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HomeMy WebLinkAbout10-2045UDREN 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 o ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER ; 111 WOODCREST ROAD, SUITE 200 t. ° CHERRY HILL, NJ 08003-3620 r _r 856-669-5400 pleadings@udren.com w Deutsche Bank National Trust ':COURT OF COMMON PLEAS Company, as Trustee under the :CIVIL DIVISION Pooling and Servicing Agreement dated as of March 1, =Cumberland County 2006, GSRPM Mortgage Loan Trust 2006-1 4828 Loop Central Drive Houston, TX 77081 Plaintiff V. Guy W. Burford Keith M. Burford NO. [? - ad L? 407 North Baltimore Street -?C?? l Mount Holly Springs, PA 17007 Defendant(s) 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 TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS 419.1 .ov ?CL P2- z2Q331 t, 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. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 e 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 demandas 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 IMIEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 C, 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 'p 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: Ameriquest Mortgage Company Assignments of Record to: Salomon Brothers Mortgage Securities VII, Inc. Recording Date: 1/24/00 Book: 630 Page: 464 Instrument No: 200001903 Assignor: Salomon Brothers Mortgage Securities VII, Inc. Assignee: Wells Fargo Bank Minnesota, N.A., S/B/M to Norwest Bank Minnesota, N.A., as Trustee of Salomon Brothers Mortgage Securities VII, Inc., Floating Rate Mortgage Pass-Through Certificates, Series 1999-AQ1 under Pooling and Servicing Agreement Dated as of March 1, 1999 without recourse Recording Date:12/10/01 Book: 682 Page: 4771 Plaintiff is in the process of formalizing the assignment of mortgage in its favor for recording. 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: 407 North Baltimore Street MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of Mount Holly Springs COUNTY: Cumberland DATE EXECUTED: 1/25/99 DATE RECORDED: 2/1/99 BOOK: 1516 PAGE: 1001 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 3/17/10: Principal of debt due $56,189.58 Unpaid Interest at 10.25%* from 8/1/09 to 3/17/10 (the per diem interest accruing on this debt is $15.78 and that sum should be added each day after 3/17/10) 3,627.90 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $442.47 and that sum should be added on the first of each month after 3/17/10) 4,448.85 Late Charges F (monthly late charge of $27.80 should be added in accordance with the terms of the note each month after 3/17/10) 111.20 Corporate Advance 338.07 Attorneys Fees (anticipated and actual to 5% of principal) 2,809.48 TOTAL $68,130.08 *This interest rate is subject to adjustment as more fully described in the note and mortgage. 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 $68,130.08 plus interest, E- costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. UDRE 0 CES, P.C. BY Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE G?ZUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE 0 ALL THAT CERTAIN lot of gro®d situated in the Borough of Mt. tinily S1mngg, Cumbahmd Cotmty, Pennsylvania, bounded and deacdbed a: follow= ON thr Heat by Aaltimom Avenue; an the Soulh by proponY now or fostoody of Imnes Ciappe. LEK* Olt due Wiwi by a ?D fmi RgWlF i4 lor, acid an the North by property now or fm=cdy aF Rebeccc Minn. Having a froatafie an Saltimnre Aveauc of SO tees iota eaaadtuu iu &pd, 160 fact Having themaa otacted a two nosy fame dwellmg bousc kwwn as 407 North Salto mm Avaix. BEING TF?Z:'. SAMF 21FZWES Namma L Ryaard and KWwyn L Rynud, husband slid wife, tt 4 Wayne 8heaflst and hVids S. Sheaffer, huebaM and wife, by deed datad Apd 14, 1969, and rrrnrt}rd Ntltbf 41 jF1Yj in the Offloe of the Pworder of neadc is and for Comioedand County in peed Book G-94, pago 6%. gnmtod and eouveyea umo SVll Imi, U Outnar and LiMn W. Smitur, Gamtom. herein Uddm and A*= to tray and all cc = r, Conditions, xemnaliona, sisht-of-,.y., o ions, aasetaenta, egreea+ants, atC., as theyy appeal of rc=d. bjeeC F Litton Loan Servicing LP PRESORT P.O. Box 9010 First-Class Mail Temecula, CA 92589-9010 U.S. Postage and 111111111111 111 Fees Paid WSO Send Payments To: 7113 8257 1473 7652 1945 Litton Loan Servicing LP Attn: Cash Management Department P.O. Box 4387 Houston, TX 77210-4387 Send Correspondence To: Litton Loan Servicing LP Attn: Customer Assistance Response Team 4828 Loop Central Drive KEITH BURFORD Houston, TX 77081 GUY BURFORD 407 N BALTIMORE AVE MOUNT HOLLY SPRINGS, PA 17065 20051117-80 DMDACT all NO 1155-v14 TM Litton Loan Servicin' Sent Via Certified Mail 7113 8257 1473 7652 1945 11/16/2009 KEITH BURFORD GUY BURFORD 407 N BALTIMORE AVE MOUNT HOLLY SPRINGS, PA. 17065 ACT 91 NOTICE 4828 Loop Central Drive Houston, TX 77081 Telephone (800) 999-8501 Fax (713) 966-8906 wwwlittonloan.com Hours of Operation (CST) Mon.: 8 a.m. - 8 p.m. Tues. - Thurs.: 8 a.m. - 10 pm. Fri.: 9 a.m. - 5 p.m. Sat.: 8 a.m. - 12 p.m. Sun.: 10 a.m. - 2 p.m. TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official Notice that the mort¢aee on vour home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached paves The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help save your home. This Notice explains how the program works. To see if HEMAP can help 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 Counselin- zencv. The name. address. and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of the Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll- free at (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 an attornev in vour area. The local bar association may be able to help you find a lawyer. LITTON LOAN SERVICING LP IS A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT YOUR DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU ARE NOT OBLIGATED ON THE DEBT OR IF THE DEBT HAS BEEN DISCHARGED IN A BANKRUPTCY PROCEEDING, THIS IS FOR INFORMATIONAL PURPOSES ONLY AND IS NOT AN ` ATTEMPT TO ASSESS OR COLLECT THE DEBT FROM YOU PERSONALLY. 2800.0032.091708100007 7113 8257 1473 7652 1945 LA NOTIFICACI6N EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACI6N OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Keith Burford Guy Burford PROPERTY ADDRESS: 407n Baltimore St Mt Holly Springs, PA 17007 LOAN ACCT. NO.: 18481176 ORIGINAL LENDER: Contact Litton Loan Servicing LP CURRENT LENDER/SERVICER: Litton Loan Servicing LP HOMEOWNER'S 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°7, 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 consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE 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 designated consumer credit counseling agencies for the county in which the prolerty 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 forwarded to PHFA and received within thirty (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILER HEMAPAPPLICATIONAS SOONAS POSSIBLE IF YOUHAVE A MEETING WITHA COUNSELINGAGENCY WITHIII' 33 DAYS OF THE POSTMARKDATE OF THIS NOTICEAND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING THEN THE LENDER WILL BE TEMPORARILYPREVENTED FROM STARTING A FORECLOSUREAGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE. " YOU RAVE THE RIGHT TO FILE A HEAIAP APPLICATION EVEN BEYOND THESE TIME PERIODS A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLYAPPROVED 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 DEFAUL'T' (Bring it up to date.) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 407n Baltimore St Mt Holly Springs, PA 17007 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: 9/1/2009 through 11/1/2009 totaling $2,995.20 Other charges (itemized): Late charges: 555.60 NSF charges: $0.00 Outstanding legal fees and costs: $955.35 Broker Price Opinion fees: $300.00 Inspection fees: $147.00 TOTAL AMOUNT PAST DUE: $4,453.15 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: Cure the default. 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 $4,453.15 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check certified check or monev order made payable and sent to: Litton Loan Servicing LP Attention: Cash Management Department P.O. Box 4387 Houston, TX 77210-4387 2800.0032 7113 8257 1473 7652 1945 0 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 THIR'T'Y (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged proaertY. 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 begins 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 attorneys' 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 rea aired to oav 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 SAL E - 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 Sheriff's Sale You may do so by wing the total amount then past due. plus anv late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale, and anv 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 Sheriff s Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriff s 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 anv time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: LI'I"I'ON LOAN SERVICING LP Address: 4828 Loop Central Drive, Houston, TX 77081 Phone Number: (800) 999-8501 Fax Number: (713) %6-8906 Contact Person: Default Administration Department EF F ECT 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, lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _ may or X may not (CHECK ONE) sell or transfer your home to a buver 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 other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: ?Lr4?a • 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 DEFAUL'T'. (HOWEVER, YOLI DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE (3) 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. CONSUMER CREDIT COUNSELING AGENCIES SERVING CUMBERLAND COUNTY Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 717.334.1518 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 Community Action Commission of Capital Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 Loveship. Inc. 2320 North 5th Street Harrisburg, PA 17110 717.232.2207 Maranatha 43 Philadelphia Avenue Waynesboro. PA 17266 717.762.3285 2800.0032.091708100007 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 7113 8257 1473 7652 1946 V 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. UDRFX-U, R N0rKICES , P.C. BY : Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE e+••TgOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE e IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Deutsche Bank National Trust Company, as Trustee under the Pooling and Servicing n-- ~, `_~ ii Agreement dated as of March 1, NO. 10-2045 ~ c _. ~ 2 0 0 6 , GSRPM Mortgage Loan ~ _., .., ; .. ;,,,~~ ,.,~ r Trust 2006-1 ~ ~. - ~~~ Plaintiff ,, ~°~~~~ `~ _ t' _~`' a zT i ~ 4 * ~ ` ~ ~ ( '~ ~ ~ T ~ V . _ r Lx Q ~ Guy W. Burford ~=- ~ ~, :~ Keith M. Burford " --~ Defendant (s ) O R D E R AND NOW, this ~j`f~ day of ~ ~'7G 2010, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage Foreclosure and all subsequent pleadings on Defendant(s), Guy W Burford, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Complaint in Mortgage Foreclosure and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant(s), Guy W Burford at 407 North Baltimore Avenue Mount Holly Springs, PA 17007 and by posting the mortgaged premises located at 407 North Baltimore Avenue Mount Holly Springs, PA 17007. ~I~G~fkrvt l-• ~y~s, ~~'. It~.~,X¢~l. ~ekI//!~ ~G UDREN LAW OFFICES, P.C. ATTORNEY MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLS, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARREMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. RAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 FOR PLAINTIFF 856-669-5400 n Deutsche Bank National Trust :COURT OF COMMON PLEAS-c~ m r: Company, as Trustee under the :CIVIL DIVISION ~'=~ ~~ Pooling and Servicing :Cumberland County ~~~= Agreement dated as of March 1, ~~~' 2006, GSRPM Mortgage Loan :~z~. Trust 2006-1 € NO. 10-2045 -~L- Plaintiff ~ v. Guy W . Burford Keith M. Burford Defendant (s) PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: a 0 c_... ~_ w n tv c.~ r ~~ ~c; ~ {cy . -~~. `~'t'~ __'~~ _~ Kindly reinstate the Complaint on the above-captioned matter. DATE: June 24, 2010 UDREN LAW OFFICES, P.C. ,,, BY :/'~ ~ r Attorneys for aintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQJJ~RE s ~#lo.oo PA ATt^f ~* Is-is~ 7 ~2#a~~y~9 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson - Sheriff FILEG'-~ `~~~~ ~0ti~~ttr of ~u+nbrr~~ir~ '•?~ ~ ~~ L ~r ` ~`~{~~~~ Jody S Smith .n Chief Deputy ~~' - ~; ~~~~ ~~~ _6 ~~~ $: ~~ Richard W Stewart ` Solicitor a~~EC: -..~s~~~zI~F ;~~.~~~ t i; , . C,~~i~u; ~~i~ Ida ~~r~~lr~'r~~~ Deutsche Bank National Trust Company Case Number vs. 2010-2045 Guy W. Burford (et al.) SHERIFF'S RETURN OF SERVICE 07/01/2010 04:56 PM -Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on July 1, 2010 at 1656 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Guy W. Burford, pursuant to order of court by posting the premises located at 407 N. Baltimore Avenue, Mount Holly Springs, Cumberland County, Pennsylvania 17065 with a true and correct copy according to law. ~" DENNI RY, DEPUTY SHERIFF COST: $40.30 July 02, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (ct GountySuite Sheriff. Telaosoft, Inc. ,. UDREN LAi~ OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. REN, ESQUIRE - ID #04302 STUART W NNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. INATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A.',SIMONI, ESQUIRE - ID #200869 ADAM L. YES, ESQUIRE - ID #86408 n ^> MARGUERI E L. THOMAS, ESQUIRE - ID #204460 ~ n `7i WOODCRES~ CORPORATE CENTER ~4~; ~'.' ~-- `~ 111 WOODC~REST ROAD, SUITE 200 ~ CHERRY HE'LL, NJ 08003-3620 _ ~n -~~cY _856-669-51400, pleadings@udren com ~~ ~=~ ~`' ~ _ ~ 4 Deutsche'.. Bank National Trust € COURT OF COMMON PLEAS F... 1^' yv _r-~` ~ ~~ `~- ~ _ i ' ~~ 1 ~r~~ ~ c~' tt Company,... as Trustee under the ECIVIL DIVISION y v Pooling sand Servicing =Cumberland County ~ , .`-~ Agreemenlt dated as of March 1, ~ ~ 2006, GS~2PM Mortgage Loan Trust 20',06-1 €NO. 10-2045 Plaintiff v. Guy W. Bnarford Keith M. Burford 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 h~ mailed a true and correct copy of the Complaint in Mortgage ,Foreclosure to Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant (s) as follow: DATE MAILED : ~ .r~ -C~' Guy W. Buford 407 North'Baltimore Avenue Mount Holy Springs, PA 17007 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties relating to unsworn falsification to authorities. Dated: ~ ~~- -~~J UDREN L~~A,,/W OFFIC~E~S , P . C . BY : ~ ~Y~I/h ~/a ~1 Attorneys "for' ntiff MARK J. UDREN, QUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE I ,_ .,~ 0 C7-a~~ _~ ~ 37 ~ y Z 1 -cpns ~~~~ r~~~ zyQ-n ~--.iron ~~o~m oOm~ `"' °mn z- m C ~ ~ C `f-- \~ ~ ~ ~~ .~ ~R W ,1'- Q n -.._ Q v c J~ C W 1 .'~~L ~~ ~ ~ ~, ,~~ ~r~ tr< UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings udren.com Deutsche Bank National Trust Company, as € COURT OF COMMON PLEAS Trustee under the Pooling and Servicing =CIVIL DIVISION Agreement dated as of March 1, 2006, :Cumberland County GSRPM Mortgage Loan Trust 2006-1 Plaintiff v. Guy W. Burford € NO. 10-2045 Keith M. Burford Defendants ~< ,~ ~ .._._ c-. `_ r ` -- -- ~ ~ "~ ~:, - -e -- ~ =- ,_ .- ~_;~c PRAECIPE TO CORRECT TYPOGRAPHICAL ERROR TO THE PROTHONOTARY: Kindly correct the inadvertent typographical error in the common address of the mortgaged premises in paragraph 3 of Plaintiff s Complaint to read as follows: 407 North Baltimore Street, a/k/a 407 North Baltimore Avenue UDREN I S, P.C. BY: Margu L. Thomas, Esquire Atto vs or Plaintiff .1 :-± ;~-.-. A UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARGUERITE L. THOMAS, ESQUIRE - ID #204460. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Trustee under the Pooling and Servicing :CIVIL DIVISION Agreement dated as of March 1, 2006, :Cumberland County GSRPM Mortgage Loan Trust 2006-1 Plaintiff v. Guy W. Burford € NO. 10-2045 Keith M. Burford Defendants pleadings ,udren.com Deutsche Bank National Trust Company, as :COURT OF COMMON PLEAS CERTIFICATE OF SERVICE The. undersigned attorney hereby certifies that I have served or caused to be served true and correct copies of the Praecipe to Correct Typographical Error of Complaint in Mortgage Foreclosure upon the- following persons} named herein at their last known address or their attorney of record. xxxxxx Regular First Class Mail Certified Mail Other (certificate of mailing) Date Served: July , 2010 TO: Guy W. Burford 407 North Baltimore Street a/k/a 407 North Baltimore Avenue Mount Holly Springs, PA 17007 UDREN Keith M. Burford 407 North Baltimore Street a/k/a 407 North Baltimore Street Mount Holly Springs, PA 17007 P.C. L. 'Thomas, Esquire ~r Plaintiff IID.{tEN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF ~iKARK' J. IIDREN, ESQIIIRE - ID #04302 STIIART WINNEG, ESQIIIRE - ID #45362 LORRAINE DOYLE, ESQIIIRE - ID #34576 ALAN M. MINATO, ESQIIIRE - ID #75860 CHANDRA M. ARKEblA, ESQIIIRE - ID #20 3437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SIIITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadiags~udrea.com Deutsche Bank National Trust COURT OF COMMQN PLEAS Company, as Trustee under the CIVIL DIVISIOI~1' Pooling and Servicing Agreement ;Cumberland County dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 :MORTGAGE FORE4LOSURE 4828 Loop Central Drive c"~ !'~ Houston, TX 77081 _~-~ --- ~~ ~~ Plaintiff ' . - V. - !1~ Guy W. Burford €NO. 10-2045 Keith M. Burford 407 North Baltimore Street P Mount Holly Springs, PA 17007 ~ ' Defendant (s ) ,r,~ PRAECIPE FOR JIIDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAI~[AGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) Guy W. Burford and Keith M. Burford for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged'. premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest Per Complaint From 03/18/2010 to 08/14/2010 Late charges per Complaint From 03/18/2010 to 08/14/2010 Escrow payment per Complaint From 03/18/2010 to 08/14/2010 TOTAL I hereby certify that Defendant are as shown above, accordance with Rule 237.1, a $6~8, 130.08 2,367.00 111.20 ,2,212.35 $7~2 , 820.63 (1) the addresses of the Plaintiff and and (2) that nptice has been given in copy of which is attached hereto. UD W OFFICES, P.C. BY: r e s for Plaintiff MARK- -J _ UDR IRE STUART WINN G SQ IRE LORRAINE DOYLE, ESQUIRE g~~f 06~~. ~)C ALAN M. MINATO, ESQUIRE CHANDRA M . ARKEMA, ESQUIRE ~~" J,~i 33 DAMAGES ARE HEREBY ASSESSED AS DATE : ~~~- J 6 t o2Q~~ INDICA PRO 2~ UDRSN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF 1idAR~ J. ~UDREN, }~SQUTRE - ID #04302 STUART WINNEG, SSQIIIRE - ID #45362 LORRAINS DOYLE, ESQUIRE - ID #34576 C7 *~ .., ~ . ALAN M. MINATO, ESQUIRE - ID #75$60 :~. ~ ~ CHANDRA M. ARKSMA, ESQUIRE - ID #203437 ~--~ ~ ~ LOUIS A. SIMONI, E3QUIRS - TD #200869 - _ "'`` -er ADAM L. KAYES, ESQUIRE - ID #86408 _ - ~~ =^3 ~~~ MARGUERITE L. THOMAS, SSQIIIRE - ID #2.04460 s~=:~;: n .~ ~~ ~ ;r c7 WOODCREST CORPORATE CENTER =~= c_~: n ~rn 7.11 WOODCRSST ROAD, SUITE 200 "' CHERRY BILL, NJ 08003-3620 '~ c~ ~ 856-669-5400 pleadinga@u.dren. corn Deutsche Bank National Trust :COURT OF COMMON PLEAS Company, as Trustee under the 'CIVIL DIVISION Pooling and Servicing Agreement dated as of March 1, `Cumberland County 2006, GSRPM Mortgage Loan Trust 2006-1 4828 Loop Central Drive Houston, TX 77081 Plaintiff v. Guy w. Burfard Keith Nf. Burford NO ~Q '- aa~ ~ . 1 ti t l ~~'/ 407 North Baltimore Street .... v ~ . Mount Holly Springs, PA 17007 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT . If you wish to defend agains t 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 SHOIILD TAIL IBIS PAPER TO YOIIR LAWYER AT ONCE. IF YOII DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SLT FORTH BELOW. THIS ~a. o ~c~~ ~.~-l SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~"~ of +~r~tr,~.~ Jody S Srnith ~b ~ Chief Depufy 4:' ;;,: ~~'~ Richard W Stewart '~~~ ==~°~ Solicitor a~oe csr es~airF Deutsche Bank National Trust Company Case Number vs. Guy W. Burford (et a[.) 2010-2045 SHERIFF'S RETURN OF SERVICE 07/01/2010 04:56 PM -Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on July 1, 2010 at 1656 hours, he served a true copy ofi the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wi#: Guy W. Burford, pursuant to order of court by posting the premises located at 407 N. Baltimore Avenue, Mount Holly Springs, Cumberland County, Pennsylvania 17065 wi#h a #rue and correct copy according to law. c,;r_ -~- DENNI Y, DEPUTY SHERIFF COST: $40.30 July 02, 2010 SO ANSWERS, ~/ RON R ANDERSON, SHERIFF ;ci Co~mtySulte BY,erilf. 7eleosoft. Inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~ ~ ~ Jody S Smith Chief Deputy ~ ~ ~~~'. ~ Ettward L Schorpp . "`~'~~ Solicitor oEmr'ter. air Deutsche Bank National Trust Company Case Number vs. Guy W. Burford (et al.} 2010-2045 SHERIFF'S RETURN OFSERVICE 03/29/2010 03:14 PM -Shawn Harrison, Deputy Sheriff, who being duly swom according to law, states that on March 29, 2010 at 1511 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Keith M. Burford, by making known unto hims personally, at 407 N. Bal#imore Avenue, Mount Holly Springs, Cumberland County, Pennsyly 1 0 its contents and at the same time handing to him personally the said true and correct copy qlf t~a e. ~ DEPUTY 04/30/2010 Ronny R. Anderson, Sheriff, who being duly swom according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Guy W. Burford, but was unable to locate him in his bailiwick. He therefore returns the within Complain# in Mortgage Foreclosure as not found as to the defendant Guy;YV. Burford. Cherie Burford, Current occupant of 407 North Baltimore Avenue, Mount Holly Springs, PA 17065 advised Deputies Guy W. Burford is thought to be residing in Carlisle, PA. The Mouni Holly Springs Postmaster was unable to provide a current address for Guy W. Burford at this time. SHERIFF COST: $55.30 April 30, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (c) Coimty5uire St+eritf. TeleosoR, trK. '[TOKEN LAW OFFICES, P.C. MARK J. UDRffi+T, ESQUIRE - ID #04302 STUART WINNSG, ESQUIRE - ID #45362 LORRAINE DOYLS, ESQUIR$ - ID #34576 ALAN M. MINATO, ESQUIRT3 - ID #75660 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 ADAM L. KAYBS, ESQUIRE - ID #85408 MARGUERITE L. THOMAS, ESQUIRE - TD #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 06003 856-669-S400 ATTORNEY FOR PLAINTIFF Deutsche Bank National Trust Companyt as ;COURT OF COMMON PLEAS Trustee under the Pooling and Servicing :CIVIL DIVISION Aggreement dated as of March 1, 2006, ;Cumberland County GSRPM Mortgage Loan Trust 2006-1 Plaintiff v. _ Guy W. Burford Reath M. BurforDefendant (s} c NO. 10-2045 TO: Keith M. Burford 407 North Baltimore Street Mount Holly Springs, PA 17007 Date of Notice: August 3, 2010 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOfJR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE P; LAWYER THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCfES 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 PA 17013 800-930-9108 NOTIFICACION IMPORTANTE USTED 5E ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE NECESID~ DEECOMPARARECERIUSTED ENTCORTEIOIESCU~NH'ARE~REUBA ALGUNAD DfCTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHO~, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO O SI NO TIENE DINERO SUFICIENTE PARR TAL SERVICIO, VAYA EN PERSONA O LLAMA POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE P'`UEDE CONSEGUIR ASSTSTENCIA LEGAL. SERVICIO DE REFERSNCIA LEGAL LAi9YER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle PA 17013 600-930-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND IBIS IS AN ATTE6SPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FO ALAN M. MINATO E: CHANDRA M. ARKENEA ADAM L. KAYES, ~S~ MARGUERITE L. THOMAS, woodcrest Co orate 111 woodcrest Load, Cherry Hill, New Jersey !00 -3620 UDRffid LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. tJDREN, ESQUIRE - ID #04302 STUART ~IINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 ADAM L. KAYSS, ESQUIRE - ID #86408 MARGURRITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTffit 111 WOODCRSST ROAD, SUITE 200 CHERRY HILL, NJ 06003 856-669-5400 Deutsche Bank National Trust Company as :COURT OF COMMON PLEAS Trustee under the Pooling and Servicing :CIVIL DIVISION A reement dated as of March 1, 2006, Cumberland County G~RPM Mortgage Loan Trust 2006-1 Plaintiff v. Guy W. Burford Keith M. Burford ?NO. 10-2045 Defendant (s} . TO : Guy W , Burford 407 North Baltimore Street Mount Holly Springs, PA 17007 Date of Notice: August 3, 2010 IMPORTANT NOTICE YOU ARE TN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YO{TR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE T0~ PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICE5 TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle PA 17013 800-990-9108 NOTIFICACION IMPORTANTl3 USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMING DE DIEZ (10} DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA SIN NECESIDAD DE COMPAR.ARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA D~CTAR 5ENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHO~, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO O SI NO TIENE DINERO SUFICIENTE PARR TAL SERVICIO, VAYA EN PERSONA O LLAM~ POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE P~JEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle PA 17013 B00-990-9108 NOTICE: PURSUANT TO TS8 FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO 8E A REST COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A D$BT. ANY INFORMATION OSTAINSD WILL BE USSR OSE. CHANDRA M. ARKEMA, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE Woodcrest Corporate Center 111 Woodcrest Koad, Suite 200 Cherry Hill, New Jersey 08003-3620 UDRSN LAW OFFICES, P.C, MARK J. IIDREN, ESQUIRE - STUART WINNE6, $SQUIRE - LORR1s,INE DOYLE, ESQIIIRE ALAN M. MINATO, ESQIIIRE CHANDRA M. ARKEMA, $sQU2; LOUTS A. SIMONI, ESQIIIRE ATTORNEY FOR PLAINTIFF ID #04302 ID #45362 - ID #34576 - ID #75860 izE - ID #203437 - ID #200869 WOODCREST CORPORATE CRNTER 111 WOODCREST ROAD, SUITS 200 CHERRY HILL, NJ 08003-3620 $56-4$2-6900 Deutsche Bank National Trust Company, as Trustee under the Pooling and Servicin Agreement dated as o~ March 7., 2006, GSRPM Mortgage Loan Trust 2006-1 4828 Loop Central Drive Houston, TX 77081 Plaintiff v. Gux W . Burford Keith M. .Burford 407 North Baltimore Street Mount Ho11y Springs, PA 17007 Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. ~O --~v~J AFFIDAVIT OF NON-MILITARY SERVICE STATE OF Texas COUNTY OF Harris SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 194Q, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Defendant: Age: Residence: Employment: Guy W. Burford Over 18 As captioned above Unknown Keith M. Burford Over 18 As captioned Unknown Sworn to and subscribed before me this a~ day o ~.~r~ 2 0 to - otary Public ~/ above /~ ~ ~ /~ /, Name : _ t3enise Bailey r Company : Assistant Secretary BRENDA MCKINZY Notary Public, Stets of Texas My Commiaaton Expirss D~oNnbrr 00, 4010 UDREN 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 - TD #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 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 under the :CIVIL DIVISION Pooling and Servicing :Cumberland County Agreement dated as of March 1, 2006, GSRPM Mortgage Loan :MORTGAGE FORECLOSURE Trust 2006-1 Plaintiff v. Guy W. Burford NO. 10-2045 Keith M. Burford Defendant(s) TO: Keith M. Burford 407 North Baltimore Street Mount Holly Springs, PA 17007 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. X Judgment _ Money Jug _ Judgment _ Judgment Judgment _ Judgment _ Judgment Prothon ary by Default 3gment / in Replevin for Possession on Award of Arbitration on Verdict on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren, Esquire At this telephone number: 856-669-5400 r - ID #04302 - ID #45362 - ID #34576 - ID #75860 LRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SIIITB 200 CHERRY HILL, NJ 08003-3620 856-669-5400 IIDREN LAW OFFICES, P.C. MARK J. DDREN, ESQIIIRE STIIART WINNEG, ESQIIIRE LORRAINE DOYLE, ESQIIIRE ALAN M. MINATO, ESQIIIRE CHANDRA M. ARREMA, ESQII' .com Deutsche Bank National Trust Company, as Trustee under the Pooling and Servicing Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 4828 Loop Central Drive Houston, TX 77081 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Guy W. Burford NO. 10-2045 Keith M. Burford 407 North Baltimore Street Mount Holly Springs, PA 17007 Defendant (s ) PRAECIPE FOR JUDGME~'NT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and Defendant(s) Guy W. Burford aad Reith M. Burford for failur Answer to Plaintiff's Complaint within 20 days from service for foreclosure and sale of the mortgaged premises, Plaintiff's damages as follows: against the e to file an thereof and and assess As set forth in Complaint $68,130.08 Interest Per Complaint 2,367.00 From 03/18/2010 to 08/14/2010 Late charges per Complaint 111.20 From 03/18/2010 to 08/14/2010 Escrow payment per Complaint 2,212.35 From 03/18/2010 to 08/14/2010 TOTAL $72,820.63 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. OFFICES, P.C. BY : '- i Attornevs for Plaintiff MARK J .__~TDR~N~~i~IRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE DAMAGES ARE HEREBY ASSESSED AS DATE: INDI T P HY UDREN 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 WOODCRSST 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 under the :CIVIL DIVISION Pooling and Servicing ':Cumberland County Agreement dated as of March 1, 2006, GSRPM Mortgage Loan :MORTGAGE FORECLOSURE Trust 2006-1 Plaintiff v. Guy W. Burford Keith M. Burford =NO. 10-2045 Defendant (s) TO : Guy W . Burford 407 North Baltimore Street Mount Holly Springs, PA 17007 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary X Judgment by Default Money Jug Judgment Judgment Judgment Judgment Judgment figment in Replevin for Possession on Award of Arbitration on Verdict on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren, Esquire At this telephone number: 856-669-5400 IIDREN LAW OFFICES, P.C. " MARK J. UDREN, ESQIIIRE - ID #04302 '~ STIIART WINNEG, ESQIIIRE - ID #45362 LORRAINE DOYLE, ESQIIIRE - ID #34576 ALAN M. MINATO, ESQIIIRE - ID #75860 CHANDRA M. ARKLNlA, ESQIIIRS - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SIIITB 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com ATTORNEY FOR PLAINTIFF Deutsche Bank National Trust COURT OF COMMON PLEAS Company, as Trustee under the CIVIL DIVISION Pooling and Servicing Agreement Cumberland County dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 :MORTGAGE FORECLOSURE 4828 Loop Central Drive Houston, TX 77081 Plaintiff v. Guy W. Burford €NO. 10-2045 Keith M. Burford 407 North Baltimore Street Mount Holly Springs, PA 17007 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILIIRE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and Defendant(s) Guy W. Burford and Keith M. Burford for failur Answer to Plaintiff's Complaint within 20 days from service for foreclosure and sale of the mortgaged premises, Plaintiff's damages as follows: As set forth in Complaint $68,130.08 Interest Per Complaint 2,367.00 From 03/18/2010 to 08/14/2010 Late charges per Complaint 111.20 From 03/18/2010 to 08/14/2010 Escrow payment per Complaint 2,212.35 From 03/18/2010 to 08/14/2010 against the e to file an thereof and and assess TOTAL $72,820.63 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. UD W OFFICES, P.C. DAMAGES ARE HEREBY ASSESSED AS DATE: ~ $Y: ~ ~-_&~t, e s for Plaintiff MARK J ~__LTDR IRE STUART WINNEG, ESQ IRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA~M~~ARKEMA, ESQUIRE INDICATED 1 ~ ~\ /1 PRO PRO UDREN 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. ARREMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 20 0 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust :COURT OF COMMON PLEAS Company, as Trustee under the :CIVIL DIVISION ,Pooling and Servicing :Cumberland County n ~; Agreement dated as of March 1, ~= ~ ~,t 2 0 0 6 , GSRPM Mortgage Loan '~"=' ~~ ~ -_~' ac r~ Trust 2006-1 € NO. 10-2045 4 `y `'"~ Plaintiff a ti v. ~ Guy W. Burford Keith M. Burford - ~ Defendant (s ) ~~ . ''' PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification for the Verification attached to the Complaint in Mortgage Foreclosure with regard to the captioned matter. DATED: August 14, 2010 UD W OFFICES, P.C. Attorne aintiff MARK J. UDREN,_ ES U STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE .+ r, V E R I F I C A T I O N The undersigned, an officer of the Corporation which is the Plaintiff in the foregaing Complaint or an officer of the Corporation which is the servicing agent of Plaintiff, and being authorized to make this verification on behalf of the Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint are taken from records maintained by persons supervised by the undersigned who maintain the business records of the mortgage held by Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: ~j""a-~~tC~ Name : '~enise Bailey Tit 1 e : ASSistaIIt SeCYetaly Company Guy W. Burford Keith M. Burford Loan #18481176 MJU #10030072-1co (Cumberland County, Pennsylvania) a 4 UDREN 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 ADAM L. KAYES, ESQUIRE - ID #86408 24ARGUERITIE L. THOMAS, ESQUIRE - ID #204460 WOODCREST'CORPORATE CENTER 111 WOODCAEST ROAD, SUITE 200 CHERRY HILL, NJ 080x13-3620 856-669-5400 Deutsche Bank National Trust COURT OF COMMON PLEAS Company, as Trustee under the `:CIVIL DIVISION Pooling and Servicing :Cumberland County Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 NO. 10-2045 Plaintiff v . Guy W. Burford ?w 4 Keith M. Burford Defendant(s) u PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: November , 2010 UDREN LAW OFFICES, P.C. BY: /? .. Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ;ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE P Service of Process by Dl utsche Bank National Trust Company, as Trustee, et. al., APB International, Ltd. I'IaiFFs) - vs. r3+ 1-800-328-7171 Guy W Buford, et. al., Defendant(s) ¦ APS International Plaza ' 7800 Glenroy Road Minneapolis, MN 55439-3122 APS File #: 107380-0001 AFFIDAVIT OF DUE AND DILIGENT ATTEMPT UDREN LAW OFFICES Ms. Henni Crommartv 111 Woodcrest Rd., Ste. 200 Cherry Hill, NJ 08003-3620 Customer File: 10030072-1 --Keith M. Burford Court Case No. 10-2045 ------ ----------------------- --- State County olF• 'o seq. Name of Server: T/r7 , undersigned, being duly sworn, deposes and says t_ _t at all tins menti rd herein- s/he was of legal_ age and was not a party to this action, Documents Served: the undersigned attempted to serve the documents described as: Notice of Sheriffs Sale of Real Property Service of Process on: The undersigned attempted to serve the documents on Keith M. Burford and after due and diligent efforts, was unable to effect service. Attempts: The following is a list of the attempts made to effect service: Dale i TimeiAddress r$a: 407 North :Baltimore Avenue, Mount Holly Springs, PA Atiearp' 17065 /0A"/" a x? - Reason for Nan-Service:. Dates/Time/Address Attempted- Reason ? ?dfor .Non-Service: Dayes,'TtmeiAddress AttenipWL: Reason for Non-Service: ? Based upon. the above stated facts, Af tant believes the defendant is qyc?di Signature of Server: Undersigned declares under penalty of perjury se and/ that the f going is true and e t. av of °, t ignature o Server blic APS InteM omd' Ltd. ?O Service of Process on: 11 Y10-14WEALTH OF PENNSYLVANIA Notarial Seal 'Wichaile Guyton, Notary Public r iv60 Soro, Cumberland County Tmli sloe Expires July 1, 2012 Mnsylvanla Association of Notaries serviee_ me this 1.4 20. r UDREN 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 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 under the :CIVIL DIVISION Pooling and Servicing :Cumberland County Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 :NO. 10-2045 Plaintiff V. Guy W. Burford Keith M. Burford Defendant(s) MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT - ?a .tz i ? Plaintiff, by its counsel, moves this Honorable Court for an order directing service of the Notice of Sale upon Defendant(s), Keith M. Burford by regular mail and certified mail and in support thereof avers the following: 1. Process was unable to be served at the then last known address of said Defendant(s) at 407 North Baltimore Street Mount Holly Springs, PA 17007, which is the mortgaged premises. A copy of the Return of Service is attached hereto as Exhibit A. 2. Pursuant to Pa.R.C.P. 430, Plaintiff made a Good Faith Investigation, the report thereof being attached hereto as Exhibit B. 3. Said investigation was unable to determine an alternate address for said Defendant(s). 4. The last known address of Defendant(s) is as set forth in the attached Exhibits. 5. Judge J. Wesley Oler Jr granted a Motion for Alternate Service, as to defendant, Guy W. Buford, on June 8, 2010. WHEREFORE, Plaintiff prays and respectfully requests that this Honorable Court enter an Order pursuant to Pa.R.C.P. 430 directing service of the Notice of Sale by regular mail and certified mail upon said Defendant(s), Keith M. Burford. UDREN LAW OFFICES, P.C. BY: ? I„- MIA^ Attorneys for Pl ntiff MARK J. UDREN, E DIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ADAM L. KAYES. ESQUIRE taut ctsr E>aTtf: tiaTiurl:lf frsast' C:oslrgan '. as Tru."tt•, e. at.. APS InteT a atittTial, U.C?. T'iaixltii€(s V5. _ 1-800-'32 -''171. :.'it?.''S!4. T{tid.,,; tt; ec, stT„ }"3'ifenti:tnTix? , . t'S iezu?rtstltiIISDSit f'teu 7800 L:ierttt?± Strad ttinviv fotT , iti?4 4j.3122 itE I ?ryC!"4'jC.F+ilr?fi'fJ'CY'.ti.( tf 11; ',4?t. Ficr:nT'CrarrllrP:lrl? ( t"t,t1t': ?°tise !4'n.. '?t?-Z(l?i:? f } i2i W(mAerc0Rd.,Sit. NO 4'ttct t ' is IR NJ O SON-3620 i R'1,ttiTIIttts?r Tir_ lEiti.'ffTfi';:..,Z_ { _ Ni1ZtY?,F r>f`.`f'S'C;': F ?•? w.l• Y'A ,clr! n . c.., <w } ,'.iFl.E' i T7i?;' :\4't7fI1._ d :?7(?ZC' S tilt •.i ti'a! ;f` M1? tF111t . (1tCr1 1't7fiL"r} t«F.:R:. S.Fh w:: o l:`.?a, t • - of T acG , s7??t tl:k5 n't?: a ;yattK' tc? artjott': T3r,clxre,cllt. s+rr?`eci thc: Und;.XSiizncd :stt: n'gAcd to senT the. do,umznu dcs-sii%cd as. Nlafiva ofiSheriff`4 5411.. of Real Propertv F: r-4'3 t'C t)f.^rfrct:s; P.m '.lr untl:: i'Sli?TIC: ( :it3.»T?1af}Ti, e to SwTST°'1 t}{lCklil?: Tl1:?? ?T: K.A.1ith Nf. ''Burford ........... ............ ........... .,.. .......................................... .._.._ arld all :r dllc and dill-gent c^l=zorm, was unati}, ta.cffz-J survicc.. tt< 11r?1 ,: 7-11e frtllfm inn is r, t ist of tale att-z-mpts made to e$ ct'sc:r: icc- 40" North Tiabhunrc, :t.vrllua., htnuu(TF %P3} S,t rhq . PA 3?nir.>'Trrzr+•%:1;1dr'css htit'rPt}r4e^d?_ Rea.um ter Nkm! rvk!` ?? 1 l ( T ^.a M: 1y arF p r 1 !}Y t.x.i +:?..:y r Ly', niltm. 11mv.'All rtresa, ATt;*:;evlec?: Prau,? Tnr tinn -A'mier'C; RtnXxivi Tim, Noll IZRrvl-L- t >. _ F Ff.i.;c.cs.1.1 i{ri1 i'{7[' i T,{11.'y'.1:94 ?.?t 1 ? ., t f. .411:_ }5 ,?1r-, C.. ?'S'1•-- tl ? t?'- :4kRrlClY7ar. ' ? r ' ` •r ? 4tri• t113 t[1C'C Cll . ,+ i i/"'S-E!T': ? ' { l'it? ?i1?}11G+: di ':i.'.r +: t7nt t 3'113 it f Tilll^i +1i>!?ti 1' (?f'umi S1; fn tC ?t17?'-1,G. +,fiis '':ha! t-ir• f.4r"poing ;, LTuc end ;p rer ,;• , 'rttb?. ?11ff2-tliii'3.4liifi?, li?'?. ) .; r>t.,a-, c ,?. rc:rnua?ar,:! wJi;l}Y_, t Page 1 of 2 PLAYERS NATIONAL LOCATOR AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number: 10030072-1 Attorney Firm: Mark J Udren & Associates Case Number: Subject: Keith M Burford A.K.A: Keith Burford, Keith W Burford Last Known Address: 407 N Baltimore Street Mount Hollys Springs, PA 17065 Sandra Krekeler, being duly sworn according to law, deposes and says: 1. 1 am employed in the capacity of Location Specialist for Players National Locator. 2. On November 8, 20101 conducted an investigation into the whereabouts of the above named defendant(s). The results of my investigation are as follows: CREDIT INFORMATION A. SOCIAL SECURITY NUMBER(S): 193-52-)o= B. EMPLOYMENT SEARCH: We were unable to verify current employment for Keith M Burford. C. INQUIRY OF CREDITORS: Creditors indicated the last reported address for Keith M Burford is 407 N Baltimore Street, Mount Hollys Springs, PA 17065 with no valid home number. INQUIRY OF TELEPHONE COMPANY A. DIRECTORY ASSISTANCE SEARCH: Directory assistance does not have a listing for Keith M Burford. INQUIRY OF NEIGHBORS We contacted (717) 486-8426 registered at 409 N Baltimore Avenue, Mount Holly Springs, PA 17065 and spoke with a neighbor who stated Keith M Burford moved from 407 N Baltimore Street, Mount Hollys Springs, PA 17065. INQUIRY OF POST OFFICE A. NATIONAL ADDRESS UPDATE: As of November 2, 2010, the National Change of Address (NCOA) has no change for Keith M Burford from 407 N Baltimore Street, Mount Hollys Springs, PA 17065. MOTOR VEHICLE REGISTRATION A. MOTOR VEHICLE & DMV OFFICE: We were unable to verify current drivers license information for Keith M Burford. EXHIBIT B Page 2 of 2 OTHER INQUIRIES A. DEATH RECORDS: As of November 2, 2010, the Social Security Administration has no death record on file for Keith M Burford and/or A.K.A.s under the social security number(s) provided. B. PUBLIC LICENSES (PILOT, REAL ESTATE, ETC.): None found. C. COUNTY VOTER REGISTRATION: We were unable to confirm a listing with the County Voters Registration Office. ADDITIONAL INFORMATION ON SUBJECT A. DATE OF BIRTH: Keith - March 1970 AFFIANT San a Krekeler K 1 rNE Notary Sub scri and sw to before m AM KI on ove r 8, 2010 011c, N ary Seat St St. ot9 of MlsU [EM,, C co m j t ton Cc I 66 ggC2, 2014 Players National Locator, 14444 Manchester Road, Manchester, MO 63011 Phone: (636) 230-9922 Fax: (636) 230-0558 UDREN 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 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 under the :CIVIL DIVISION Pooling and Servicing :Cumberland County Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 =NO. 10-2045 Plaintiff V. Guy W. Burford Keith M. Burford Defendant(s) MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule the plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. NOTE: A sheriff's return of "not found" or the fact that a defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). Notice of intended adoption mailed to last known address requires a "good faith effort" to discover the correct address. Adoption of Walker, 468 Pa. 165, 360 A2d 603 (1976). An illustration of a good faith effort to locate the defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and employers of the defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As set forth in the Return of Service marked Exhibit A, the Sheriff and/or Process Server has been unable to serve the Notice of Sale. A good faith effort to discover the whereabouts of the Defendant (s) has been made as evidenced by the attached Affidavit of Good Faith Investigation marked Exhibit B. WHEREFORE, Plaintiff prays and respectfully requests service of the Notice of Sale upon Defendant(s) by regular mail and certified mail. UDRENN LAW OFFICES, P.C. BY: N-1 146, ?Akk Attornbys for P intiff MARK J. UDREN, QUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ADAM L. KAYES, ESQUIRE VERIFICATION The undersigned hereby states that he/she is the Attorney for the Plaintiff in this action, that he/she is authorized to take this Verification, and that the statements made in the foregoing MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of his/her knowledge, information and belief . The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Sec 4904 relating to unsworn falsification to authorities. Date: November 10, 2010 UDREN LAW OFFICES, P.C. BY:Au&4 i?m Attorneys forvlaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ADAM L. KAYES, ESQUIRE UDREN 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 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 under the :CIVIL DIVISION Pooling and Servicing :Cumberland County Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 :NO. 10-2045 Plaintiff V. Guy W. Burford Keith M. Burford Defendant(s) CERTIFICATE OF SERVICE I, hereby certify that I have served true and correct copies of the attached Motion For Special Service upon the following person(s) named herein at their last known address or their attorney of record by: Regular First Class Mail Certified Mail Date Served: November 10, 2010 TO: Keith M. Burford 407 North Baltimore Street Mount Holly Springs, PA 17007 UDREN LAW OFF ES, P.C. BY: Attorneys for aintiff MARK J. UDREN, SQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ADAM L. KAYES, ESQUIRE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Deutsche Bank National Trust Company, as Trustee under the Pooling and Servicing Agreement dated as of March 1, NO. 10-2045 2006, GSRPM Mortgage Loan Trust 2006-1 Plaintiff V. Guy W. Burford Keith M. Burford Defendant(s) O R D E R , _ AND NOW, this Z 2 .,, d day of 1 i a v. , 2010, upon consideration of Plaintiff' s Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of .Sale and all subsequent pleadings on Defendant(s), Keith M. Burford, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Notice of Sale and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant(s), Keith M. Burford at 407 North Baltimore Street Mount Holly Springs, PA 17007 and by posting the mortgaged premises located at 407 North Baltimore Street, Mount Holly Springs, PA 17007. ill.o Aotaw?, L. yes Est, G CU ° o = C) .{ F" , rn !M CD rn mailed cop , ? ro rn y r =? x ri GC -V Cl-n =CD s, .. c 5c-) V ?- cn D ;0 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER ATTORNEY FOR PLAINTIFF 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Company as Trust :COURT OF COMMON PLEAS , ee under the Pooling and Servicing :CIVIL DIVISION Agreement dated as of March 1 =Cumberland County , 2006, GSRPM Mortgage Loan Trust 2006-1 ' Plaintiff : NO. 10-2045 V. Guy W. Burford Keith M. Burford Defendant (s) - 11 PRAECIPE TO FILE PROOF OF SERVICE czi n r1ri zz --:u TO THE PROTHONOTARY: r d "b co - - D p r . Kindly file the attached Proofs of Service with ee ; the captioned matter. r d o on Date: December?( 2010 -r UDREN LAW OFFICJ?FS,,,KC. BY: Attor ,tff ajlnbs3 )juelq '9 awaar 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Deutsche Bank National Trust Company, as Trustee under the Pooling and Servicing Agreement dated as of March 1, NO. 10-2045 2006, GSRPM Mortgage Loan Trust 2006-1 Plaintiff v. Guy W. Burford Keith M. Burford Defendant(s) O R D E R AND NOW, this ?z •,? day of 2010, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale and all subsequent pleadings on Defendant(s), Keith M. Burford, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Notice of Sale and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant (s) , Keith M. Burford at 407 North Baltimore Street Mount Holly Springs, PA 17007 and by posting the mortgaged premises located at 407 North Baltimore Street, Mount Holly Springs, PA 17007. G? C: .? EXHI13IT ? F, //C^ UDREN LAW OFFICES Nis. Henni Crommarty I I I Woodernt Rd., Ste. zoo Cherry I il, NJ t16o03-3620 --Keith M. Burford, by posting Court Case No. 1o-2045 State of: o - - _ _ - - --- -- County t: - - - - - Name of Server: ss. that at the time of service, s/he was of legal tiger s gned, being duly SWorn, deposes and says Date/Time of Service: that on the 'W's 'lot a party to ibis xenon: !:?? day of Place of Service: 20/,?2 at/ 2?ciockM at 407 North Baltimore Avenue Documents Served. , in Mount Holl S rin PA 17065 the undetxigt?e+d. sawed the doeu as: Notice of Sherifrs Safe of Real Prop nr•ty, w/ Order Service of Process on: A true and correct copy of the aforesaid document(s) was s Person Served, and Keith M. Burford, by posting erved on: Method of Service: - *,By personally delivering them into the hands of the By person to be served. deOverin them into the harrds of e. ?,? a person Of suitable age. who verified, or who upon questioiring stated, that he/she rest Keith M. Burford, by posting des with r Description at the place of service, and whose relationship to the ' of Person The person receiving documents is described as follow .Person is: ReceivingDocuments: Sex - : Skin Cabe s Approx. Age Hair Color Facial, Hair Approx. ifeight y To the the time best of my knowledge and belief, said person Approx. Wei, Of service. as not a gag d in the US Mil itat Signature of Server: Undersigned declares under Penalty that of perjury s? or in and rorr t. C I rr a sworn to before rrre 2 Is of Serve APS Inter tional, Ltd. P (Commission in.?? COF TM ir NI?YI-ViANIA Al; Coawrs som alpaC urN?ouP Y 1, 7012 )EXHIBIT B Deutsche Bank National Trust Co Pwatiff(s) mpany, as Trustee, et, al., vs. Guy W. Buford, et. al.. Defendant(s) Service of Process by APS International, Lt(L 1-800-328-7-171 APS International Plaza 7800 Gienroy Rd. Minneapolis, N1N 55439-3122 APS File M: 10738).0002 AFFIDAVCT OF SERVICE -- Individual Service of process an: SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ; Jody S Smith Chief Deputy Richard W Stewart Solicitor OFF ,CF - -E,[;F Deutsche Bank National Trust Company Case Number vs. Guy W. Burford (et al.) 2010-2045 SHERIFF'S RETURN OF SERVICE 10/11/2010 03:13 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on 10-11-10 at 1506 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 Guy W. & Keith M. Burford, located at, 407 North Baltimore Avenue, Mount Holly Springs, Cumberland County, Pennsylvania according to law. 10/11/2010 03:13 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on 10-11-10 at 1506 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 Guy W. Burfod, by posting upon the property of Guy W. Burford, located at, 407 North Baltimore Avenue, Mount Holly Springs, Cumberland County, Pennsylvania, pursuant to Court Order. 10/11/2010 03:13 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on 10-11-10 at 1506 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 Keith M. Burfod, by posting upon the property of Keith M. Burford, located at, 407 North Baltimore Avenue, Mount Holly Springs, Cumberland County, Pennsylvania, pursuant to Court Order. SHERIFF COST: $908.92 SO ANSWERS, t: October 26, 2010 RON R ANDERSON, SHERIFF EXHIBIT IR 1ci CouniySuite Snenfl. Teleas?tt Inc. 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 under the :CIVIL DIVISION Pooling and Servicing :Cumberland County Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 Plaintiff - w , -+ x -ri rn rri- v . ;?_ -2 r cra .,.} c-a rv -v r* c? Guy W. Burford co Keith M. Burford : NO. 10-2045 o--6 CD c=? Defendant(s) D 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 a true and correct copy of the Notice of Sale was mailed to Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: DATE MAILED: October 25, 2010 & December 1, 2010 Guy W. Burford 407 North Baltimore Avenue Mount Holly Springs, PA 17007 Keith M. Burford 407 North Baltimore Street Mount Holly Springs, PA 17007 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: December 7f , 2010 UDREN LAW OFFICE; P.C. BY: qJJ6tP Vd Attorney o tb 9 awe[ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Deutsche Bank National Trust Company, as Trustee under the -Pooling and Servicing Agreement dated as of March 1, NO. 10-2045 2006, GSRPM Mortgage Loan ? it ? lj ? ? - ?; •` Trust 2006-1 Plaintiff V. Guy W. Burford Keith M. Burford Defendant (s) O R D E R AND NOW, this V Y4 day of , 2010, upon consideration of Plaintiff Is Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage Foreclosure and all subsequent pleadings on Defendant(s), Guy W Burford, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies -o.-IL' the Complaint in Mortgage Foreclosure and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant(s), Guy W Burford at 407 North Baltimore Avenue Mount Holly Springs, PA 17007 and by posting the mortgaged premises located at 407 North Baltimore Avenue Mount Holly Springs, PA 17007. BY THE COURT: r EXHIBIT B H O Z o 9 J? o• xn Fin phi O ro rr a r• E W U1 (D ro? (D O O J O p C =?mm m z ?8 =vp? F'm°o--nn `E?m Z 0 M m . ?- a- L E m'm m m a .o -0 Posag Certified Fee S ' ? Poetrnerk r 0, O Realm Receipt Fee Here ---? - O O (Endorearmnt Required) C3 i C ResMcted Delivery Fee C O (Endorsement Required) -j e & Fees $ t l P ra r- os ag Tota rq rR co to Guy W. Burford C3, C3 407 North Baltimore Avenue o<PO ewr nro . 'cn s s6aie; z? + Mount Holly Springs, PA 17007 ---- -"---_._ .a d . - .ti??? r:1vrt1+ Hasler CT1 a) 1 ?? Flo 0 ? ca EXHIBIT B 1. 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W C CZ T? c 0 O O w 0 O v N 1 C 3 cr (D (n TI O 3 W V V CD CS v Co co N O 3 A Q 0 O D a (T .0 w 3 O W O M 7 r c o . CA . A . W _... N . CD O CO CD -4 O CJ7 A W N -+ m Q':3 7 CD D v (nb fla Q c CD CD =@ CCDD CD N O C CD m 7 CO O 3 rr C1 N O N _ Cr O CD N O Y/ ? J ? o O -4 c 3 ? - (D o o D opv CL O D mpm e =r w CL a Z M o Z m O 0 m N o (n 0 0 Q' cn ? n ?0 H cn m CD c z n„ c n D - v D CCDD a 3 ?yy Con -4t_ 0 w OCR d p CD a I Wmn O V 24 N m o o m D 2 4 1 y [A ? ? ? ? T fD o 3 0 CD 7 C CO f n a m f F o n m f T T v a f S' m f { 53;p x f y P CTD o m C f v r . t.,ti (4 CD CL M t wr 3 O N CCDD w ( J, ._ f ,tai'' (? 2 d Cn c a o a c l m 2 m ,° ^. .... S N oma=moo; ?n 3>> ... a ? ? cpS o o m •? 0? (Q C y' x q 6 o w O E E S (D 41 . O ry_ j c m j- y n C ou COLoo y O ' 3 F is a n C ? o? oo CD v -?. (A m m bo o m c a n Q c W Q o o me$m? 3 m c n vmiomoa m = O'7 x = ?. m O 52.E m'SCa 3 N O m m y ~ N C O 3 M o m' m -a M - am 1 m m 25- v 0 a 3 ?awy 8 03 acv O CL CD m m m m CD N a ^_Z (D m09.3--='9 5CD N w m 40i y N O S aO.O m voQo'm G CD ? 263 ' _ $ c O 4t o O CD N w .? m - N - N -n i(J . O t0 O O m N O y 0 0 0 m N P _ o 3 am °-mm a ?O _ a3 mv2°' 9 m^ - _ ?1 rn -wfD m -i 0 n to CD W tr d 0 o . O CD CD N ?y c x g CD In c U EM y?g (D mi v c y 3 mm CO N O n m O 3 X X H 3. B o a X B' Q O a m x O M ,0 m d CD m o m a CD CD IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION? Deutsche Bank National Trust Company, as Trustee under the Pooling and Servicing Agreement dated as of March 1, NO. 10-2045 2006, GSRPM Mortgage Loan Trust 2006-1 Plaintiff v. Guy W. Burford Keith M. Burford Defendant(s) O R D E R AND NOW, this day of ?p v 2010, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale and all subsequent pleadings on Defendant(s), Keith M. Burford, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Notice of Sale and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant(s), Keith M. Burford at 407 North Baltimore Street Mount Holly Springs, PA 17007 and by posting the mortgaged premises located at 407 North Baltimore Street, Mount Holly Springs, PA 17007. ?- Q ?tT - R ! R T13 0 o N o ? xn ? O rr H?r F-' w an C/1 N Fii ro rr O Fl- ?s o a tomD ((D cn ro rr ?n H ((D J rr O O J ?e ooz O 2 23 M <0C.) =0o* FM?T 0 Or?? OMn T N r- •?? ? ns1? 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S ? ,vim o m q w O ,? o 0 CL 33?$oN d H a m m ° DCiA c" p 30 OR d 0 .: . . m m 02, 0. n 3 c c y a c = n 0 CD <D m o ? 7 .,, O N O m c C °-' o m o. y m A 3 ° fD > > m x n? m3 c ? ° 3 =«? 0 C O n D .N3 w da= C D om co a?x 3 pnN * n 3 = ? (D m ' m ° y 05an . 08 0 a - x 3 .3 S 4 - 3 m . ?!nd aim A -n ;U v N -w o n o° o y? N u N Cb O 7 m SO C m 3 c W ?' n T fn c'?D a 0 d 1 . j f^ ? m ody3 CD a. N Vim-; ' 3m3 - - ECD d m c c 3 u C n /n N 2 w m m ntn3 ?0^?03 " 3 ??g? ? ?T ? o o m? RL N m > > v. Q m W? N N m o_ CD m o N tDkEN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Company, as :COURT OF COMMON PLEAS Trustee under the Pooling and Servicing :CIVIL DIVISION Agreement dated as of March 1, 2006, GSRPM :Cumberland County Mortgage Loan Trust 2006-1 Plaintiff c-) c. v.}c? . rn Guy W. Burfordi - Keith M. Burford :NO. 10-2045 r? De f endant (s) AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 --+ -G Plaintiff, by its/his/her Attorney hereby verifies that: 0 a a rn r= r n o co C? - C) x -n "0 O -n o r-) sv --4 73 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: December 2010 UDREN LAW OFFICES, P.C. BY: Att re UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust :COURT OF COMMON PLEAS Company, as Trustee under the :CIVIL DIVISION Pooling and Servicing :Cumberland County Agreement dated as of March 1, 2006, GSRPM Mortgage Loan :MORTGAGE FORECLOSURE Trust 2006-1 Plaintiff V. Guy W. Burford € NO. 10-2045 Keith M. Burford Defendant(s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Deutsche Bank National Trust Company, as Trustee under the Pooling and Servicing Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1, Plaintiff in the above action, by its attorney, Udren Law Offices, P.C., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 407 North Baltimore Street, a/k/a 407 North Baltimore Avenue, Mount Holly Springs, PA 17007 1. Name and address of Owner(s) or reputed Owner(s): Name Address Guy W. Burford Keith M. Burford 407 North Baltimore Avenue Mount Holly Springs, PA 17007 407 North Baltimore Street, a/k/a 407 North Baltimore Avenue, Mount Holly Springs, PA 17007 407 North Baltimore Street Mount Holly Springs, PA 17007 407 North Baltimore Street, a/k/a 407 North Baltimore Avenue, Mount Holly Springs, PA 17007 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Providian National Bank 295 Main Street Tilton, NH 03276 4. Name and address of the last recorded holder of every mortgage of record: Name Address Deutsche Bank National Trust Company, as Trustee under the Pooling and Servicing Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 4828 Loop Central Drive Houston, TX 77081 Wells Fargo Bank Minnesota, NA, S/B/M to Norwest Bank 505 South Main Street, Suite 6000 Minnesota, NA, as Trustee of Orange, CA 92868-4509 Salomon Brothers Mortgage Securities VII, Inc., Floating C/O: Frank Federman Rate Mortgage Pass-Through One Penn Center Plaza Certificates, Series 1999-AQ1 Suite 1400 Under Pooling and Servicing Philadelphia, PA 19103 Agreement Dated as of March 1, 1999 Without Recourse, Pennsylvania Housing Finance 211 North Front Street Agency Harrisburg, PA 17101 5. Name and address of every other person who has any record lien on the property: Name Address Commonwealth of Pennsylvania Department 280946 Department of Revenue Harrisburg, PA 17128-0946 Bureau of Compliance 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue 13 North Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 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 Address Tenants/Occupants 407 North Baltimore Street, a/k/a 407 North Baltimore Avenue Mount Holly Springs, PA 17007 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. sec. 4904 relating to unsworn falsification to authorities. DATED: December Zl , 2010 UDREN LAW OFFIC P.C. BY: A t t eys iff VA 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 under the Pooling and Servicing Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 Plaintiff V. Guy W. Burford Keith M. Burford Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-2045 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Guy W. Burford and Keith M. Burford PROPERTY: 407 North Baltimore Street, a/k/a 407 North Baltimore Avenue Mount Holly Springs, PA 17007 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on December 8. 2010, at 10:00am, in the Commissioners Hearing Room, 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. EXHIBIT A G7 c a] c O Q T? 3 K C O Q O O co O 0 v N n C cr CD v Q CA 0 3 W co v v CD Q c Cu to Co A O 3 C fA CT O 0 O O O. 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D0 CCDD COD ?0 C ?'a „m ?9 0 MF- - y c p d ON' c 3 ?_? y y rn ? .- o> _ ? nD w - o hm V ° O wm h 14 y m u vm3 v N CD D < 0 CD -4 0 Z fn m (7 - Bz CD 0 Z 0 co -? :3 c Dim " . hi c ° Dmo ao -4 CD Vr? ? ym m D o 0) CD co CD N z0 Z cX n w CD 0) maD CD v ?m? 0 wv w m a = c > N m -0 ? ? ?? ?c CA) m o O ai ; m ? :L v c ?c HS W f D a a am VJ N C CL rri 1 1 co CD 1 ?- r ??(D? . m CD F - .. • -n y =CD - _ Dt {{ 0, F 78y CD CD . -moo y m a3 N 1 ` N (1 l 1 -i i T ) O1• CD fD t?0 C N N 1 ... n R w e o n .+ r•. . c.. 3o w$ om g " =D) n - m°`a33.oo. (pa ??c] TDS J J J tD K ° O fG C C (C' NCl C < y 7C =.o m ?' 0 m 3 `° $ o y ?,y n ' a N ?p N O m. ¢fA? 01 .fDO ° m ?' N > > NC fD '==. N ii c m m ? ? n N 0 1 8 on d C N lD C N d 0 O C ° _ J i 0 '!R = ' Sd (1 <CL = 9.mm>?3 N d o a o a» > m 3 n N O ?y ?5.md . o d 3 o H m T ? -? 0 OD) D) 0 A w Sax m 3md ?? ? ti ya vCD 0`v . N ON. nO ? 080 ` O N 7C• NO v m?oc?d v3°v? 3 M v 00 Z O-= v=: O yd,m N O O 3 JC C G. - N oa m C macm2? JodNO ? nw ID Q C ?N o.JJ JN m 53 m0 m y y m= m 3 c CD CD 2 O C 3 ? 4i J n 91 d N Q f p ? ( ?_ O n N O .Z1 o EX HIBIT A w v fD J J 'O. Q . =j5 ? W N O • O I D c 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 under the :CIVIL DIVISION Pooling and Servicing ;Cumberland County Agreement dated as of March 1 , 2006, GSRPM Mortgage Loan Trust 2006-1 N0. 10-2045 .? Plaintiff = y , V. Guy W. Burford Keith M. Burford Defendant (s) PETITION FOR POSTPONEMENT OF SHERIFF'S SALE Plaintiff, by its counsel, petitions the Court for a (2) two month postponement of the Sheriff's sale scheduled in the above captioned matter and in support thereof avers the following: 1. A Sheriff's sale of the mortgaged property involved herein, located at 407 North Baltimore Street, a/k/a 407 North Baltimore Avenue, Mount Holly Springs, PA 17007 was originally scheduled for December 8, 2010, then postponed to January 5, 2011 to allow time to complete service of the Notice of Sheriff's Sale on the Defendants, then postponed to March 2, 2011. 2. The Plaintiff now seeks the postponement of the Sheriff's sale(2) two month(s)to allow Plaintiff to resolve the pending assignment issue. 3. Pursuant to local rule the defendants are unrepresented by counsel and plaintiff has no manner in which to seek concurrence except by mail. 4. The Honorable J. Wesley Oler, Jr., was assigned to this matter and granted Plaintiff's motion for special service. Y WHEREFORE, Plaintiff respectfully prays and requests that the Sheriff's sale of the mortgaged property be postponed to the May 4, 2011 Sheriff's sale. athan Wolf, Esquire Local Counsel Respectfully submitted, UDREN LAW OFFICES, P.C. BY: "'nA3-0hq ldma Attorney for Plaintiff Oorwft M. Arkema, Esquire PAID 203437 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 under the :CIVIL DIVISION Pooling and Servicing Agreement :Cumberland County dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 Plaintiff `NO. 10-2045 V. Guy W. Burford Keith M. Burford Defendant(s) PLAINTIFF'S MEMORANDUM OF LAW Pennsylvania R.C.P. 3129.3(b) allows for the postponement of a Sheriff's sale. In the present matter, the sale has been previously postponed. Plaintiff now seeks an additional postponement in order to resolve the pending assignment issue. Therefore, in order for the Plaintiff to be able to properly conduct itself at the Sheriff's sale, a postponement of the sale is necessary. Pa.R.C.P. 3129.3(a) allows the postponement of the sale more than once, and without new notice, by Special Order of Court. Accordingly, for the reasons hereinabove stated, and as more particularly set forth in the Motion, Plaintiff respectfully requests continuance of the Sheriff's Sale of the mortgaged premises, located at 407 North Baltimore Street, a/k/a 407 North Baltimore Avenue, Mount Holly Springs, PA 17007, to the May 4, 2011 Sheriff's sale as set forth in the Motion. Respectfully submitted, Local C UDREN LAW OFFICES, P.C. an C kff,, quir e a ? :1 BY: Attorney for Plaintiff Chenft M. Arkomma, Esquire PA 10 203437 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 under the ;CIVIL DIVISION Pooling and Servicing ;Cumberland County Agreement dated as of March 1, 2006,.GSRPM Mortgage Loan Trust 2006-1 NO. 10-2045 Plaintiff V. Guy W. Burford Keith M. Burford Defendant (s) CERTIFICATE OF SERVICE The undersigned certifies that true and correct copies of the attached Petition for Postponement of Sheriff's Sale was served upon the following person(s) named herein at their last known address or their attorney of record by: xxxx Regular First Class Mail Certified Mail Other Date Served: March 1, 2011 TO: Guy W. Burford Keith M. Burford 407 North Baltimore Street 407 North Baltimore Street Mount Holly Springs, PA 17007 Mount Holly Springs, PA 17007 UDREN LAW OFFICES, P.C. BY: atha a , Esquire Attorney for Plaintiff Local u el CIMMft K Arkema, Esquire PA ID 203437 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Deutsche Bank National Trust Company, as Trustee under the Pooling and Servicing Agreement dated as of March 1, NO. 10-2045 2006, GSRPM Mortgage Loan Trust 2006-1 Plaintiff V. Guy W. Burford Keith M. Burford Defendant(s) O R D E R AND NOW, this (St day of March, 2011, after consideration of Plaintiff's Petition for Postponement of Sheriff's Sale of the mortgaged property located at 407 North Baltimore Street, a/k/a 407 North Baltimore Avenue, Mount Holly Springs, PA 17007, it is hereby ORDERED that the said Sale currently scheduled for March 2, 2011, is extended (2) two month(s) to the regularly scheduled Cumberland County Sheriff's Sale scheduled for May 4, 2011. No further advertising or additional notice to lienholders or Defendant(s) is required provided the postponement is announced at the March 2, 2011 Sheriff's Sale. TO: V"Guy W. Burford 407 North Baltimore Street Mount Holly Springs, PA 17007 Keith M. Burford 407 North Baltimore Street Mount Holly Springs, PA 17007 V Udren Law Offices, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 Attn: Sale Department ? Office of the Sheriff Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 (P, PS N1a l ed 31,1, E r i C..3 'E ?y yY 41? A % IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION MM -'? =!"t'!• Deutsche Bank National Trust' Company, as Trustee under the .?> Pooling and Servicing r- Agreement dated as of March 1, NO. 10-2045_ 2006, GSRPM Mortgage Loan_ Trust 2006-1 == ` Plaintiff V. _.Guy W. Burford Keith M. Burford Defendant(s) O R D E R AND NOW, this 4 fL day of May, 2011, after consideration of Plaintiff's Petition for Postponement of Sheriff's Sale of the mortgaged property located at 407 North Baltimore Street, a/k/a 407 North Baltimore Avenue, Mount Holly Springs, PA 17007, it is hereby ORDERED that the said Sale currently scheduled for May 4, 2011, is extended (2) two month(s) to the regularly scheduled Cumberland County Sheriff's Sale scheduled for July 6, 2011. No further advertising or additional notice to lienholders or Defendant(s) is required provided the postponement is announced at the May 4, 2011 Sheriff's Sale. BY, THE Jib Wesley 01(it, Jr.`" J. TO:'*"Guy W. Burford 1 407 North Baltimore Street Mount Holly Springs, PA 17007 ? Keith M. Burford 407 North Baltimore Street Mount Holly Springs, PA 17007 Udren Law Offices, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 Attn: Sale Department Office of the Sheriff Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 Uw`" ,Iql I bjta _o ? r Sq T ?= -C ;xr C z c ,7- i? --- "r o° CD A ` IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Deutsche Bank National Trust Company, as Trustee under the Pooling and Servicing Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 Plaintiff V. Guy W. Burford Keith M. Burford Defendant(s) O R D E R AND NOW, this r?6 day of July, 2011, after consideration of Plaintiff's Petition for Postponement of Sheriff's Sale of the mortgaged property located at 407 North Baltimore Street, a/k/a 407 North Baltimore Avenue, Mount Holly Springs, PA 17007, it is hereby ORDERED that the said Sale currently scheduled for July 6, 2011, is extended (3) three month(s) to the regularly scheduled Cumberland County Sheriff's Sale scheduled for October 5, 2011. No further advertising or additional notice to lienholders or Defendant(s) is required provided the postponement is announced at the July 6, 2011 Sheriff's Sale. NO. 10-2045 BY THE sley Ol?r, Jr TO : '/Guy W. Burford U 407 North Baltimore Street Mount Holly Springs, PA 17007 Keith M. Burford 407 North Baltimore Street Mount Holly Springs, PA 17007 Udren Law Offices, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 Attn: Sale Department Office of the Sheriff Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 (tip?C i??it', 1f? 7,Ql1 r_. uIp a o? , ` -C .? © X- o -rr C? ?- ;;a 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 under the :CIVIL DIVISION Pooling and Servicing :Cumberland County Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 -NO. 10-2045 Plaintiff V. Guy W. Burford Keith M. Burford Defendant(s) C ) N r_-y rnw MM c_ c= =-i -<?' cn c:) 4 C:) w 70 PETITION FOR POSTPONEMENT OF SHERIFF'S SALE Plaintiff, by its counsel, petitions the Court for a (3) three month postponement of the Sheriff's sale scheduled in the above captioned matter and in support thereof avers the following: 1. A Sheriff's sale of the mortgaged property involved herein, located at 407 North Baltimore Street, a/k/a 407 North Baltimore Avenue, Mount Holly Springs, PA 17007 was originally scheduled for December 8, 2010, then postponed to January 5, 2011 to allow time to complete service of the Notice of Sheriff's Sale on the Defendants, then postponed to March 2, 2011, then postponed to May 4, 2011 due to pending assignment issue, then postponed to July 6, 2011. 2. The Plaintiff now seeks the postponement of the Sheriff's sale(3) three month(s)to allow Plaintiff to resolve the pending assignment issue. 3. Pursuant to local rule the defendants are unrepresented by counsel and plaintiff has no manner in which to seek concurrence except by mail. 4. The Honorable J. Wesley Oler, Jr., was assigned to this matter and granted Plaintiff's motion for special service and prior petition to postpone sheriff sale. WHEREFORE, Plaintiff respectfully prays and requests that the Sheriff's sale of the mortgaged property be postponed to the October 5, 2011 Sheriff's sale. Respectfully submitted, UDREN LAW OFFICES, P.C. f BY i ath C. 6661f, Esquire Attorney for Plaintiff Local -ounsel Alan M. Minato, Esquire PA ID 75860 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 under the :CIVIL DIVISION Pooling and Servicing Agreement :Cumberland County dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 Plaintiff NO. 10-2045 V. Guy W. Burford Keith M. Burford Defendant(s) PLAINTIFF'S MEMORANDUM OF LAW Pennsylvania R.C.P. 3129.3(b) allows for the postponement of a Sheriff's sale. III the present matter, the sale has been previously postponed. Plaintiff now seeks an additional postponement in order to resolve the pending assignment issue. Therefore, in order for the Plaintiff to be able to properly conduct itself at the Sheriff's sale, a postponement of the sale is necessary. Pa.R.C.P. 3129.3(a) allows the postponement of the sale more than once, and without new notice, by Special Order of Court. Accordingly, for the reasons hereinabove stated, and as more particularly set forth in the Motion, Plaintiff respectfully requests continuance of the Sheriff's Sale of the mortgaged premises, located at 407 North Baltimore Street, a/k/a 407 North Baltimore Avenue, Mount Holly Springs, PA 17007, to the October 5, 2011 Sheriff's sale as set forth in the Motion. Respectfully submitted, athan C. 61f, Esquire Local Codrsel UDREN LAW.-OFFICES, P.C. BY: Attorney for Plaintiff Alan M. Minato, Esquire PA ID 75860 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 under the :CIVIL DIVISION Pooling and Servicing :Cumberland County Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 :NO. 10-2045 Plaintiff V. Guy W. Burford Keith M. Burford Defendant(s) CERTIFICATE OF SERVICE The undersigned certifies that true and correct copies of the attached Petition for Postponement of Sheriff's Sale was served upon the following person(s) named herein at their last known address or their attorney of record by: XXXX Regular First Class Mail Certified Mail Other Date Served: July 5, 2011 TO: Guy W. Burford 407 North Baltimore Street Mount Holly Springs, PA 17007 Keith M. Burford 407 North Baltimore Street Mount Holly Springs, PA 17007 UDREN LAW OFFICES, P.C. BY. Nathar ,p-' Wolf, Esquire Local Counsel Attorney for PlainEiff- Alan M. Minato, Esquire PA ID 75860 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 under the :CIVIL DIVISION Pooling and Servicing :Cumberland County Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 :NO. 10-2045 Plaintiff V. Guy W. Burford Keith M. Burford Defendant(s) PETITION FOR POSTPONEMENT OF SHERIFF'S SALE ?s r*; w Q c t Plaintiff, by its counsel, petitions the Court for a (1) one month postponement of the Sheriff's sale scheduled in the above captioned matter and in support thereof avers the following: 1. A Sheriff's sale of the mortgaged property involved herein, located at 407 North Baltimore Street, a/k/a 407 North Baltimore Avenue, Mount Holly Springs, PA 17007 was originally scheduled for December 8, 2010, then postponed to January 5, 2011 to allow time to complete service of the Notice of Sheriff's Sale on the Defendants, then postponed to March 2, 2011, then postponed to May 4, 2011 due to pending assignment issue, then postponed to July 6, 2011, then postponed to October 5, 2011. 2. The Plaintiff now seeks the postponement of the Sheriff's sale(1) one month to allow Plaintiff to review the pending Home Affordable Modification Program (HAMP)application. 3. Pursuant to local rule the defendants are unrepresented by counsel and plaintiff has no manner in which to seek concurrence except by mail. 4. The Honorable J. Wesley Oler, Jr., was assigned to this matter and granted Plaintiff's motion for special service and prior petition to postpone sheriff sale. WHEREFORE, Plaintiff respectfully prays and requests that the Sheriff's sale of the mortgaged property be postponed to the November 2, 2011 Sheriff's sale. Respectfully submitted, UDREN LAW OFFICES, P.C. BY P A torn y for Plaintiff d Local Counsel 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 under the =CIVIL DIVISION Pooling and Servicing Agreement aCumberland County dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 Plaintiff NO. 10-2045 V. Guy W. Burford Keith M. Burford Defendant(s) PLAINTIFF'S MEMORANDUM OF LAW Pennsylvania R.C.P. 3129.3(b) allows for the postponement of a Sheriff's sale. In the present matter, the sale has been previously postponed. Plaintiff now seeks an additional postponement in order to review the pending "RAMP" application. Therefore, in order for the Plaintiff to be able to properly conduct itself at the Sheriff's sale, a postponement of the sale is necessary. Pa.R.C.P. 3129.3(a) allows the postponement of the sale more than once, and without new notice, by Special Order of Court. Accordingly, for the reasons hereinabove stated, and as more particularly set forth in the Motion, Plaintiff respectfully requests continuance of the Sheriff's Sale of the mortgaged premises, located at 407 North Baltimore Street, a/k/a 407 North Baltimore Avenue, Mount Holly Springs, PA 17007, to the November 2, 2011 Sheriff's sale as set forth in the Motion. Respectfully submitted, UDREN LAW OFFICES, P.C. B Y G? Nathan lf, Esquire Attorn for Plaintiff Local C isel rV \ r 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 under the =CIVIL DIVISION Pooling and Servicing Cumberland County Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 ::NO. 10-2045 Plaintiff V. Guy W. Burford Keith M. Burford Defendant(s) CERTIFICATE OF SERVICE The undersigned certifies that true and correct copies of the attached Petition for Postponement of Sheriff's Sale was served upon the following person(s) named herein at their last known address or their attorney of record by: xxxx Regular First Class Mail Certified Mail Other Date Served: October 4, 2011 To: Guy W. Burford Keith M. Burford 407 North Baltimore Street 407 North Baltimore Street Mount Holly Springs, PA 17007 Mount Holly Springs, PA 17007 UDREN LAW OFFICES, P.C. BY- till Attoi7? y for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Deutsche Bank National Trust Company, as Trustee under the Pooling and Servicing Agreement dated as of March 1, NO. 10-2045 '= 2006, GSRPM Mortgage Loan n • t`r 1 - ? F•+? .?7 Trust 2006-1 -? r Plaintiff Guy W. Burford Ra 7 Keith M. Burford Defendant(s) r? w =-? 0 R D E R AND NOW, this LSl day of November, 2011, after consideration of Plaintiff's Petition for Postponement of Sheriff's Sale of the mortgaged property located at 407 North Baltimore Street, a/k/a 407 North Baltimore Avenue, Mount Holly Springs, PA 17007, it is hereby ORDERED that the said Sale currently scheduled for November 2, 2011, is extended (2) two month(s) to the regularly scheduled Cumberland County Sheriff's Sale scheduled for January 6, 2012. No further advertising or additional notice to lienholders or Defendant(s) is required provided the postponement is announced at the November 2, 2011 Sheriff's Sale. ABYE CO J .W4r, J. TO ? Guy W. Burford 407 North Baltimore Street d Mount Holly Springs, PA 17007 Keith M. Burford ojfe M OOP 407 North Baltimore Street Mount Holly Springs, PA 17007 Udren Law Offices, P. C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 Attn: Sale Department Office of the Sheriff -hand &Iiyerecl Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 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 under the ;CIVIL DIVISION Pooling and Servicing :Cumberland County Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 :NO. 10-2045 Plaintiff V. Guy W. Burford Keith M. Burford Defendant(s) PETITION FOR POSTPONEMENT OF SHERIFF'S SALE C-.) c c .- M =M t- f 1 c-y rn_ r- -0m : CTS' J : 0 CD I D c? XCZ = C7 3> C N ,ern cn co Plaintiff, by its counsel, petitions the Court for a (2) two month postponement of the Sheriff's sale scheduled in the above captioned matter and in support thereof avers the following: 1. A Sheriff's sale of the mortgaged property involved herein, located at 407 North Baltimore Street, a/k/a 407 North Baltimore Avenue, Mount Holly Springs, PA 17007 was originally scheduled for December 8, 2010, then postponed to January 5, 2011 to allow time to complete service of the Notice of Sheriff's Sale on the Defendants, then postponed to March 2, 2011, then postponed to May 4, 2011 due to pending assignment issue, then postponed to July 6, 2011, then postponed to October 5, 2011, then postponed to November 2, 2011, due to pending assignment issue, then postponed to January 4, 2012. 2. The Plaintiff now seeks the postponement of the Sheriff's sale (2) two month(s) to allow Plaintiff to resolve the pending assignment issue. 3. Pursuant to local rule the defendants are unrepresented by counsel and plaintiff has no manner in which to seek concurrence except by mail. 4. The Honorable J. Wesley Oler, Jr., was assigned to this matter and granted Plaintiff's motion for special service and prior petitions to postpone sheriff sale. WHEREFORE, Plaintiff respectfully prays and requests that the Sheriff's sale of the mortgaged property be postponed to the March 7, 2012, Sheriff's sale. Respectfully submitted, UDREN LAW OFFICES, P.C. Y?- Attorney for P aids K i t IVE. !matt, Esqk. irt:: Pia ID 75B60 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 under the -CIVIL DIVISION Pooling and Servicing Agreement ':Cumberland County dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 Plaintiff -NO. 10-2045 V. Guy W. Burford Keith M. Burford Defendant(s) PLAINTIFF'S MEMORANDUM OF LAW Pennsylvania R.C.P. 3129.3(b) allows for the postponement of a Sheriff's sale. In the present matter, the sale has been previously postponed. Plaintiff now seeks an additional postponement in order to resolve the pending assignment issue. Therefore, in order for the Plaintiff to be able to properly conduct itself at the Sheriff's sale, a postponement of the sale is necessary. Pa.R.C.P. 3129.3(a) allows the postponement of the sale more than once, and without new notice, by Special Order of Court. Accordingly, for the reasons hereinabove stated, and as more particularly set forth in the Motion, Plaintiff respectfully requests continuance of the Sheriff's Sale of the mortgaged premises, located at 407 North Baltimore Street, a/k/a 407 North Baltimore Avenue, Mount Holly Springs, PA 17007, to the March 7, 2012, Sheriff's sale as set forth in the Motion. Respectfully submitted, UDREN LAW OFFICES, P.C. BY: Nathan W Alf, Esquire AtF&i;Tey for Plaint, Local C u el Alan M. Minato, Esquire PA ID 75860 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadingsQudren.com Deutsche Bank National Trust 'COURT OF COMMON PLEAS Company, as Trustee under the :CIVIL DIVISION Pooling and Servicing 'Cumberland County Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 --:NO. 10-2045 Plaintiff V. Guy W. Burford Keith M. Burford Defendant(s) CERTIFICATE OF SERVICE The undersigned certifies that true and correct copies of the attached Petition for Postponement of Sheriff's Sale was served upon the following person(s) named herein at their last known address or their attorney of record by: xxxx Regular First Class Mail Certified Mail Other Date Served: December 27, 2011 TO: Guy W. Burford Keith M. Burford 407 North Baltimore Street 407 North Baltimore Street Mount Holly Springs, PA 17007 Mount Holly Springs, PA 17007 UDREN LAW OFFICES, P.C. Nathan C. , Esquire ain -1f I Local Coun el Alan M. Minato, Esquire PA ID 75860 r? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Deutsche Bank National Trust Company, as Trustee under the Pooling and Servicing Agreement dated as of March 1, NO. 2006, GSRPM Mortgage Loan Trust 2006-1 _ Plaintiff V. Guy W. Burford Keith M. Burford Defendant(s) 10-2045 O R D E R r -Tj w irn v x ?t Wr- ? C5 ? U = ?? a _ A ?? c?'rn AND NOW, this fro day of December, 2011, after consideration of Plaintiff's Petition for Postponement of Sheriff's Sale of the mortgaged property located at 407 North Baltimore Street, a/k/a 407 North Baltimore Avenue, Mount Holly Springs, PA 17007, it is hereby ORDERED that the said Sale currently scheduled for January 4, 2012, is extended (2) two month(s) to the regularly scheduled Cumberland County Sheriff's Sale scheduled for March 7, 2012. No further advertising or additional notice to lienholders or Defendant(s) is required provided the postponement is announced at the January 4, 2012 Sheriff's Sale. BY THE COURT: -- a.- -Weal-ey el eT , 3: . J. TO:Guy W, Burford 407 North Baltimore Street Mount Holly Springs, PA 17007 Keith M. Burford 407 North Baltimore Street Mount Holly Springs, PA 17007 Udren Law Offices, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 Attn: Sale Department Office of the Sheriff if)'Jih Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ????ci„ ®9 ?ir.rabr?t2er ?i ?- "?1fJCu it 26 G CVJ''+8EF LA?,40 4lflA u ? PENNSYLVANIA Deutsche Bank National Trust Company Case Number S. 2010-2045 Guy W. Burford (et al.) SHERIFF'S RETURN OF SERVICE 10/11/2010 03:13 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on 10-11-10 at 1506 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 Guy W. & Keith M. Burford, located at, 407 North Baltimore Avenue, Mount Holly Springs, Cumberland County, Pennsylvania according to law. 10/11/2010 03:13 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on 10-11-10 at 1506 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 Guy W. Burfod, by posting upon the property of Guy W. Burford, located at, 407 North Baltimore Avenue, Mount Holly Springs, Cumberland County, Pennsylvania, pursuant to Court Order. 10/11/2010 03:13 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on 10-11-10 at 1506 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 Keith M. Burfod, by posting upon the property of Keith M. Burford, located at, 407 North Baltimore Avenue, Mount Holly Springs, Cumberland County, Pennsylvania, pursuant to Court Order. 12/01/2010 As directed by Mark J Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 1/5/2011 01/05/2011 As directed by Mark J Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 3/2/2011 03/01/2011 As directed by Mark J Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 5/4/2011 05/04/2011 As directed by Mark J Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 7/6/2011 07/06/2011 As directed by Mark J Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 10/5/2011 10/05/2011 As directed by Mark J Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 11 /2/2011 11/01/2011 As directed by Mark J Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 1/4/2012 01/01/2012 As directed by Mark J Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 3/7/2012 03/29/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania on March 07, 2012 at 10:00 AM. He sold the same for the sum of $1.00 to Attorney Udren, on behalf of the Deutsch Bank National Trust Company, as Trustee under the Pooling and Servicing Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 at 2001 Australian Avenue, Bay 1, Riviera Beach, Florida 33404. Deutsch Bank National Trust Company, as Trustee under the Pooling and Servicing Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1, being the buyer in this execution, paid to the Sheriff the sum of $1,193.51. 03/29/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law states that this writ is returned STAYED. ?Ci (;Uli(tty`;U'fi J'tt9i'Ilf. (LiE'O ;qf'.!1;,. W 0p 114. a SHERIFF COST: $1,193.51 March 29, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF (Ci CouNYSuite sheriff. Telt:c,c", .rc UDREN LAW OFFICES, P.C. ATTORNEY 70R ??'?ITNTIFF .s MARK J. UDREN, ESQUIRE - ID #04302 T STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINAT0, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 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 under the ;CIVIL DIVISION Pooling and Servicing ::Cumberland County Agreement dated as of March 1, 2006, GSRPM Mortgage Loan :MORTGAGE FORECLOSURE Trust 2006-1 Plaintiff V. Guy W. Burford :NO. 10-2045 Keith M. Burford Defendant (s) AFFIDAVIT PURSUANT TO RULE 3129.1 Deutsche Bank National Trust Company, as Trustee under the Pooling and Servicing Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 407 North Baltimore Street, a/k/a 407 North Baltimore Avenue, Mount Holly Springs, PA 17007 1. Name and address of Owner(s) or reputed Owner(s): Name Address Guy W. Burford 407 North Baltimore Street Mount Holly Springs, PA 17007 Keith M. Burford 407 North Baltimore Street Mount Holly Springs, PA 17007 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Providian National Bank 295 Main Street Tilton, NH 03276 4. Name and address of the of record: Name last recorded holder of every mortgage Deutsche Bank National Trust Company, as Trustee under the Pooling and Servicing Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 Address 4828 Loop Central Drive Houston, TX 77081 Wells Fargo Bank Minnesota, NA, S/B/M to Norwest Bank 505 South Main Street, Suite 6000 Minnesota, NA, as Trustee of Orange, CA 92868-4509 Salomon Brothers Mortgage Securities VII, Inc., Floating C/O: Frank Federman Rate Mortgage Pass-Through One Penn Center Plaza Certificates, Series 1999-AQ1 Suite 1400 Under Pooling and Servicing Philadelphia, PA 19103 Agreement Dated as of March 1, 1999 Without Recourse, Pennsylvania Housing Finance 21101 North Front Street Agency Harrisburg,-PA 17105-5530 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 and whose interest may be affected by the sale: Name Address Real Estate Tax Dept Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, PA 17013 13 North Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 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 Address Tenants/Occupants 407 North Baltimore Street, a/k/a 407 North Baltimore Avenue Mount Holly Springs, PA 17007 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. sec. 4904 relating to unsworn falsification to authorities. DATED: August 14, 2010 UDREN LA P.C. P BY: MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. i3DREN, 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 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 under the :CIVIL DIVISION Pooling and Servicing :Cumberland County Agreement dated as of March 1, 2006, GSRPM Mortgage Loan 'MORTGAGE FORECLOSURE Trust 2006-1 Plaintiff V. Guy W. Burford € NO. 10-2045 Keith M. Burford Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Guy W. Burford 407 North Baltimore Street Mount Holly Springs, PA 17007 Your house (real estate) at 407 North Baltimore Street, a/k/a 407 North Baltimore Avenue, Mount Holly Springs, PA 17007 is scheduled to be sold at the Sheriff's Sale on December 8, 2010, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse Square, PA, to enforce the court judgment of $72,820.63, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. 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. 3. 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 notice on page two on how to obtain an attorney.) YOU Y.AY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the, Sheriff's Sale is not stopped, your property will to sold to th_ highest bidder. You may find out the price bid by calli.:zg 8156-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you. may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after 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 distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 ALL THAT CtRTAIN LOT OF GROUND SITUATED IN THE BOROUGH OF MT. HOLLY SPRINGS, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: ON THE EAST BY BALTIMORE AVENUE; ON THE SOUTH BY PROPERTY NOW OR FORMERLY OF JAMES CLEPPER ESTATES ON THE WEST BY A 20 FOOT PUBLIC ALLEY; AND ON THE NORTH BY PROPERTY NOW OR FORMERLY OF REBECCA ELLIOTT. HAVING A FRONTAGE ON BALTIMORE AVENUE OF 50 FEET AND EXTENDING IN DEPTH 180 FEET, HAVING THEREON ERECTED A TWO STORY FRAME DWELLING HOUSE KNOWN AS 407 NORTH BALTIMORE AVENUE. UNDER AND SUBJECT TO ANY AND ALL COVENANTS, CONDITIONS, RESTRICTIONS, RIGHT-OF-WAY, OBJECTIONS, EASEMENTS, AGREEMENTS, ETC., AS THEY APPEAR OF RECORD. BEING KNOWN AS: 407 North Baltimore Street a/k/a 407 North Baltimore Avenue Mount Holly Springs, PA 17007 PROPERTY ID NO.: 23-32-2336-060 TITLE TO SAID PREMISES IS VESTED IN GUY W. BURFORD, SINGLE MAN, AND KEITH M. BURFORD, MARRIED MAN, AS JOINT TENANTS WITH THE RIGHT OD SURVIVORSHIP BY DEED FROM WILLIAM M. STARNER AND LINDA W. STARNER, HIS WIFE DATED 01/25/1999 RECORDED 02/01/1999 IN DEED BOOK 193 PAGE 623. UDREN L R 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 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust Company, as Trustee under the Pooling and Servicing Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 Plaintiff V. Guy W. Burford Keith M. Burford Defendant(s) ATTORNEY 7CR P.-aXINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 10-2045 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Keith M. Burford 407 North Baltimore Street Mount Holly Springs, PA 17007 Your house (real estate) at 407 North Baltimore Street, a/k/a 407 North Baltimore Avenue, Mount Holly Springs, PA 17007 is scheduled to be sold at the Sheriff's Sale on December 8, 2010, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse Square, PA, to enforce the court judgment of $72,820.63, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400. 2. 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. 3. 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 notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after 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 distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 ALL THAT CERTAIN LOT OF GROUND SITUATED IN THE BOROUGH OF MT. HOLLY SPRINGS, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: ON THE EAST BY BALTIMORE AVENUE; ON THE SOUTH BY PROPERTY NOW OR FORMERLY OF JAMES CLEPPER ESTATES ON THE WEST BY A 20 FOOT PUBLIC ALLEY; AND ON THE NORTH BY PROPERTY NOW OR FORMERLY OF REBECCA ELLIOTT. HAVING A FRONTAGE ON BALTIMORE AVENUE OF 50 FEET AND EXTENDING IN DEPTH 180 FEET, HAVING THEREON ERECTED A TWO STORY FRAME DWELLING HOUSE KNOWN AS 407 NORTH BALTIMORE AVENUE. UNDER AND SUBJECT TO ANY AND ALL COVENANTS, CONDITIONS, RESTRICTIONS, RIGHT-OF-WAY, OBJECTIONS, EASEMENTS, AGREEMENTS, ETC., AS THEY APPEAR OF RECORD. BEING KNOWN AS: 407 North Baltimore Street a/k/a 407 North Baltimore Avenue Mount Holly Springs, PA 17007 PROPERTY ID NO.: 23-32-2336-060 TITLE TO SAID PREMISES IS VESTED IN GUY W. BURFORD, SINGLE MAN, AND KEITH M. BURFORD, MARRIED MAN, AS JOINT TENANTS WITH THE RIGHT OD SURVIVORSHIP BY DEED FROM WILLIAM M. STARNER AND LINDA W. STARNER, HIS WIFE DATED 01/25/1999 RECORDED 02/01/1999 IN DEED BOOK 193 PAGE 623. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO10-2045 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 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF MARCH 1, 2006, GSRPM MORTGAGE LOAN TRUST 2006-1 Plaintiff (s) From GUY W. BURFORD AND KEITH M. BURFORD (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$72,820.63 L.L. S. Sa Interest FROM 08/15/2010 TO DATE OF SALE DECEMBER 8, 2010 - ONGOING PER DIEM OF $15.78 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $1,830.48 Atty's Comm % Atty Paid $,-310 Plaintiff Paid Date: AUGUST 16, 2010 i r (Seal) Due Prothy $2.00 Other Costs (' ?) l D ell, Prothonotary By: Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C., WOODCREST CORPORATE CENTER, 111 WOODCREST ROAD, SUITE 200, CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 T T*WMW RUE Co" FROM RECORD ?Kndq? hw WAD so my hand T1Ms Fa'cz ? ? tart' On September 22, 20 10 the Sheriff levied upon the defendant's interest in the real property situated in Mount Holly Springs Borough, Cumberland County, PA, Known and numbered as, 407 North Baltimore Street a/k/a 407 North Baltimore Avenue, Mount Holly Springs, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 22, 2010 _ By: / a Real Estate Coordinator 161 "1 10 The Patriot-News Co. 2020 Teohnology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE Z4 t Patriot News Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY ar, 2010 A. D. This ad ran on the date(s) shown below: Notary Public COMMONWEALTH OF PENNSYLVANIA Nato W Sal Shenie L Kisnar, Notary Public Lower Paxton TWP., Dauphin County My CommWOn Expires Nov. 26, 2011 Member, !'ennsvlvania Association of Notaries 10/15/10 10/22/10 10/29/10 2010-2045 Civil Term Deutsche Bank National an. u der pooling a as 7Fustee Agreement dat and Servicing 1, 2006 GS ed as Of March u 2? gage Loan Guy W. Burford Keith M, Burford AttYc Mark J Udren LL ETHADT CE TAIN LOT OF GROUND SIT HOLLY THE BOROUGH OF COUNTY PENNSIYNI CUMBERLAND ANIA, BOUNDED AND DESCRIBED AS FOLLOWS. ON THE EAS T BY BALTIMORE A ON THE SOUTH By PROPER ENUE; S FORMERLY OF JAMES CLEP ?R PUBLIC ESTATES ALLEY' THE WEST By A 20 FOOT EY; AND ON NORTH BY PROPERTY NOW THE OF REBLOCCA OR FORMERLY FRO L TT HAVING A NTAGE ON B OF50 M17MORE AVENUE 180 FEET HAVINGXTENDINGINDEPT'H A TWO STORY THEREONERECTED HOUSE FRAME DWELLING KNOWN BALTIMORE AVENUE 407 NORTH UNDER ALL AND SUBJECT TO ANY AND COVENANTS, CONDITIONS, RESTRICTIONS, WAY' OBJECTIONS RIGHT-OF- AGREEMENTS EASEMENTS OFRECORD. ETC 'ASTHEYAPPEAR? B Street EING KNOWN AS. 407 N Wk/a 407North orth Baltimore MountHo11Y. Baltimore Avenue PROP Springs, PA 17007 ERTY ID NO.. 23-32-2336-060 TT FLE TO SAID PREMISES GUY WMB B pRBORD, SINGLE ? IS MAN, VESTED IN KEITH AND AS JOINT TEN MARRIED MAN OD SURVIVORSHIP WITH D FRIGH ROM WILLIAM M. HISWIEETRNER AND LINDA W. "ORDED DATED 0] 25/1999 623. 02/0]/1999 GE IN DEED BOOK eh a Patriot-Xtws Now you know 2020 Technology Pkwy., Suite 300 MECHANICSBURG, PA 17050 (717) 255-8462 BILL TO: Cumberland County Sheriffs Office Cumberland County Court House Carlisle, PA 17013 ACCT. # 2260 DUPLICATE BILL Date Description Sale # Size Rate Net Cost Of Ad 10/15/10 10/22/10 10/29/10 Sheriff Sale 2045 7.08 $12.00 $ 84.96 Sheriff Sale 2045 7.08 $12.00 $ 84.96 Sheriff Sale 2045 7.08 $12.00 $ 84.96 Notary Fee I I I I I 1 1 $5.00 TOTAL DUE FOR THIS SALE: $ 259.88 JLC 1 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA . ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 22, October 29, and November 5, 2010 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Lisa Marie Co yade, Editor SWORN TO AND SUBSCRIBED before me this da of November 2010 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 CUMBERLAND LAW JOURNAL Writ No. 2010-2045 Civil Deutsche Bank National Trust Company, as Trustee under Pooling and Servicing Agreement dated as of March 1, 2006 GSRPM Mortgage Loan Trust 2006-1 vs. Guy W. Burford Keith M. Burford Atty.: Mark J. Udren ALL THAT CERTAIN lot of ground situated in the borough of Mt. Holly Springs, Cumberland County, Penn- sylvania, bounded and described as follows: ON THE EAST by Baltimore Av- enue; on the south by property now or formerly of James Clepper Estates on the west by a 20 foot public alley; and on the north by property now or formerly of Rebecca Elliott. having a frontage on Baltimore Avenue of 50 feet and extending in depth 180 feet, having thereon erected a two story frame dwelling house known as 407 North Baltimore Avenue. UNDER AND SUBJECT to any and all covenants, conditions, re- strictions, right-of-way, objections, easements, agreements, etc., as they appear of record. BEING KNOWN AS: 407 North Baltimore Street a/k/a 407 North Baltimore Avenue, Mount Holly Springs, PA 17007 PROPERTY ID NO.: 23-32-2336- 060. TITLE TO SAID PREMISES IS VESTED IN Guy W. Burford, single man, and Keith M. Burford, mar- ried man, as joint tenants with the right od survivorship by deed from William M. Starner and Linda W. Starner, his wife dated 01/25/1999 recorded 02/01/1999 in Deed Book 193 Page 623. 17 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Deutsch Bank National Trust Co as Trustee for GSRPM Mortgage Loan Trust 2006-1 is the grantee the same having been sold to said grantee on the 7 day of March A.D., 2012, under and by virtue of a writ Execution issued on the 16 day of August, A.D., 2010, out of the Court of Common Pleas of said County as of Civil Term, 2010 Number 2045, at the suit of Deutsche Bank National Trust Co as Trustee for GSRPM Mortgage Loan Trust 2006-1. against Guy W. Burford and Keith M. Burford is duly recorded as Instrument Number 201211998. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this C;,5 day of 2,?? -, A.D. 6\0 (a, -?; ct" & Recorder of Deeds % "ft of Deeds, Q nberW Cmxdy, C ffW PA Wy Qxrrnission Exgres the FrA Monday of Jan. 2014