORNEY FOR PLAINTIFF O ~l0 . oo P o ATr! Cf~~" 83'7(0 ~ a.~133 a SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor ~~~; 1`r1~ Ot ~lY3t![t~~,~~~~~ .'r. ~~ rt~ ~Llr ~y~.r y n~, l-~*S ff i _ ~!f'V .~ Z~10 FED i 9 ,~~ S~ 53 ,~ `~i` L r i~ a o Deutsche Bank National Trust Company Case Number vs. Ralph B. Zeiders 2009-6614 SHERIFF'S RETURN OF SERVICE 02/08/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Ralph B. Zeiders, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Complaint in Mortgage Foreclosure according to law. 02!08/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Gloria J. Zeiders, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Complaint in Mortgage Foreclosure according to law. 02/16/2010 09:00 AM -Dauphin County Return: And now February 16, 2010 at 0900 hours 1, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do herby certify and return that 1 served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Ralph B. Zeiders by makinc known unto himself personally, at 2748A Green Street, Harrisburg, PA 17110 its contents and at the same time handing to him personally the said true and correct copy of the same. 02/16/2010 09:00 AM -Dauphin County Return: And now February 16, 2010 at 0900 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Gloria J. Zeiders by making known unto herself personally, at 2748A Green Street, Harrisburg, PA 17110 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $53.00 SO ANS ERS, f,.--~ ~J, February 18, 2010 ~' RO~ Y R ANDERSON, SHERIFF i .+JUim+ySuite 'v:^ESr~`. f, ie:!~osoft. Inc. Mary Jane Snyder Real Estate Depu .. William T. Tully t solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin . DEUTSCHE BANK NA VS RALPH B ZEIDERS Sheriff s Return No. 2010-T-0309 OTHER COUNTY NO. 20096614 Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy And now: FEBRUARY 16, 2010 at 9:00:00 AM served the within COMPLAINT IN MORTGAGE FORECLOSURE upon GLORIA J ZEIDERS by personally handing to GLORIA J ZEIDERS 1 true attested copy of the original COMPLAINT IN MORTGAGE FORECLOSURE and making known to him/her the contents thereof at 2748A GREEN STREET HARRISBURG PA 17110 Sworn and subscribed to before me this 16TH day of February, 2010 ~/ N.'~TARIAL SEAL ARY JANE SNYDER, Notary Public Highspire, Dauphin County M Commission Ex Tres Set 1; 2010 So Answers, ~~~~~~ Sheri oauphin County, Pa. ea 13 ~. Deput~ Sheriff ~ _,~~~ ~,'~~, Deputy: D ARTHUR Sheriffs Costs: $66.5 2/11/2010 Mary Jane Sn~der Real Estate Depu :: William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin DEUTSCHE BANK NA VS RALPH B ZEIDERS Sheriff s Return No. 2010-T-0309 OTHER COUNTY NO. 20096614 Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy And now: FEBRUARY 16, 2010 at 9:00:00 AM served the within COMPLAINT IN MORTGAGE FORECLOSURE upon RALPH B ZEIDERS by personally handing to RALPH B ZEIDERS 1 true attested copy of the original COMPLAINT IN MORTGAGE FORECLOSURE and making known to him/her the contents thereof at 2748A GREEN STREET HARRISBURG PA 17110 Sworn and subscribed to before me this 16TH day of February, 2010 ~/ NOTARIAL SEAL RY JANE SNYDER, Notary Publi Highspire, Dauphin County M Commission Ex fires Set 1, 2010 So Answers, ~~~~~~ Sherit# of Dauphin County ~~- ~~ ~: . r ,~~ By `~ ~'~T Deput~iff Deputy: D ARTHUR Sheriffs Costs: $66.5 2/11/2010 In The Court of Common Pleas of Cumberland County, Pennsylvania Deutsche Bank, NA vs. Ralph B. & Gloria J. Zeiders 2748A Green Street Harrisburg, PA 17110 Civil No. 2009-6614 Now, February S, 2010, I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. -.+~+.. Sheriff of Cumberland County, PA Affidavit of Service Now, , 20 , at o'clock M, served the within upon at by handing to and made known to Sworn and subscribed before me this day of ,20_ So answers, Sheriff of COSTS SERVICE_ MILEAGE_ AFFIDAVIT copy of the original, the contents thereof. County, PA ? may Daniel Mancini & Associates Daniel J. Mancini, Esq. PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 mancinilawfirm@attomeydanielmancini.com r r s-Or rc _ r "c PROTHONOTAR''f 2011 MAR 31 AM 11 49 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF THE RESIDENTIAL ASSET SECURITIZATION TRUST 2006-A14CB, MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2006-N UNDER THE POOLING AND SERVICING AGREEMENT DATED OCTOBER 1, 2006 PLAINTIFF VS CIVIL Division Case Number: 09-6614 CIVIL TERM MORTGAGE FORECLOSURE RALPH B. ZEIDERS AND GLORIA J. ZEIDERS DEFENDANTS PRAECIPE TO WITHDRAW To the Prothonotary: Kindly enter my withdraw as attorney for plaintiff in the above captioned matter `7 Daniel J. MancEsq. I.D # 39353 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 KEVIN T. MCQUAH,, ESQUIRE - ID # 307169 c CHRISTINE L. GRAHAM - ID # 309480 c 123 South Broad Street, Suite 2080 M CD Philadelphia, Pennsylvania 19109 Mss (215) 790-1010 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF THE RESIDENTIAL ASSET SECURITIZATION TRUST 2006-A14CB, MORTGAGE PASS- THROUGH CERTIFICATIONS, SERIES 2006-N UNDER THE POOLING AND SERVICING AGREEMENT DATED OCTOBER 1, 2006 PLAINTIFF V. RALPH B. ZEIDERS and GLORIA J. ZEIDERS DEFENDANTS <Q COURT OF COMMON PLEAftd OF CUMBERLAND COUNTW"-- --r NO.: 09-6614 CIVIL TERM MORTGAGE FORECLOSURE ENTRY OF APPEARANCE TO THE PROTHONTARY: r-.> w M& .c- mac: C1-, C Kindly enter the appearance of McCabe, Weisberg & Conway, P.C. as counsel in the above referenced action on behalf of Plaintiff, DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE. Andrew L. Markowitz, Esquire Attorney for Plaintiff, Deutsche (Bank National Trust Company, as Trustee Date: March 29, 2011 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 KEVIN T. MCQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM - ID # 309480 123 South Broad Street, Suite 2080 Attorneys for Plaintiff Philadelphia, Pennsylvania 19109 (215) 790-1010 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF THE RESIDENTIAL ASSET SECURITIZATION TRUST 2006-A14CB, MORTGAGE PASS- THROUGH CERTIFICATIONS, SERIES 2006-N UNDER THE POOLING AND SERVICING AGREEMENT DATED OCTOBER 1, 2006 PLAINTIFF COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-6614 CIVIL TERM MORTGAGE FORECLOSURE V. RALPH B. ZEIDERS and GLORIA J. ZEIDERS DEFENDANTS CERTIFICATE OF SERVICE I, ANDREW L. MARKOWITZ, Esquire, attorney for Plaintiff, hereby certify that a true and correct copy Plaintiff's Entry of Appearance was served on the below parties on the 29`h day of March, 2011 by the United states mail, first class: Ralph B. Zeiders Gloria J. Zeiders 1814 Letchworth Drive Camp Hill, PA 17011 DATE: March 29.2011 ANDREW L. MARKOWITZ, ES IRE WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-6614 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF THE RESIDENTIAL ASSET SECURITIZATION TRUST 2006-A14CB, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-N UNDER THE POOLING AND SERVICING AGREEMENT DATED OCTOBER 1, 2006 Plaintiff (s) From RALPH ZEIDERS AND GLORIA ZEIDERS (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 $138,475.03 Interest FROM 03/26/10 $12,085.56 AT $22.76 Atty's Comm % Atty Paid $263.00 Plaintiff Paid Date: 5/25/11 (Seal) REQUESTfNG PARTY: L.L. $.50 Due Prothy $2.00 Other Costs C David D. Buell, Pr thonotary By: Name: TERRENCE MCCABE, ESQUIRE Address: MCCABE, WEISBERG AND CONWAY 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Deputy Supreme Court ID No. 16496 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION Deutsche Sank National Trust Company, As Trustee. Of The Residential Asset Securitization Trust 2006-A 14CB, Mortgage Pass-Through Certificates, Series 2006-N Under the Pooling and Servicing Agreement Dated October 1, 2006 Ralph Zeiders and Gloria Zeiders FILE NO.: Gq- IP19,141 _ Civil Term AMOUNT DUE: $ 1 75,./13 INTEREST: from 03/26/10 $12,085.56 at $22.76 ATTY'S COMM.: COSTS: W (7 N = = 3 rrn m ,1C X M Z• cnr' tv -<? cn 2C I c,rt TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) 1814 Letchworth Drive Camp Hill Pennsylvania 17011 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: May 19, 2011 L9 # ?Wv0 A'ly # ?(• G D AA 4 573•aa ,4 N ZU .f A,0&3. DU p0' A 'a?# a07 7Z Signature: / Print Name: MCCABE, WEISBERG AND CONWAY Address: 123 S. Broad Street, Suite 2080 Philadelphia. PA 19109 Attorney for: Plaintiff Telephone: (215) 790 1010 Supreme Court ID No. ,f X1)V_ C? --t rn r ..0C) ?D ° C, 4° s 3?Fri 3/a5'ir• ?u/ltL? ?nt? Spda 4el r? McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Deutsche Bank National Trust Company, As Trustee Of The Residential Asset Securitization Trust 2006-A14CB, Mortgage Pass-Through Certificates, Series 2006-N Under the Pooling and Servicing Agreement Dated October 1, 2006 Plaintiff V. Ralph Zeiders and Gloria Zeiders Defendants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COWO tV PLEAS_ Z? ? r?t? NO: 09-6614 r tars y„ cn te r ? r- ---? c? C-) 3 ` ! ?p , c-? --? cn AFFIDAVIT PURSUANT TO RULE 3129 The undersigned, attorney for Plaintiff in the above action, sets forth the following information concerning the real property located at: 1814 Letchworth Drive, Camp Hill, Pennsylvania 17011, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property being attached hereto. Name and address of Owners or Reputed Owners Name Address Ralph Zeiders 278A Green Street Harrisburg, Pennsylvania 17110 Gloria Zeiders 278A Green Street Harrisburg, Pennsylvania 17110 2. Name and address of Defendants in the judgment: Name Address Ralph Zeiders 278A Green Street Harrisburg, Pennsylvania 17011 Gloria Zeiders 278A Green Street Harrisburg, Pennsylvania 17110 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Address Mortgage Electronic Registration P.O. Box 2026 Systems, as nominee for Indymac Flint, Michigan 48501 Bank Mortgage Electronic Registration 155 N. Lake Avenue Systems, Inc., as nominee for Indymac Pasadena, California 91110 Bank 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants/Occupants Address 1814 Letchworth Drive Camp Hill, Pennsylvania 17011 Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 8`h Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriffs Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 Domestic Relations P.O. Box 320 Cumberland County Carlisle, PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States Name and address of Attorney of record: Name U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 Address None I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to author' 'es. May 19, 2011 TERRENCE J. McCABE, ESQUIRE DATE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff MCCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 CIVIL ACTION LAW C N C C) Deutsche Bank National Trust Company, As Trustee COURT OF COMMON PLEAS `-93 Of the Residential Asset Securitization Trust MW ,. rrtr- 2006-A14CB, Mortgage Pass-Through Certificates, CUMBERLAND COUNTY N 7 Series 2006-N Under the Pooling and Servicing c n Agreement Dated October 1, 2006 r" x `tt v Number 09-6614 Cl ? _n ? F5 Ralph Zeiders and Gloria Zeiders r NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Ralph Zeiders Gloria Zeiders 278A Green Street 278A Green Street Harrisburg, Pennsylvania 17011 Harrisburg, Pennsylvania 17110 Your house (real estate) at 1814 Letchworth Drive, Camp Hill, Pennsylvania 17011 is scheduled to be sold at Sheriffs Sale on September 7, 2011 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment of $ 138, 475.030 obtained by Deutsche Bank National Trust Company, As Trustee Of The Residential Asset Securitization Trust 2006-A 14CB, Mortgage Pass-Through Certificates, Series 2006-N Under the Pooling and Servicing Agreement Dated October 1, 2006 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: The sale will be canceled if you pay to Deutsche Bank National Trust Company, As Trustee Of The Residential Asset Securitization Trust 2006-A 14CB, Mortgage Pass-Through Certificates, Series 2006-N Under the Pooling and Servicing Agreement Dated October 1, 2006 the back payments, late charges, costs, and reasonable attorney's fees due. To fmd out how much you must pay, you may call McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty (30) days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the schedule of distribution. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 LEGAL DESCRIPTION ALL #hst aeftn lot Ot peel of lead sib In Lower Alm Township, Cum Wend C+ourdy. Penneovanig, bounded and described fa accardw" WM a pion C(" made, by Ernest J. bier, ProfosOmal Enginew, dated ,Janusfy 24, 1,9137, as fi OW0. BEC1NWKG-elt a point on the Nay silo of LOWMeft. Ddve (Fifty feet wide) at the Me dh'Mft LA* No& 21 and 22, Okick d, on t#* herkgr amt and ptarti of kft 6814 POW bung Forty acrd TWo-Tsnft fit (44.2p of toe Marti of the Noffimn R? aLothWdrb DAM va the p v*ft taW1W ins of Nk tMe -Ncuth Try Hund e d Forty-ftht and Ninegr-fc One-Hunk t -048.W) to a paint BMW axterxtiifig North aeuanty- hw ? nine mlrrt?es Eat t di?+ae of Fvr?p-i?Ikre, OW i t d?rte-Fharrdr Bra feet (49.88' b a PON; 8>lrros SOW dWM tyrenttr-nira minutes Soot a dbwm of Two Hundred F" Mr*-Tanft Abet " to 9 paintan MO Nptthe * side at l r**wwo oft them 'n 8 Weshatty dtifttiatr SWO the ftftO side of Leid wriA Grit's on the = of a 6'cel on s 60 ding b the fthfa having a Md1w of the HLmdred Sb**%* jt (1051 the arc dkhmoe of Twentyu&aretir &A fthqTtVft One.Hu s feet to,* 1xint Of k thencat extrwdlrtig SO* sip ft ftraessVVnt ON *M the Northe* shit oflsbd worth d a *WW cat Tltilety`'TWO acrd Sanenteon cote. Hum feet (3Z 17') to a point the pietas of gMNNING, WNG Lot No. 22. Secft Q on Man No. 8 of HVOWW Elsa vd joh plan is Moorded in Plan Bftk 4. Page 104, n d County Rem*, HALVING ihemon ereoW a orw story One d Mft known as 1894 Lem *tImL 1814 Letchworth Drive, Camp Hill, Pennsylvania 17011. BEING the same premises which BETTY L. HUNSTOCKER, WIDOW, JOSEPH C. BENDER AND JOANNE M. BENDER, HUSBAND AND WIFE AND GERALD R. ROBBINS AND VIRGINIA L. ROBBINS, HUSBAND AND WIFE by deed dated June 24, 1987 and recorded June 29, 1987 in the office of the Recorder in and for Cumberland County in Deed Book T32, Page 406, granted and conveyed to Ralph Zeiders and Gloria Zeiders, husband and wife, in fee. TAX MAP PARCEL NUMBER: 13230547206 LEGAL DESCRIPTION ALL that c;erWn lot or pamel of r situft to Lower Allen Township, Cu nd County. Penne"ania, bounded and wed in wwr4ence with a plan of eeavsyr rmW*.byf Ernest J. Vtd er, Pr omal &Vinw, dated January 24, 1867, as fdtbwa: BEOINNNG st a point on the Northerly side of Letrhwoft Orh a (FIRy feet wide) at the 11M dim LAO NO& 21 and 22, Mock #y, on tho herd nmftW plan of . said poft bell Forty and Two-Tents 1W_(40. t of on inters aon of th# Noffm r Hne of t lktoworth MV WM the pr*cted balm In of Nimlteenth Stmt; lhmte aWg ,said dhridirg line North be 4"reft Wheat ad dbtafte of Two Hundred Forly4ftht and Ninety k O n e -Hun rl f o r 48.W) io a point ow m e n+ N serwty.8 M d$90M nine mirwbs Most is dkbmm of ft*-Nkm stud Sb4%f*t Oft-Huncinuflho fief (40.061 b a paint; tam $owrth saran de+proes tr-nirw minute Soot a dkunrai of Two Hur ?F". od MwTwft filet (MM to a point on he Nute* We of LGWNM M i ; therms in a Westerlydlr6clan almV 1he NorbeAt of LaW rk 06a on the am of a ckW on a~ bw curing b the ft hip tovinp a radtua of One Hundred Ste. lket (1661 the on disbnm of Twen*8ew awl EoWy-Throe CmMur is bw to a point of haltr ?' lthence sbdwwatwe SoM $ ? r?s?es W4* stAt dwq the Nort side of TMV-7% and Hu la %et (37- 1T) to a point the plane of NE{#Ii?INNdo.' N??n ?r1e- SONG Lot No. 22, 88dJ n Q on Flan No. S of HishWM adman which elm is recorded in Plan Book 4, Pie 100, CurnberrWM County Reoords. HAVING tharoon erected a Oros ft q stone dweIRV 10M M as 1814 LOWWKrpt t]". 1814 Letchworth Drive, Camp Hill, Pennsylvania 17011. BEING the same premises which BETTY L. HUNSTOCKER, WIDOW, JOSEPH C. BENDER AND JOANNE M. BENDER, HUSBAND AND WIFE AND GERALD R. ROBBINS AND VIRGINIA L. ROBBINS, HUSBAND AND WIFE by deed dated June 24, 1987 and recorded June 29, 1987 in the office of the Recorder in and for Cumberland County in Deed Book T32, Page 406, granted and conveyed to Ralph Zeiders and Gloria Zeiders, husband and wife, in fee. TAX MAP PARCEL NUMBER: 13230547206 McCABE, WEISBERG & CONWAY, P.C. TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Deutsche Bank National Trust Company, As Trustee Of The Residential Asset Securitization Trust 2006-A14CB, Mortgage Pass-Through Certificates, Series 2006-N Under the Pooling and Servicing Agreement Dated October 1, 2006 Plaintiff V. Ralph Zeiders and Gloria Zeiders Defendant Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 09-6614 AFFIDAVIT OF SERVICE OF AMENDED AFFIDAVIT PURSUANT TO RULE 3129 C a rn _ _ M ? c?n`•r" r- -°r i r UO o f Q C3 r ,r.ti Sa. ZZ: • - The undersigned attorney for the Plaintiff in the within matter, hereby certifies that on the 6th day of July, 2011, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s) as set forth in Amended Affidavit Pursuant to 3129 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part hereof. SWORN AND SUBSCRIBED BEFORE ME THIS ?? DAY OF ?y LkA , 2011 P 1 . McCABE, W RG , P.C. NOTARY UBLIC Attorneys fof"intig "'701 # A NwEALTH Or PENNSYLVANIA By' v O -1'A F". i A L :? E A !. TE RAINC + J. McCABE, ESQUIRE - I QD176 Megan C. Paofucci -Notary Public MARC S. WEISBERG, ESQUIRE - ID Cfty of Philadelphia, Philadelphia County EDWARD D. CONWAY, ESQUIRE - IMY COMMISSION EX IRES JAN. 06, 2014 MARGARET GAIRO, ESQUIRE - ID # 34419 McCABE, WEISBERG & CONWAY, P.C. TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Deutsche Bank National Trust Company, As Trustee Of The Residential Asset Securitization Trust 2006-A14CB, Mortgage Pass-Through Certificates, Series 2006-N Under the Pooling and Servicing Agreement Dated October 1, 2006 Plaintiff V. Ralph Zeiders and Gloria Zeiders Defendants Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 09-6614 AMENDED AFFIDAVIT PURSUANT TO RULE 3129 The undersigned attorney for Plaintiff in the above action sets forth the following information concerning the real property located at 1814 Letchworth Drive, Camp Hill, Pennsylvania 17011, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property is attached hereto. Name and address of Owners or Reputed Owners Name Address Ralph Zeiders 278A Green Street Harrisburg, Pennsylvania 17110 Gloria Zeiders 278A Green Street Harrisburg, Pennsylvania 17110 2. Name and address of Defendants in the judgment: Name Address Ralph Zeiders 278A Green Street Harrisburg, Pennsylvania 17011 Gloria Zeiders 278A Green Street Harrisburg, Pennsylvania 17110 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Address Mortgage Electronic Registration P.O. Box 2026 Systems, as nominee for Indymac Flint, Michigan 48501 Bank Mortgage Electronic Registration 155 N. Lake Avenue Systems, Inc., as nominee for Indymac Pasadena, California 91110 Bank 5. Name and address of every other person who has any record lien on the property: Name Address 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants/Occupants Address 1814 Letchworth Drive Camp Hill, Pennsylvania 17011 Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 8`h Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg, PA 17128-1230 Compliance ATTN: Sheriff's Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 Domestic Relations P.O. Box 320 Cumberland County Carlisle, PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States Name and address of Attorney of record: Name U. S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 Address I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. McCABE, WE' /? & / W?jY, P.C. July 6, 2011 Attorneys fo 1 DATE By. E TERRACE J. MXABE, + QU MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Deutsche Bank National Trust Company, As Trustee Of The Residential Asset Securitization Trust 2006-A 14CB, Mortgage Pass-Through Certificates, Series 2006-N Under the Pooling and Servicing Agreement Dated October 1, 2006 Plaintiff V. Ralph Zeiders and Gloria Zeiders Defendants DATE: July 6, 2011 TO: ALL PARTIES IN INTEREST AND CLAIMANTS Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 09-6614 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS: Ralph Zeiders and Gloria Zeiders PROPERTY: 1814 Letchworth Drive, Camp Hill, Pennsylvania 17011 IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriffs Sale on September 7, 2011 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty (30) days after sale. 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McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Deutsche Bank National Trust Company, As Trustee Of The Residential Asset Securitization Trust 2006-A14CB, Mortgage Pass-Through Certificates, Series 2006-N Under the Pooling and Servicing Agreement Dated October 1, 2006 Plaintiff V. Ralph Zeiders and Gloria Zeiders Defendants Attorneys for Plaintiff Cumberland County Court of Common Pleas Number 09-6614 MOTION TO ALLOW SERVICE ON THE DEFENDANTS PURSUANT TO PA RULE OF CIVIL PROCEDURE 430 Plaintiff attempted to personally serve a true and correct copy of the Notice of Sheriffs Sale of Real Property upon the Defendant, Ralph Zeiders, at his/her last-known address of 278A Green Street, Harrisburg, Pennsylvania 17110. The process server was not able to serve the Defendant because the defendant moved and left no forwarding address. Plaintiff attempted to personally serve a true and correct copy of the Notice of Sheriffs Sale of Real Property upon the Defendant, Gloria Zeiders, at his/her last-known address of 278A Green Street, Harrisburg, Pennsylvania 17110. The process server was notable to serve the Defendant because the defendant moved and left no forwarding address. A true and correct copy of the Return of Service indicating the same is attached hereto, made a part hereof as Exhibit "A". 2. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has conducted a good faith investigation to determine the current whereabouts of Defendants and the attached Affidavit sets forth in detail the nature and extent of the investigation. See Affidavit of Good Faith Investigation attached hereto and marked Exhibit "B". As a result of the investigation, a special Order of Court is required permitting service by regular and certified mail at the Defendants last known address and by posting a copy of the original process on the mortgaged premises. 4. No judge has ruled upon any other issue in this matter or in any related matter. No attorney has entered an appearance in this matter on behalf of Defendants and, therefore, no concurrence of opposing counsel was sought with regard to the instant motion. 6. If service cannot be made on the Defendants, Ralph Zeiders and Gloria Zeiders, the Plaintiff will be prejudiced. WHEREFORE, Plaintiff prays this Honorable Court grant an Order allowing the Plaintiff to serve the Notice of Sheriffs Sale of Real Property, and all other subsequent pleadings that require personal service, and the Notice of Sheriff's Sale upon the Defendants Ralph Zeiders and Gloria Zeiders, by regular mail; certified mail, return receipt requested; and by posting at the last-known address of Defendants and the mortgaged premises known in this herein action as 1814 Letchworth Drive, Camp Hill, Pennsylvania 17011. n f 'W, (' TERRENCE U. MCCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE HEIDI R. SPIVAK, ESQUIRE Attorneys for Plaintiff MCCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Deutsche Bank National Trust Company, As Trustee Of The Residential Asset Securitization Trust 2006-A 14CB, Mortgage Pass-Through Certificates, Series 2006-N Under the Pooling and Servicing Agreement Dated October 1, 2006 Plaintiff V. Ralph Zeiders and Gloria Zeiders Defendants Attorneys for Plaintiff Cumberland County Court of Common Pleas Number 09-6614 MEMORANDUM OF LAW If a resident Defendant has obstructed or prevented service of process by concealing his whereabouts or otherwise, the Plaintiff shall have the right of service in such a manner as the Court by special order shall direct service pursuant to P.R.C.P. 430. WHEREFORE, Plaintiff prays this service be made. TERRENCE . McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET CAIRO, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE HEIDI R. SPIVAK, ESQUIRE Attorneys for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Deutsche Bank National Trust Company, As Trustee Of The Residential Asset Securitization Trust 2006-A 14CB, Mortgage Pass-Through Certificates, Series 2006-N Under the Pooling and Servicing Agreement Dated October 1, 2006 Plaintiff V. Ralph Zeiders and Gloria Zeiders Defendants Attorneys for Plaintiff Cumberland County Court of Common Pleas Number 09-6614 CERTIFICATION OF SERVICE The undersigned attorney for the Plaintiff hereby certifies that he/she served a true and correct copy of the foregoing Motion for Alternative Service, by United States Mail, first class, postage prepaid, on the 17th day of August, 2011, upon the following: Ralph Zeiders 1814 Letchworth Drive Camp Hill, Pennsylvania 17011 Gloria Zeiders 1814 Letchworth Drive Camp Hill, Pennsylvania 17011 ESQUIRE MARGARET GAIRO, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE HEIDI R. SPIVAK, ESQUIRE Attorneys for Plaintiff q I a M-A TERRENCE EDWARD D. . CONWAY, McCABE, ESQUIRE MARC S. W ISBERG, ESQUIRE VERIFICATION The undersigned attorney hereby certifies that he/she is the attorney for the Plaintiff in the within action and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative, who is out of this jurisdiction and not available to sign this verification at this time, and are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to un worn falsification to authorities. TERRENC J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE HEIDI R. SPIVAK, ESQUIRE Attorneys for Plaintiff EXHIBIT A SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sherd '?'Ooly of t+nbrr?a?4 OFFICE OF THE "4-RIFF rltc.?I-kQ-- Jody S Smith Chief Deputy Richard W Stewart Solicitor Deutsche Bank National Trust Company Case Number vs. Ralph B. Zeiders (et al.) 2009-6614 S1 ERWWS-RETURN OF SERVICE 06/23/2011 08:10 PM - Deputy Shawn Gutshall, being duly swom according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 1814 Letchworth Drive, Camp Hill, PA 17011, Cumberland County. 07/05/2011 Ronny R. Anderson, Sheriff, being duly swom according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Ralph B. Zeiders, but was unable to locate the Defendant it his bailiwick. He therefore deputized the Sheriff of Dauphin County to serve the within Real Estate Writ, Notice and Description, in the above titled action, according to law. 07/05/2011 The requested Real Estate Writ, Notice and Description, in the above titled action, returned by the Sheriff of Dauphin County, the within named Defendant Ralph B. Zeiders, not found. So Answers: B. Hunter, Deputy Sheriff, per Rental Office at address stated, defendants moved, left no forwarding. 07/05/2011 Ronny R. Anderson, Sheriff, being duly swom according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Gloria J. Zeiders, but was unable to locate the Defendant in his bailiwick. He therefore deputized the Sheriff of Dauphin County to serve the within Real Estate Writ, Notice and Description, in the above titled action, according to law. 07/05/2011 The requested Real Estate Writ, Notice and Description, in the above titled action, returned by the Sheriff of Dauphin County, the within named Defendant Gloria Zeiders, not found. So Answers: B. Hunter, Deputy Sheriff, per Rental Office at address stated, defendants moved, left no forwarding. SHERIFF COST: $917.94 July 05, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF (c) CountySuite ShenfP. Teleosoft. Inc. Attorney Outsourcing Support Services, Inc. Suite 2040 123 S. Broad Street Philadelphia, PA 19109 (215) 790-5964 FAX (215) 320-5770 AFFIDAVIT OF GOOD FAITH INVESTIGATION SUBJECT OF INVESTIGATION: Zeiders, Gloria CLIENT: McCabe, Weisberg and Conway, P.C. FILE #: 55529 MATTER #: 293-0774 AOSS FILE#: 11-6965 SUBJECT'S LAST-KNOWN ADDRESS: 278A Green Street, Harrisburg, PA, 17110 SUBJECT'S PROPERTY ADDRESS: 1814 Letchworth Drive, Camp Hill, PA 17011 I, Stephen Fattori, being duly sworn according to law, depose and say that Attorney Outsourcing Support Services, Inc. completed a good faith investigation into the whereabouts of the above-named subject and the extent of the investigation and the results are as follows: INQUIRY OF POSTAL AUTHORITY: 278A Green Street, Harrisburg, PA, 17110 - Moved, left no forwarding address. 1814 Letchworth Drive, Camp Hill, PA 17011 - Not known at address given. Page 2 Investigation of Zeiders. Gloria continued: (subject name) 2. INQUIRY OF LOCAL TELEPHONE COMPANY; Directory Assistance: Directory assistance had no listing for the subject. 3. INTERNET SEARCH: Search shows no address for the subject. 4. DEATH RECORDS: Social Security has no death record for the subject. 5. LOCAL TAX RECORD INQUIRY: Tax bill is mailed to the subject at the above stated last-known address. 6. INQUIRY OF COUNTY VOTER REGISTRATION: After inquiry, I was unable to confirm a listing with the County Voters Registration Office for this subject. Page 3 Investigation of Zeiders. Gloria continued: (subject name) INQUIRY OF NEIGHBORS: I was unable to identify any neighbors who could verify any further information. The information set forth in this Affidavit of Good Faith Investigation is true and correct to the best of my knowledge, information, and belief. BY: ,w NAME: Stephen Fattori M.1 TITLE: Location Specialist DATE: August 12, 2011 Notary Public: Sworn to and subscribed before me this JLlrh- day of , 2011 13 -, 1}.'^`•,;'. ±w GF 11FPJ ?SYLYANIA NoTAJREAL SEAL Megan C. Paolucci - NLary Public cRy of Philadetphia, Philadelphia County MY COMMISSION EXPIRES JAN. 06, 2014 Postmaster Date July 29, 2011 Camp Hill, PA 17011 City, State, ZIP Code Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or the name and street address (if a boxholder) for the following: Name: Zeiders, Gloria Address: 1814 Letchworth Drive. CamQHill, PA 17011 NOTE: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 265.6(d)(6xii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester (e.g. process server, attorney, party representing himself): attorney 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or party acting pro se - except a corporation acting pro se must cite statute): Not applicable. Requester is an attorney 3. The names of all known parties to the litigation: v. Zeiders. Ralph and Zeiders. Gloria 4. The court in which the case has been or will be heard: CUMBERLAND. PA 5. The docket or other identifying number if one has been issued: NO: 6. The capacity in which this individual is to be served (e.g. defendant or witness): Defendant WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). PLEASE PROVIDE THE CORRECT ADDRESS FOR THE DEFENDANT. I certify that the above information is true and that the address information is needed and will be used solely for service of legal pr ess in connection with actual or prospective litigation. 123 S. Broad Street. Suite 2050 Signature Address Stephen Fattori. AOSS Philadelphia. PA 19109 Printed Name City, State, ZIP Code FOR POST OFFICE USE ONLY NEW ADDRESS or BOXHOLDER'S NAME and No change of address order on file. PHYSICAL STREET ADDRESS Not known at address given. Moved, left no forwarding address. No such address. Good As Addressed 11, 6 711 ,- Postmaster Date July 29, 2011 Harrisburg. PA 17110 City, State, ZIP Code Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or the name and street address (if a boxholder) for the following: Name: Zeiders. Gloria Address: 278A Green Street, Harrisburg. PA 17110 NOTE: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester (e.g. process. server, attorney, party representing himself): attorney 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or party acting pro se - except a corporation acting pro se must cite statute): Not applicable. Requester is an attorney 3. The names of all known parties to the litigation: v. Zeiders, Ralph and Zeiders. Gloria 4. The court in which the case has been or will be heard: CUMBERLAND. PA 5. The docket or other identifying number if one has been issued: NO: 6. The capacity in which this individual is to be served (e.g. defendant or witness): Defendant WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). PLEASE PROVIDE THE CORRECT ADDRESS FOR THE DEFENDANT. I certify that the above information is true and that the address information is needed and will be used solely for service of legal Zes in connection with actual or prospective litigation. 123 S. Broad Street. Suite 2050 Signature Address Stephen Fattori, AOSS Philadelphia, PA 19109 Printed Name City, State, ZIP Code FOR POST OFFICE USE ONLY No change of address order on file. Not known at address given. Moved, left no forwarding address. No such address. Good As Addressed NEW ADDRESS or BOXHOLDER'S NAME and PHYSICAL STREET ADDRESS vTf,- Attorney Outsourcing Support Services, Inc. Suite 2040 123 S. Broad Street Philadelphia, PA 19109 (215) 790-5964 FAX (215) 320-5770 AFFIDAVIT OF GOOD FAITH INVESTIGATION SUBJECT OF INVESTIGATION: Zeiders, Ralph CLIENT: McCabe, Weisberg and Conway, P.C. FILE #: 55529 MATTER #: 293-0774 AOSS FILE#: 11-6965 SUBJECT'S LAST-KNOWN ADDRESS: 278A Green Street, Harrisburg, PA, 17110 SUBJECT'S PROPERTY ADDRESS: 1814 Letchworth Drive, Camp Hill, PA 17011 I, Stephen Fattori, being duly sworn according to law, depose and say that Attorney Outsourcing Support Services, Inc. completed a good faith investigation into the whereabouts of the above-named subject and the extent of the investigation and the results are as follows: 1. INQUIRY OF POSTAL AUTHORITY: 278A Green Street, Harrisburg, PA, 17110 - Moved, left no forwarding address. 1814 Letchwortb Drive, Camp Hill, PA 17011- Not known at address given. Page 2 Investigation of Zeiders. Ralpb continued: (subject name) 2. INQUIRY OF LOCAL TELEPHONE COMPANY; Directory Assistance: Directory assistance had no listing for the subject. INTERNET SEARCH: Search shows no address for the subject. 4. DEATH RECORDS: Social Security has no death record for the subject. LOCAL TAX RECORD INQUIRY: Tax bill is mailed to the subject at the above stated last-known address. INQUIRY OF COUNTY VOTER REGISTRATION: After inquiry, I was unable to confirm a listing with the County Voters Registration Office for this subject. Page 3 Investigation of Zeiders. Ralah continued: (subject name) INQUIRY OF NEIGHBORS: I was unable to identify any neighbors who could verify any further information. The information set forth in this Affidavit of Good Faith Investigation is true and correct to the best of my knowledge, information, and belief. BY: NAME: Stephen Fattori Priet TITLE: Location Specialist DATE: August 12 2011 Notary Public: Sworn to and subscribed before me this l aih day of f-t 2011 C' C ? I?S+ \ C I Jl. C..eMMO n?!? n. TN rF pEWNSYIVANiA `g??-xi? SEAL ! vegan C. Fe?*Cdl-Notary Public CP, d pMadelph e, Philadelphia County "Y :SIC': ?''iRES JAN. 06, 2014 Postmaster Date JuIY 29.2011 Camp Hill, PA 17011 City, State, ZIP Code Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please famish the new address or the name and street address L a boxholderl for the following: Name: Zeiders. Ralph Address: 1814 Letchworth Drive, Camp Hill. PA 17011 NOTE: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester (e.g. process server, attorney, party representing himself): attorney 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or party acting pro se - except a corporation acting pro se must cite statute): Not applicable. Requester is an attorney 3. The names of all known parties to the litigation: v. Zeiders. Ralph and Zeiders. Gloria 4. The court in which the case has been or will be heard: CUMBERLAND. PA 5. The docket or other identifying number if one has been issued: NO: 6. The capacity in which this individual is to be served (e.g. defendant or witness): Defendant WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). PLEASE PROVIDE THE CORRECT ADDRESS FOR THE DEFENDANT. I certify that the above information is true and that the address information is needed and will be used solely for service of legal pro ess in connection with actual or prospective litigation. AS, -? 123 S. Broad Street. Suite 2050 Signature Address Stephen Fattori, AOSS Philadelphia. PA 19109 Printed Name City, State, ZIP Code FOR POST OFFICE USE ONLY No change of address order on file. Not known at address given. Moved, left no forwarding address. No such address. Good As Addressed NEW ADDRESS or BOXHOLDEWS NAME and PHYSICAL STREET ADDRESS v r., , A Postmaster Date July 29, 2011 Harrisburg, PA 17110 City, State, ZIP Code Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or the name and street address (if a boxholder) for the following: Name: Zeiders. Ralth Address: 278A Green Street. Harrisburg. PA 17110 NOTE: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester (e.g. process server, attorney, party representing himself): attorney 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or party acting pro se - except a corporation acting pro se must cite statute): Not applicable. Requester is an attorney 3. The names of all known parties to the litigation:_ v. Zeiders. Ralph and Zeiders. Gloria 4. The court in which the case has been or will be heard: CUMBERLAND. PA 5. The docket or other identifying number if one has been issued: NO: 6. The capacity in which this individual is to be served (e.g. defendant or witness): Defendant WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). PLEASE PROVIDE THE CORRECT ADDRESS FOR THE DEFENDANT. I certify that the above information is true and that the address information is needed and will be used solely for service of legal rocess in connection with actual or prospective litigation. 123 S. Broad Street. Suite 2050 Signature Address Stephen Fattori, AOSS Philadelphia. PA 19109 Printed Name City, State, ZIP Code FOR POST OFFICE USE ONLY No change of address order on file. Not known at address given. J Moved, left no forwarding address. No such address. Good As Addressed 0 T? NEW ADDRESS or BOXHOLDER'S NAME and PHYSICAL STREET ADDRESS //-c.. sly r J. ., 0 t Deutsche Bank National Trust Company, As Trustee Of The Residential Asset Securitization Trust 2006-A 14CB, Mortgage Pass-Through Certificates, Series 2006-N Under the Pooling and Servicing Agreement Dated October 1, 2006 Plaintiff V. Ralph Zeiders and Gloria Zeiders Defendants Cumberland County Court of Common Pleas - 3 s GI, -? r . rx ? 35 Number 09-6614 I A ORDER AND NOW, this Ic day of A V J , 2011, the Plaintiff is granted leave to serve process in this mortgage foreclosure action upon the Defendant, Ralph Zeiders, by regular mail and by certified mail, return receipt requested, to his/her last known address of 278A Green Street, Harrisburg, Pennsylvania 17110 and upon the Defendant, Gloria Zeiders, by regular mail and by certified mail, return receipt requested, to his/her last known address of 278A Green Street, Harrisburg, Pennsylvania 17110, and by posting the mortgaged premises of 1814 Letchworth Drive, Camp Hill, Pennsylvania 17011. BY THE COURT: , A- J. ?M?Cabe I?e+?e? C'onux?y, Ma,?d am S/pIoKB