HomeMy WebLinkAbout10-1588UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
LOUIS A. SIMONI, ESQUIRE - ID #200869
ADAM L. KAYES, ESQUIRE - ID #86408
L--HARGUERITE L. THOMAS, ESQUIRE - ID #204460 -'
WOODCREST CORPORATE CENTER cn
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111 WOODCREST ROAD, SUITE 200
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CHERRY HILL, NJ 08003-3620
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856-669-5400 C"
pleadings@udren.com pleadings@udren. com - Cn
Deutsche Bank National Trust :COURT OF COMMON PLEAS
Company as Trustee for Saxon =CIVIL DIVISION
Asset Securities Trust 2007-2
4708 Mercantile Drive -Cumberland
Ft. Worth, TX 79137
Plaintiff
V.
Justin D. Gordon
County
Amber Gordon NO. (p - X588
950 Baltimore Road
Shippensburg, PA 17257
Defendant(s)
a-,V't I -rem
COMPLAINT IN MORTGAGE FORECLOSURE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the
claims set forth in the following pages, you must take action
within twenty (20) days after this Complaint and Notice are served,
by entering a written appearance personally or by attorney and
filing in writing with the Court your defenses or objections to the
claims set forth against you. You are warned that if you fail to
do so the case may proceed without you and a judgment may be
entered against you by the Court without further notice for any
money claimed in the Complaint or for any other claim or relief
requested by the Plaintiff. You may lose money or property or
other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF
YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. ?ga,OO PD ATN
?aas5 ?9
LAWYERS REFERRAL SERVICE
Cumberland Count Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
AVISO
Le han demandado a usted en la corte. Si usted quiere defenderse
de estas demandas expuestas en las paginas siguientes, usted tiene
veinte (20) dias de plazo al partir de la fecha de la demanda y la
notificacion. Hace falta ascentar una comparencia escrita o en
persona o con un abogado y entregar a la corte en forma escrita sus
defensas o sus objeciones a las demanders en contra de su persona.
Sea avisado que si usted no se dafiende, la corte tomara medidas y
puede continuar la demanda en contra suya sin previo aviso o
notificacion. Ademas, la corte puede decidir a favor del
demandante y requiere que usted cumpla con todas las provisiones de
esta demanda. Usted puede perder dinero o sus propiedades u otros
derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO
0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN
PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
Cumberland Count Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
NOTICE
The amount of your debt is as stated in the attached document. The name of the creditor
to whom the debt is owed is as named in the attached document. Unless you notify us within
30 days after receipt of this Notice and the attached document that the validity of the stated
debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify
us in writing of a dispute within the 30 day period, we will obtain verification of the debt or
a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not
an admission of liability on your part. Also, upon your written request within the 30 day
period, we will provide you with the name and address of the original creditor if different from
the current creditor.
If you notify us in writing within the 30 day period as stated above, we will cease collection
of your debt, or any disputed portion of it, until we obtain the information that is required
and mail it to you. Once we have mailed to you the required information, we will then
continue the collection of your debt.
This law firm is deemed to be a debt collector and this Notice and the attached document is
an attempt to collect a debt, and any information obtained will be used for that purpose.
UDREN LAW OFFICES, P.C.
/s/ Mark J. Udren, Esquire
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill, NJ 08003-3620
(856) 669-5400
1. Plaintiff is the Corporation designated as such in the
caption on a preceding page. Plaintiff is the legal holder of the
Mortgage that is the subject of this action. Current assignments of
mortgage of record are as follows.
Assignor: Saxon Mortgage Inc. d/b/a Saxon Home Mortgage
Assignments of Record to: Deutsche Bank National Trust Company, as
Trustee for Saxon Asset Securities Trust 2007-2
Recording Date: 09/22/08 Book: 200831976
2. Defendant(s) is the individual designated as such on the
caption on a preceding page, whose last known address is as set
forth in the caption, and unless designated otherwise, is the real
owner(s) and mortgagor(s) of the premises being foreclosed.
3. On or about the date appearing on the Mortgage
hereinafter described, at the instance and request of Defendant (s) ,
Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned
to the Defendant(s) the sum. appearing on said Mortgage, which
Mortgage was executed and delivered to Plaintiff as security for
the indebtedness. Said Mortgage is incorporated herein by
reference in accordance with Pa.R.C.P. 1019 (g).
The information regarding the Mortgage being foreclosed is as
follows:
MORTGAGED PREMISES: 950 Baltimore Road
MUNICIPALITY/TOWNSHIP/BOROUGH: Southampton Township
COUNTY: Cumberland
DATE EXECUTED: 02/14/07
DATE RECORDED: 02/26/07 BOOK: 1983 PAGE: 1535
The legal description of the mortgaged premises is attached hereto
and made part hereof.
4. Said Mortgage is in default because the required payments
have not been made as set forth below, and by its terms, upon
breach and failure to cure said breach after notice, all sums
secured by said Mortgage, together with other charges authorized by
said Mortgage itemized below, shall be immediately due.
5. After demand, the Defendant(s) continues to fail or
refuses to comply with the terms of the Mortgage as follows:
(a) by failing or refusing to pay the installments of
principal and interest when due in the amounts indicated
below;
(b) by failing or refusing to pay other charges, if any,
indicated below.
6. The following amounts are due on the said Mortgage as of
01/26/10:
Principal of debt due $147,485.88
Unpaid Interest at 7.0%
from 10/01/09 to 01/26/10
(the per diem interest accruing on
this debt is $28.28 and that sum
should be added each day after 01/26/10) 3,288.12
Title Report 325.00
Court Costs (anticipated, excluding
Sheriff's Sale costs) 280.00
Escrow Overdraft/(Balance)
(The monthly escrow on this account
is $213.13 and that sum should
be added on the first of each
month after 01/26/10) 1,499.61
Late Charges
(monthly late charge of $46.40
should be added in accordance
with the terms of the note
each month after 01/26/10) 464.00
Uncollected Fees 4,456.66
Attorneys Fees (anticipated and actual
to 5% of principal) 7,374.29
TOTAL $165,173.56
7. The attorney's fee 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.
8. The combined notice specified by the Pennsylvania
Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983
and Notice of Intention to Foreclose under Act 6 of 1974 has been
sent to each defendant, via certified and regular mail, in
accordance with the requirements of those acts, on the date
appearing on the copy attached hereto as Exhibit "A", and made part
hereof, and defendant (s) have failed to proceed within the time
limits, or have been determined ineligible, or Plaintiff has not
been notified in a timely manner of Defendant(s) eligibility.
WHEREFORE, the Plaintiff demands judgment, in rem, against
the Defendant(s) herein in the sum of $165,173.56 plus interest,
costs and attorneys fees as more fully set forth in the Complaint,
and for foreclosure and sale of the Mortgaged premises.
UDRENYT.iAW 10,'F:tC08 P.C.
BY:
V?,ey f r P anti
REN, ES QU
NEG, ESQUIRE
OYLE, ESQUIRE
NATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
LOUIS A. SIMONI, ESQUIRE
ADAM L. KAYES, ESQUIRE
MARGUERITE L. THOMAS, ESQUIRE
E "A"
ALL THE FOLLOWING DESCRIBED THREE TRACTS OF REAL ESTATE LYING AND
BEING SxTtlATR IN SOUTHAMPTON TOWNSHIP, Cmema ND COUNTY, PENNSYLVANIA
BOUNDTD'AND LIMITED AS FOLLOWS:
TRACT NO 1: BEGINNING AT AN IRON FIX IN THE CFNTRER OF THE PUBLIC ROAD
LEADING FROM SHIPPENSBURG TO CLEVBRSBURG. KKOWN AS THE BALTIMORE ROAD
AT THE LIKE ONE LANE} NOW OR FORMERLY OF ROBERT C. REBERLING: AND DORIS
C. HEBERLING HIS WIn THENCE ALONG SAID LANDS NOW OR FORMERLY OF
HEBERLLING SOUTH 17 DEGREES 45 MINUTES WEST A DISTANCE OF 150 FENT TO
AN IRON PIN AT LANDS NON OR FORMERLY OF LESLIR D. SHOAP AM HAZEL V.
SHOAP HIS WIFE AND L. RICHARD SHOAP SINGLE MAN THENCE BY SAID LANDS
NOW OR FORMERLY OF SHOAP SOUTH 72 DEGREES .15 MINUTES EAST A DISTANCE
OF 75 FEET TO AN IRON PINS AT OTHER LARDS NOW OR FORMERLY OF THE SAID
SHOAP THENCE BY THE SAME NORTR 17 DEGUES 45 MINUTES EAST A DISTANCE
OF 150 FEET TO AN IRON PIN IN THE GBNTRER OF THE AFORESAID PUBLIC
ROAD; THENCE ALONG THE CMMUR OF AFORESAID PUBLIC ROAD NORTH 72
DEGREES 15 MINUTES WEST A DISTANCE OF 75 FEET TO AN IRON PIN, THE
PLACE OF BEGINNING
TRACT NO. 2
8EGINNING AT A POINT IN THE CENTER OF THE PUBLIC ROAD LEADING FROM
SHIPPENSBURG TO CLVERSBURG, 101OWN AS BALTIMORE ROAD AT LINE OF OTHER
LAND NOW OR FORMERLY OF JOHN L. STINE AND MILDRHD V. STINE HIS WIFE,
.MXCE ALONG THE SAME SOUTH 17 DEGREES 45 MIN11TES WEST A DISTANCE OF
150 FEET TO A'POINT AT LINE OF LAND NOW OR FORMERLY OF LESLIE D. SHOAP
AND HAZEL V. SHOAP HIS WIFE, AND L. RICHARD SHOiAP THENCE BY THE SAME
SOUTH 72 DEGREES 15 MINUTES EAST A DISTANCE OF 75 FEET TO THE POINT ON
LINE OF LAND NOW OR FORMERLY OF NQR)QN SICKELMERGER, THENCE BY THE
SAME, NORTF 17 DEGREES 45 MINUTES BAST• A DISTANCE OF 150 FEET TO THE
POINT IN THE CENnM OF THE AFORESAID PUBLIC ROAD; THENCE BY THE CENTER
OF THE AFORESAID PUBLIC ROAD NORTH. 72 DEGREES 15 MINUTES WEST A
DISTANCE OF 75 FEET TO A POINT, THE PLACE OF BEGIMING
TRACT NO 3
BEGINNING AT AN IRON PIN LOCATED ON THE SOUTHWEST COMM OF LANDS NOW
OR FORMERLY OF LESTER SUDERS THENCE BY LANDS NOW OR FORMERLY OF
Y]3 3nM L. GRESAMAN HIS WIFE SOUTH 18 DEORBSS 49 MINUTES 01 SBCOMS
WEST 50 FEET TO AN IRON PIN; THENCE BY THE SAME NORTH 71 D8GRPM 10
MINUTES 59 SECONDS WEST 150 FEET TO AN IRON PIN THENCE BY LANDS NOW OR
FORMERLY OF THOMAS REILLY NORTH 16 DEGREES 49 MINUTES 01 SECONDS EAST
50 PERT TO AN IRON PIN; THWCE BY OTHER LMS NOW OR FORMERLY OF THE
SAID GBESAMAN SOUTH 71 DIMSES 10 MINUTES 59 SECONDS LAST 154 FEET TO
AN IRON PIN, THE PLACE OF BEGINNING
TAX ID# 39-36-2428-015
e
ACT 91 NOTICE
DATE OF NOTICE: 01/29/2010
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THE PURPOSE OF COLLECTING THE DEBT.
This is an official notice that the mortgage on your home is in default, and the
lender intends to foreclose Specific information about the nature of the default is provided in
the attached pages.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be
able to help to save your home. This Notice explains how the program works.
To see if HEMAP can helms you must MEET WITH A CONSUMER CREDIT
COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this
Notice with you when you meet with the Counseling Agency.
The name address and phone number of Consumer Credit Counseling Agencies serving
your County are listed at the end of this Notice. If you have any questions, you may call the
Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired
hearing can call (717) 780-1869.)
This Notice contains important legal information. If you have any questions,
representatives at the Consumer Credit Counseling Agency may be able to help explain it.
You may also want to contact any attorney in your area. The local bar association may be able
to help you find a lawyer.
La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar
viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion
immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al
numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado
"Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la
perdida del derecho a redimir su hipoteca.
Prepared by: GOLDBECK McCAFFERTY & McKEEVER
Suite 5000 - Mellon Independence Center.
701 Market Street
Philadelphia, PA 19106
Fax (215) 627-7734
E?F9V?4 r A
Date: 01/29/2010
Homeowners Name: AMBER D. GORDON and JUSTIN D. GORDON
Property Address: 950 Baltimore Road, Shippensburg, PA 17257
Loan Account No.: 12068705
Original Lender: SAXON MORTGAGE SERVICES INC.
Current Lender/Servicer: SAXON MORTGAGE SERVICES INC.
- HOMEOWNERS'
EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL
ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE
MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S
EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE
ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
* IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
* IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
* IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for
mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the
designated consumer credit counseling agencies listed at the end of this Notice.
THIS MEETING MUST OCCUR WITHIN THE NEXT (33) DAYS. IF YOU DO NOT
YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO
DATE.
CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer
credit counseling agencies listed at the end of this notice, the lender may NOT take action against you
for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of
desismated consumer credit counseling agencies for the county in which the property is located are set
forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your
lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the
reasons set forth later in this Notice (see following pages for specific information about the nature of
your default.) You have the right to apply for financial assistance from the Homeowner's Emergency
Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's
Emergency Assistance Program Application with one of the designated consumer credit counseling
agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications
for the program and they will assist you in submitting a complete application to the Pennsylvania
Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your
application MUST be filed or postmarked within thirty (30) days of your fact-to-face meeting with the
counseling agency.
YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU
HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE
POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA
WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY
PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS
EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF
FORECLOSURE."
YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND
THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER
FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS
EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE
FORECLOSURE WILL BE STOPPED.
AGENCY ACTION - Available funds for emergency mortgage assistance are very limited.
They will be disbursed by the Agency under the eligibility criteria established by the Act. The
Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your
application. During that time, no foreclosure proceedings will be pursued against you if you have met
the time requirements set forth above. You will be notified directly by the Pennsylvania Housing
Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION
IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR
INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN
ATTEMPT TO COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for
Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT Bring it uP to date).
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property
located at: 950 Baltimore Road, Shippensburg, PA 17257 IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months
and the following amounts are now past due:
(a) Monthly payment from 11/01/2009 thru 01/29/2010
(3 mos. at $1,141.20/month) $3,423.60
(b) Late charges from 11/01/2009 thruOl/29/2010 (3 mos. at $46.40/month) $139.20
(c) Other charges; Escrow, Inspec., NSF Checks
(d) Other provisions of the mortgage obligation, if any
(e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $3,562.80
HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the
date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH
IS 3$ ,562.80, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME
DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check,
certified check or money order made payable and sent to:
SAXON MORTGAGE SERVICES INC.
4708 Mercantile Drive North
Fort Worth, TX 76137
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default
within THIRTY (30? DAYS of the date of this Notice, the lender intends to exercise its rights to
accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be
considered due immediately and you may lose the chance to pay the mortgage in monthly installments.
If full payment of the total amount past due is not made within THIRTY (30) DAYS, the.lender also
intends to instruct its attorneys to start legal action to foreclose upon your mortgaged Property.
IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the
Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the
delinquency before the lender brings legal proceedings against you, you will still be required to pay the
reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are
started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender
even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which
may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY
period, you will not be required to vav attorney's fees.
OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the
default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have
the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale.
You may do so by pang the total amount then past due, plus any late or other charges then due,
reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected
with the Sheriff s Sale as specified in writing by the lender and by performing any other requirements
under the mortgage. Curing your default in the manner set forth in this notice will restore your
mortgage to the same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a
Sheriff s Sale of the mortgaged property could be held would be approximately four (4 to six (6)
months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to
you before the sale. Of course, the amount needed to cure the default will increase the longer you wait.
You may find out at any time exactly what the required payment or action will by contacting the
lender.
HOW TO CONTACT THE LENDER:
Name of Lender: SAXON MORTGAGE SERVICES INC.
Address: 4708 Mercantile Drive North
Fort Worth, TX 76137
Phone Number: 888-325-3502
Contact Person: Loss Mitigation Department
EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff s Sale will end your ownership of
the mortgaged property and your right to occupy it. If you continue to live in the property after the
Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by
the lender at any time.
ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who
will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees
and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
* TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE
DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF
THIS DEBT.
* TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
* TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO
DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT
HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY
CALENDAR YEAR.)
* TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
* TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH
ACTION BY THE LENDER.
* TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
Contact: Loss Mitigation Department
Phone Number: 888-325-3502
6
HEMAP Consumer Credit Counseling Agencies
Report last updated: 11/27/2009 2:32:10 PM
CCCS of Western PA
4402 Peach Street
Erie, PA 16509
888.511.2227 ext
108
888.511.2227 ext
108
DAUPHIN County
CCCS of Western PA
2000 Linglestown Road
Harrisburg, PA 17102
888.511.2227
888.511.2227
Center for Family Services, Inc.
213 Center Street
Meadville, PA 16335
814.337.8450
Greater Erie Community Action Committee
18 West 9TH Street
Erie, PA 16501
814.459.4581
Shenango Valley Urban League. Inc.
601 Indiana Avenue
Farrell, PA 16121
724.981.5310
St. Martin Center
1701 Parade Street
Erie, PA 16503
814.452.6113
CUMBERLAND County
CCCS of Western PA
2000 Linglestown Road
Harrisburg, PA 17102
888.511.2227
888.511.2227
Community Action Commission of Captial Region
1514 Derry Street
Harrisburg, PA 17104
717.232.9757
Maranatha
43 Philadelphia Avenue
Waynesboro, PA 17268
717.762.3285
PA Interfaith Community Programs Inc
40 E High Street
Gettysburg, PA 17325
717.334.1518
PHFA
211 North Front Street
Harrisburg, PA 17110
717.780.3940
800.342.2397
Community Action Commission of Captial Region
1514 Derry Street
Harrisburg, PA 17104
717.232.9757
PHFA
211 North Front Street
Harrisburg, PA 17110
717.780.3940
800.342.2397
DELAWARE County
Advocates for Financial Independence
202 East Hinkley Avenue
Ridley Park, PA 19078
215.389.2810
American Credit Counseling Institute
175 Strafford Avenue
Suite 1
Wayne, PA 19087
610.971.2210
888.212.6741
American Credit Counseling Institute
526-528 Dekalb Street
Norristown, PA 19401
610.971.2210
888.212.6741
American Financial Counseling Services Inc.
1080 N. Delaware Avenue
Suite 200
Philadelphia, PA 19125
267.228.7903
800.490.3039
American Financial Counseling Services Inc.
405 West Germantown Pike
Norristown, PA 19403
267.228.7903
800.490.3039
American Financial Counseling Services Inc.
175 Strafford Avenue
Suite One
Wayne, PA 19087
267.228.7903
800.490.3039
Page 8 of 21
Form 3877
Domestic USPS Firm Mailing Book
-----------------------------------------------
-Name and Address of Sender: Permit Number Sequence Number
JOSEPH A GOLDBECK JR 3020A
MELLON INDEPENDENCE CENT
701 MARKET ST STE 5000 Ascent - MAC v7.50.7.70.J
PHILADELPHIA, PA 19106 -
---------------------------------------------- ----------- ------__
Piece ID Article # Delivery Address SS Fee Postage Value Sender Charges
Addressee Name Type Insur./Register Due Total
---------------- _---r---------------------
72019ACT-CS 71114342363000770652 SHALLENBERGER, CARA C 2.80 0.61 4.51
175 Eannotti Road ERR 1.10
Dawson, PA 15428
72019ACT-CR 71114342363000770669 RICHTER, CHRISTOPHER L. C 2
80 0
61
. . 4.51
- - 175 Eannotti Road ERR 1.10 -
Dawson, PA 15428
78709ACT-RW 711143423,63000770676 WILLIAMS, RONALD C 2
80 61
0
. - 4.51
12 Mccormick Lane ERR 1.10
Blakeslee, PA 18610
8592BACT-WF 71114342363000770683 FLECK, WLFRED E. C 2
80 0
61
. . 4Si
2105 Pennington Road ERR 1.10
Warriors Mark, PA 16877
8592BACT-RF 71114342363000770690 FLECK, RUTH A. C 2.80 0
61
. 4.51
2105 Pennington Road ERR 1-10
Warriors Nark, PA 16877
71873ACT-DC 7'114342363000770706 COHEN, DAVID S. C 2
80 61
0
. . 11.51
215 Nortk Market Street# 217 ERR 1.10
New Wilmington, PA 16142
i
70989AC1'-WK
71119342363000770713
KIRBY III, WARREN E.
C
2.80
0
61 ,
. 4 51
64 Ramblewood Drive ERR 1.10
Saylorsburg, PA 18353
67822ACT-JG 71114342363000770720 GORDON, JUSTIN D. C 2
80 0
61
. . 4.51
950 Baltimore Road ERR 1.10
Shippensburg, PA 17257
Page Totals:
8 ---- ------ -- - --- --------.. .--- ------_------..
31.20 4.88 36.08
Cumulative To tals: 24
93.60 14.64 106.24
Page 3
Form 3877
Domestic USPS Firm Mailing Book
Name and Address of Sender: Permit Number Sequence Number
JOSEPH A GOLDBECK JR 3020A
MELLON INDEPENDENCE CENT
701 MARKET ST STE 5000 Ascent - MAC v7.50.7.70.J
PHILADELPHIA, PA 19106
------------------------------- - ----------------------------------------------------- ----------------- --------------------------
Piece ID Article # Delivery Address 55 Fee Postage value Sender Charges
Addressee Name Type insur./Register Due Total
------------ ---- ----
b7822ACT-AG 7111434'2.363000770737 GORDON, AMBER C 2.80 0.61 4.51
950 Baltimore Road ERR 1.10
Shippensburg, PA 17257
71873ACT-AC 71114342363000770744 COHEN, AMY L. C 2.80 0.61 4.51
215-217 North Market Street ERR 1.10
New Wilmington, PA 16142
66530ACT-WD 71114342363000770751 DUFRESNE, WOOSELYNE C 2.80 0.61 4.51
2895 Rossiter Avenue ERR 1.10
Abington, PA 19001
65109ACT-WZ 71114342363000770768 ZEIN, WAFAA MOHAMMAD C 2.80 0.61 4.51
2024 Deer Ridge Drive ERR 1.10
Pottstown, PA 19464
71873ACT-AC.0171114342363000770775 COHEN, ANY L. C 2.80 0.61 4.51
215 North Market Street# 217 ERR 1.10
New Wilmington, PA 16142
91631ACT-CM 711143423630007'10782 MILLER, CATHY L. 2.80 0.61 4.51
49 Mill Street ERR 1.10
Columbus, PA 16405
91547ACT-ZA.0171114342363000770799 ANAM, ZAHID C 2.80 0.61 4.51
4420 P6:-k Avenue ERR 1.10
Slatington, PA 18080
91446ACT-DC 71114342363000'170805 CLARK, DANIEL. G. C 2.80 0.61 4.51
515 Cemetery Street ERR 1.10
Mayfield, PA 18433
------------------------------------------- .------------------------------------------------ Page Totals: 8 31.20 4.88/ 36.08
Cumulative Totals: 32 124.80O+Nh_? 2.5' 144.32
Page
? AFC
0
V E R I F I C A T I O N
The undersigned, hereby states that he/she is the attorney for
the Plaintiff, a corporation unless designated otherwise; that
he/she is authorized to make this Verification and does so because
of the exigencies regarding this matter, and because Plaintiff must
verify much of the information through agents, and because he/she
has personal knowledge of some of the facts averred in the
foregoing pleading; and that the statements made in the foregoing
pleading are true and correct to the best of his/her knowledge,
information and belief and the source of his information is public
records and reports of Plaintiff's agents. The undersigned
understands that this statement herein is made subject to the
penalties of 18 Pa.C.S. Section 4904 relating to unsworn
falsification to authorities.
UDREN,LAW C FnICES , P.C.
BY:
At ntY#' ?Flaint-Tt
MAR J. T4DAtN, ESQUIRE
STU T W NNEG, ESQUIRE
LOR IN DOYLE, ESQUIRE
ALAN . MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
LOUIS A. SIMONI, ESQUIRE
ADAM L. KAYES, ESQUIRE
MARGUERITE L. THOMAS, ESQUIRE
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
x ~~tt1t~, of ~~iwbr~~tn
(+
Fl~h~C~
Jody S Smith
Chief Deputy
Edward L Schorpp
Solicitor
~~.
~~ .~;~~
~~, ~,~ kf
C ,u.
~;
Deutsche Bank National Trust Company
Case Number
vs.
Justin D Gordon (et al.) 2010-1588
SHERIFF'S RETURN OF SERVICE
03/11/2010 06:04 PM -Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on
March 11, 2010 at 1758 hours, he served a true copy of the within Complaint in Mortgage Foreclosure,
upon the within named defendant, to wit: Justin D. Gordon, by making known unto himself personally, at
950 Baltimore Road, Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the
same time handing to him personally the said true and correct copy of the same.
GE LD WORTHINGTO EPUTY
03/12/2010 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: Justin D. Gordon, 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 Justin D. Gordon. Justin D. Gordon currently resides at 950 Baltimore Road, Shippensburg, PP
17257.
03/16/2010 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: Amber N. Gordon, 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 Amber N. Gordon. Request for service at 107 Gilbert Road, Shippensburg, PA 17257 is
currently occupied by the defendant's mother. She advised Deputies Amber N. Gordon receives her mail
at this address, but is currently residing with her boyfriend on Scotland Road, Shippensburg, PA. Amber
N. Gordon can be reached on her cell phone at 717-977-0862.
03/16/2010 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: Amber N. Gordon, 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 Amber N. Gordon. Request for service at 950 Baltimore Road, Shippensburg, PA 17257 is
currently occupied by Justin D. Gordon.
SHERIFF COST: $115.00
March 18, 2010
SO ANSWERS,
""_
RON R ANDERSON, SHERIFF
s` CountpSiite Sherdt, Telecsofl, Inr.
IIDR$N LAW OFFICES, P.C.
' MARK J. DDREN, ESQIIIRE - ID #04302
STIIART WINNEG, ESQIIIRE - ID #45362
LORRAINE DOYLE, ESQIIIRE - ID #34576
ALAN M. MINATO, ESQIIIRE - ID #75860
CHANDRA M. ARKEMA, ESQIIIRE - ID #203437
ADAM L. KAYES, ESQIIIRE - ID #86408
MARGUERITE L. THOMAS, ESQIIIRE - ID #204460
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SIIITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
Deutsche Bank National Trust Company, as
Trustee for Saxon Asset Securities Trust
2007-2
Plaintiff
v.
Justin D. Gordon
Amber Gordon
Defendant(s)
ATTORNEY FOR PLAINTIFF
,t~F, r. ~,-~
~ F~..._,.~ ~`,a _,
J~L3D PM S: 3y
.; : -~ ~ .
Lu,: ., 3'
- :_ _ ~ .
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 10-1588 Civil Term
AFFIDAVIT OF SERVICE PIIRSIIANT TO Pa.R.C.P.RUI,E 3129.1
Plaintiff, by its/his/her Attorney hereby verifies that:
1. A copy of the Notice of .Sheriff's Sale, a true and correct copy of which is
attached hereto as Exhibit "A", was sent to every recorded lienholder and every
other interested party known as of the date of the filing of the Praecipe for the
Writ of Execution, on the date(s) appearing on the attached Certificates of
Mailing.
2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and
certified mail on the date appearing on the attached Return Receipt, which was
signed for by Defendant(s) on the date specified on the said Return Receipt.
Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B"
3. If a Return Receipt is not attached hereto, then service was by personal
service on the date specified on the attached Return of Service, attached hereto
as Exhibit "B".
4. If service was by Order of Court, then proof of compliance with said Order
is attached hereto as Exhibit "B".
All Notices were served within the time limits set forth by Pa Rule C.P. 3129.
This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904
relating to unsworn falsification to authorities.
Dated: July 21, 2010
~~"'~AW OFFICES, P.
BY:
aintiff
MARK J. UDREN, QUI "-'--`~
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIREv
CHANDRA M. ARKEMA, ESQUIRE
ADAM L. KAYES, ESQUIRE
MARGUERITE L. THOMAS, ESQUIRE
UDREN LAW OFFICES, P.C.
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
ADAM L. KAYES, ESQUIRE - ID #86408
MARGUERITE L. THOMAS, ESQUIRE - ID #204460
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
Deutsche Bank National Trust Company,
as Trustee for Saxon Asset Securities
Trust 2007-2
Plaintiff
v.
Justin D. Gordon
Amber Gordon
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON
CIVIL DIVISION
Cumberland County
PLEAS
NO. 10-1588 Civil Term
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
OWNER(S): Justin D. Gordon and Amber Gordon
PROPERTY: 950 Baltimore Road,
Shippensburg (Southampton Township), PA 17257
Improvements: RESIDENTIAL DWELLING
The above captioned property is scheduled to be sold at the Cumberland County
Sheriffs Sale on September 8. 2010, at 10:OOam, in the Commissioners Hearing
Room, 2ND Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a
mortgage or judgment on 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 30 days after sale. Distribution will be made in accordance with the
schedule unless exceptions are filed thereto within 10 days after the filing of the
schedule. ,~,
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson ~cL
Sheriff
Jody S Smith ~9~~ta of ~irtnbrrf~~~
Chief Deputy C>. ,-. ,
e~"~, rr
Richard W Stewart 6.-~~M~,w
Solicitor Q~~c~ aF -:~ sw~a,~i=
Deutsche Bank National Trust Company
vs. Case Number
Justin Darryl Gordon (et al.) 2010-1588
SHERIFF'S RETURN OF SERVICE
06/25/2010 10:43 AM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on
06-27-2010 at 1035 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and
Description, in the above entitled action, upon the property of Justin Darryl & Amber N. Gordon, located at
950 Baltimore Road, Shippensburg, Cumberland County, Pennsylvania according to law.
06/25/2010 10:43 AM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on
6-25-2010 at 1035 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in
the above entitled action, upon the within named defendant, to wit Amber N. Gordon, by posting upon the
property of Amber N. Gordon, located at, 950 Baltimore Road, Shippensburg, Cumberland County,
Pennsylvania, pursuant to Court Order.
06/29/2010 05:06 PM -Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on 6/29/10 at
1706 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above
entitled action, upon the within named defendant, to wit: Justin Danyl Gordon, by making known unto,
Justin Danyl Gordon, per~so~n~ll~..at, 950 Baltiomore Road, Shippens urg, Cumberland County,
Pennsylvania its cortt~ sfif-and at the same time handing to him personally the said true and correct copy
of the same.
SHERIFF COST: $1,618.92 SO ANSWERS,
July 02, 2010 RON R ANDERSON, SHERIFF
~. ~Xy~eir~,
(c) CountySuite Sheriff, Teleosoff. Inc.
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. UDR.EN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIR}3 - ID #203437
ADAM L. KAYES, ESQUIRE - ID #86408
MARGUERITE L. THOMAS, ESQUIRE - ID #204460
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
Deutsche Bank National Trust 'COURT OF COMMON PL
EAS ~ N_
o ~'~'
Company, as Trustee for Saxon :CIVIL DIVISION n
Asset Securities Trust 2007-2 :Cumberland County _
_ ;r,
Plaintiff _,
.~.
c;i`.-
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'~- `~~
'
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V • ~' i wf`
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Justin D. Gordon ~ ~ -.`~~'{
Amber Gordon `: NO. 10-1588 Civil Term
Defendant(s)
VERIFICATION OF SERVICE BY CERTIFIED MAIL AND
REGULAR MAIL PURSUANT TO COURT ORDER
The undersigned hereby verifies that he is counsel for Plaintiff in
the above case and that pursuant to the Court order issued in this
matter he mailed a true and correct copy of the Notice of Sale to
Defendant(s), by certified mail and regular first class mail, to
the last known address of Defendant(s) as follows:
DATE MAILED: June 9, 2010
Amber Gordon
107 Gilbert Road
Shippensburg, PA
I verify that the
I understand that
penalties of 18
falsification to <
17257
statements made herein are true and correct and
false statements made herein are subject to the
Pa.C.S. Section 4904 relating to unsworn
authorities.
Dated: June 9, 2010
UDREN LAW OFFICES, P.C.
BY : e~
Attorneys r Plaintiff
/~"\ O MARK J. UDREN, ESQUIRE
((`J" O n STUART WINNEG, ESQUIRE
U•:J ~ LORRAINE DOYLE, ESQUIRE
(((jjf ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
ADAM L. KAYES, ESQUIRE
MARGUERITE L. THOMAS, ESQUIRE
EXHIBIT 8
._ti ~~ i_
f r~
! ~ ..~.
~3AR 3 0 ZD~O
~x T~ cocr~.~ of co~ao~a Pr~RS o~ Ctunbeslaad cov~rrY
CIVTL DIVISIQN
Deutsche Bank National Trust t.',.
Company, as Trustee fox Saxon ~-'
Asset Securities Trust 2007-2.
Plaintiff NO. 10-1588 Civil Term.
v.
Justin D. Gordan
Amber Gordon
Defendant (s}
O R D E R
3 ~s~
AND NOW, this day of ~ 2010, upon
consideration of Pla.intiff's Motion and the Affidavit of Good Faith
investigation attached hereto, it is hereby ORDERED t}.iat service of
the Complaint and all subsequent pleadings on Defendant (s } , Amber
Gordon, shall be complete when Plaintiff or its counsel ar agent .
has mailed true a.nd correct copies of the Complaint and all
subsequent .pleadings by certified mail and regular mail to the last
known address of Defendant{s}, Amber Gordan at 107 Gilbert Road
5hippensburg, pry 17257 and by posting the mortgaged premises
located. at 950 Ealtimore Road Shippensburg (Southampton Township},
~~ ~7zs7.
BY THE COURT:
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UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400 pleadings@udren.com
Deutsche Bank National Trust :COURT OF COMMON PLEAS
Company, as Trustee for Saxon =CIVIL DIVISION
Asset Securities Trust 2007-2 :Cumberland County N C)
4708 Mercantile Drive --4
Ft. Worth, TX 79137 r-- rn--
Plaintiff NO. 10-1588 Civil Term _; ro
Cp
V . --1 C)
2
--
Justin D. Gordon _
_--
Amber Gordon
950 Baltimore Road
Shippensburg, PA 17257 -' °? -
Defendant(s)
SUGGESTION OF BANKRUPTCY
To the Prothonotary:
Kindly note on the record that the above Defendant, Justin D.
Gordon and Megan D. Gordon have filed Chapter 13 Bankruptcy in the
Middle District of Pennsylvania on September 4, 2010, Bankruptcy
Case No. 10-07269.
ICES, ,P.C.
At 4r ror1'Y1ainX7iff
' tO m , Esquire
MJU 08080069-2
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003 .,
?.a
856-669-5400
Deutsche Bank National Trust €COURT OF COMMON PLEAS
Company, as Trustee for Saxon =CIVIL DIVISION
Asset Securities Trust 2007-2 :Cumberland County
4708 Mercantile Drive -~.
Ft. Worth, TX 79137 ZZ
Plaintiff € NO. 10-1588 Civil Term```= s
c.v
v.
Justin D. Gordon
Amber Gordon
950 Baltimore Road
Shippensburg, PA 17257
Defendant(s)
PRAECIPE TO WITHDRAW JUDGMENT AND DISCONTINUE WITHOUT PREJUDICE
TO THE PROTHONOTARY:
Kindly mark the above captioned matter JUDGMENT WITHDRAWN
and ACTION DISCONTINUED WITHOUT PREJUDICE, upon payment of your
costs only.
DATED: December -2F, 2011
08080069-2
I_?7
Attorney for Plaintiff
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