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HomeMy WebLinkAbout10-2608UDREN 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 LOUIS A. SIMONI, ESQUIRE - ID #200869 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 pleadings@udren.com ATTORNEY FOR PLAINTIFF 0 C s._ t J n ' ' irk. C. r:> Deutsche Bank National Trust :COURT OF COMMON PLEAS Company, as Trustee of the ::CIVIL DIVISION Home Equity Mortgage Loan Asset-Backed Trust Series ;Cumberland County INABS 2006-E, Home Equity Mortgage Loan Asset-Backed Certificates, Series INABS 2006-E under the Pooling and Servicing agreement. dated Dec 1, 2006 888 E. Walnut Street Pasadena, CA 91101 Plaintiff V. Robert J. Jones Sharon L. Jones NO. lO -?1.Og L 30 Wagner Drive Carlisle, PA 17013 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 ?Q.Z.00 t?cL?? eK.? ?y4ssy ?? R Yd 8 7-2, other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 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 IMMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 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 r 1. Plaintiff is the Corporation designated as such in the caption on a preceding page, who is the legal holder of the Mortgage and is in the process of formalizing the Assignment of Mortgage to be sent 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: 30 Wagner Drive MUNICIPALITY/TOWNSHIP/BOROUGH: Middlesex Township COUNTY: Cumberland DATE EXECUTED: 11/2/06 DATE RECORDED: 11/15/06 BOOK: 1972 PAGE: 4777 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 4/19/10: Principal of debt due $147,759.40 Unpaid Interest at 7.8750 from 2/1/09 to 4/19/10 (the per diem interest accruing on this debt is $31.88 and that sum should be added each day after 4/19/10) 16,611.91 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $0 and that sum should be added on the first of each month after 4/19/10) 6,163.88 Late Charges (monthly late charge of $51.18 should be added in accordance with the terms of the note each month after 4/19/10) 698.28 Suspense Balance (1,724.96) Recoverable Balance 2,195.50 Attorneys Fees (anticipated and actual to 5t of principal) 7,387.97 TOTAL $179,696.98 *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 $179,696.98 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. UDREN LAW OFFICES P.C. By Dn W, Attorneys for Plaintiff 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, ESQUIRE J " -, EXHIBIT A - LEM DESCRIPRON ALL. THAT CERTAIN tract of land situate in Middlesex Township, Cumberland County, Pennsylvania, bounded and described in accordance with a draft or survey made by Noel B. Smith, Registered Surveyor, dated October 1964, as follows: BEGINNING at an iron pin near the northern right-of-way of the public road leading from State Highway Route No. 34 known as Spring Road to Wertz's School House which road is now known as Wagner Drive at corner of land formerly of Leon K. Wagner and now or formerly of William Peiper; thence from said iron pin at the Place of Beginning along line of said land now or formerly of William Peiper, south 07 degrees 48 minutes east a distance of 245.00 feet to an iron pin at corner of land now or formerly of Jacque D. Hurley and wife described in Deed Book "C", Volume 24, Page 835, thence along line of said land now or formerly of Jacque D. Hurley and wife, south 86 degrees 51 minutes west a distance of 167.50 feet to a point at the southeastern comer of land now or formerly of Richard Lee Kimmel and wife described in Deed Book "S", Volume 16, Page 260, known as 34 Wagner Drive; thence along line of said land now or formerly of Richard Lee Kimmel, north 04 degrees 42 minutes west a distance of 236.80 feet to a railroad spike in the centerline of said public road leading to Wertz's School House now known as Wagner Drive; thence along the centerline of said Wagner Drive and continuing through the northern portion of said Wagner Drive, north 84 degrees 11 minutes 30 seconds east a distance of 153.13 feet to an iron pin at the Place of BEGINNING. The above-described tract of land contains approximately 0.80 acres, more or less, exclusive of the described right-of-way of Wagner Drive, and has thereon erected a two=story dwelling house and other improvements. For Informational Purposes Only: The improvements thereon being known as 30 Wagner Drive, Carlisle, Pennsylvania 17013. BEING all and the same lot of ground which by Deed dated September 6, 2001, and recorded among the Land Records of Cumberland County, Pennsylvania in Liber No. 254, folio 1014, was granted and conveyed by Robert J. Jones, onto Robert J. Jones and Sharon L. Jones. Parcel No.: 21-13-0968414. BK 1972PG4796 IndyMac Mortgage Services PRESORT a Division of One West Bank Frst-Class Mail PO Box 9042 U.S. Postage and Temecula, CA 92589-9042 Fees Paid WSO Send Payments To: 7113 8257 1473 9973 0669 IndyMac Mortgage Services a Division of One West Bank PO Box 4045 Kalamazoo, MI 49003-4045 Send Correspondence To: lndyMac Mortgage Services a Division of One West Bank PO Box 4045 SHARON L JONES Kalamazoo, MI 49003-4045 30 WAGNER DR CARLISLE, PA 17013 20100217-72 XC718 t ? EXHIBIT N 1f59-v34 Home Loan Servicing 6900 Beartice Drive Kalamazoo, MI 49009 February 17, 2010 SHARON L JONES 30 WAGNER DR CARLISLE, PA 17013 RE: Loan Number 100876062.9 Legal Description of Property: 30 WAGNER DR CARLISLE, PA 17013 ACT 91 NOTICE Sent Via Certified Mail 7113 8257 1473 9973 0669 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) MAY BE ABLE TO HELP TO SAVE YOUR HOME. This Notice exolains how the program works. To see if HEMAP can help, you must MEET WITH CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies servicing your county are listed at the end of this Notice. If you have py questions, oY u may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call 1-717-780-1869). 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 attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIF'ICACION EN ADJUNTO ES DE SUMA IMPORTANCLA, DUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDIDO DE ESTA NOTIFICACION 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 PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. !-M- 7113 8257 1473 9973 0669 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"), 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 property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to-face meeting with the counseling agency. YOUSHOULD FILEA HEMAPAPPLICATION ASSOONASPOSSMLE. IF YOUHAVEA MEE77NG WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SEC77ON CALLED -TEMPORARY STAY OF FORECLOSURE': YOU HA VE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICA77ON IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN A BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it uv to date)NATURE OF THE DEFAULT - The MORTGAGE debt held by IndyMac Mortgage Services, a Division of OneWest Bank on your property located at the above referenced address is in SERIOUS DEFAULT, because you have not made the monthly payments that follow: Next Payment Due Date: 03/01/2009 Current Monthly Payment: $1,246.43 Total Monthly Payments Due: $14,511.66 Late Charges: $595.92 Other Charges: Uncollected NSF Fees: $0.00 Other Fees: $55.00 Corporate Advance Balance: $1,445.50 Partial Payment Balance: 41,724.96 TOTAL YOU MUST PAY TO CURE DEFAULT: $14,883.12 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 $14,883.12, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check certified check or money order made payable and sent to: IndyMac Mortgage Services, a Division of OneWest Bank P.O. Box 78826 Phoenix, AZ 85062-88026 IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) Days, the lender also intends to instruct its attorneys to start legal action to foreclosure upon your mortsaeed property. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender 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 attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the 1 default within the THIRTY (30) DAY period you will not be reauired to pay attorney's fees 7113 6257 1473 9973 0669 OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY(30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale You may do so by paving the total amount then past due. plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortggage Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: IndyMac Mortgage Services, a Division of OneWest Bank 2900 Esperanza Crossing Austin, Texas 78758 Loan Resolution Department 1(877) 9084357 EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it, If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may be eligible to sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. You will need to obtain expressed approval of the lender prior to any sale or transfer or assumption of the mortgage debt YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED. IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. 0 TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. You may also contact a HUD-approved housing counseling agency toll-free at 1 (800) 569-4287 or TDD 1 (800) 877-8339 for the housing counseling agency nearest you. These services are usually free of charge. CONSUMER CREDIT COUNSELING AGENCIES SERVICING YOUR COUNTY CAN BE LOCATED ON THE ATTACHED LIST OF COUNSELING AGENCIES LOCATED IN THE STATE OF PENNSYVAN A This company is a debt collector. We are attempting to collect a debt and any information obtained will be used for that purpose. However, if your debt has been discharged pursuant to the Bankruptcy laws of the United States, this communication is intended solely for informational purpose. Sincerely, IndyMac Mortgage Services, a Division of OneWest Bank Loan Resolution Please 1) Make your check payable to IndyMac Mortgage Services, a Division of OneWest Bank 2) Do not staple your payment to your billing statement 3) Write your loan number on your check or money order 4) Do no include correspondence 5) Do not send Cash 6) Mail your payments to: IndyMac Mortgage Services, a Division of OneWest Bank P.O. Box 78826 Phoenix, AZ 85062-88026 a CONSUMER CREDIT COUNSELING AGENCIES SERVING CUMBERLAND COUNTY a z Adams County Interfaith CCCS of Westem PA Community Action Loveship, Inc. Housing Authority 2000 Linglestown Road Commission 2320 North 5th Street 40 E High Street Harrisburg, PA 17102 of Capital Region Harrisburg, PA 17110 Gettysburg , PA 17325 888.511.2227 1514 Derry Street 717.232.2207 717.334.1518 Harrisburg, PA 17104 717.232.9757 Maranatha PHFA 43 Philadelphia Avenue 211 North Fran Street Waynesboro, PA 17268 Harrisburg, PA 17110 717.762.3285 717.780.3940 800.342.2397 7113 8257 1473 9973 0669 IndyMac Mortgage Services a Division of One West Bank PO Box 9042 Temecula, CA 92589042 Send Payments To: IndyMac Mortgage Services a Division of One West Bank PO Box 4045 Kalamazoo, Ml 49003-4045 Send Correspondence To: IndyMac Mortgage Services a Division of One West Bank PO Box 4045 Kalamazoo, MI 490034045 L 7113 ,._, 1473 9973 0e90 ROBERT J JONES 30 WAGNER DR CARLISLE, PA 17013 PRESORT First-Class Mail U.S. Postage and Fees Paid WSO 20100217-72 XC718 1159-v34 1 } Home Loan Servicing 6900 Bearlice Drive Kalamazoo, MI 49009 February 17, 2010 ROBERT J JONES 30 WAGNER DR CARLISLE, PA 17013 RE: Loan Number 1008760629 Legal Description of Property 30 WAGNER DR CARLISLE, PA 17013 ACT 91 NOTICE Sent Via Certified Mail 7113 8257 1473 9973 0690 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) MAY BE ABLE TO HELP TO SAVE YOUR HOME. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies servicingyour county are li sted at the end of this Notice. If you have anyquestions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call 1-717-780-1869) 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 attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, DUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDIDO DE ESTA NOTIFICACION 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 PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. 7113 8257 1473 9973 0690 .? f 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"), 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 property is located are set forth at the end of this Notice It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEBLIP APPLICATION AS SOONAS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE". YOU HA VE THE RIGHT TO FILE A HEMAP APPLICATIONEVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE AC77ON, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. 9 .% 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 A BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT Bring it uu to datel NATURE OF THE DEFAULT - The MORTGAGE debt held by IndyMac Mortgage Services, a Division of OneWest Bank on your property located at the above referenced address is in SERIOUS DEFAULT, because you have not made the monthly payments that follow: Next Payment Due Date: 03/01/2009 Current Monthly Payment: $1,246.43 Total Monthly Payments Due: $14,511.66 Late Charges: $595.92 Other Charges: Uncollected NSF Fees: $0.00 Other Fees: $55.00 Corporate Advance Balance: $1,445.50 Partial Payment Balance: -$1.724.96 TOTAL YOU MUST PAY TO CURE DEFAULT: $14,883.12 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 $14,883.12, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check certified check or money order made payable and sent to: IndyMac Mortgage Services, a Division of OneWest Bank P.O. Box 78826 Phoenix, AZ 85062-88026 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 mortggge debt This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) Days, the lender also intends to instruct its attorneys to start legal action to foreclosure upon your mortgaged Property. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender 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 attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY Period, you will not be required to pay attorney's fees 7113 8257 1473 9973 0690 4 } OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY(30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale You may do so by paving 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 any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: IndyMac Mortgage Services, a Division of OneWest Bank 2900 Esperanza Crossing Austin, Texas 78758 Loan Resolution Department 1(877) 9084357 EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may be eligible to sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. You will need to obtain expressed approval of the lender prior to any sale or transfer or assumption of the mortgage debt YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED. IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. 9 TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. • . - f 02'? You may also contact a HUD-approved housing counseling agency toll-free at 1 (800) 569-4287 or TDD 1 (800) 877-8339 for the housing counseling agency nearest you. These services are usually free of charge. CONSUMER CREDIT COUNSELING AGENCIES SERVICING YOUR COUNTY CAN BE LOCATED ON THE ATTACHED LIST OF COUNSELING AGENCIES LOCATED IN THE STATE OF PENNSYVANL4 This company is a debt collector. We are attempting to collect a debt and any information obtained will be used for that purpose. However, if your debt has been discharged pursuant to the Bankruptcy laws of the United States, this communication is intended solely for informational purpose. Sincerely, IndyMac Mortgage Services, a Division of OneWest Bank Loan Resolution Please 1) Make your check payable to IndyMac Mortgage Services, a Division of OneWest Bank 2) Do not staple your payment to your billing statement 3) Write your loan number on your check or money order 4) Do no include correspondence 5) Do not send Cash 6) Mail your payments to: IndyMac Mortgage Services, a Division of OneWest Bank P.O. Box 78826 Phoenix, AZ 85062-88026 CONSUMER CREDIT COUNSELING AGENCIES SERVING a CUMBERLAND COUNTY a Adams County Interfaith CCCS of Western PA Commuryty Action Loveship, Inc. Housing Authority 2000 Unglestown Road Commission 2320 North 5th Street 40 E High Street Harrisburg, PA 17102 of Capital Region Harrisburg, PA 17110 Gettysburg , PA 17325 888.511.2227 1514 Derry Street 717.232.2207 717.334.1518 Harrisburg, PA 17104 717.232.9757 Maranatha PH FA 43 Philadelphia Avenue 211 North Front Street Waynesboro, PA 17268 Harrisburg, PA 17110 717.762.3285 717.780.3940 800.342.2397 7113 8257 1473 9973 0690 I 0 . % V E R I F I C A T I O N The undersigned, hereby states that he/she is the attorney for the Plaintiff, a corporation unless designated otherwise; that he/she is authorized to make this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he/she has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his/her knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. BY k,4 LM L& VW ( V(' Attorneys or Plaintiff 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, ESQUIRE SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy ~~,~„t~ of ~sr,r~6Arl,~~,~~ ~~ ~ ~ ~~ 201 Q MA1f I ~ AM 8..48 Edward L Schorpp Solicitor >r ti~~'~ w~~ PE~NNSYLVI~ Deutsche Bank National Trust Company vs. Robert J. Jones (et al.) Case Number 2010-2608 SHERIFF'S RETURN OF SERVICE 05/10/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Sharon L. Jones, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Sharon L. Jones. Request for service at 30 Wagner Drive, Carlisle, PA 17013 is vacant. The Carlisle Postmaster has advised the defendant's new address is 7865 W. Highway 40 Lot 150, Ocala, FL 34482. 05/10/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Robert L. Jones, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Robert L. Jones. Request for service at 30 Wagner Drive, Carlisle, PA 17013 is vacant. The Carlisle Postmaster has advised the defendant's new address is 7865 W. Highway 40 Lot 150, Ocala, FL 34482. SHERIFF COST: $59.40 May 10, 2010 SO ANSWERS, l "" RON R ANDERSON, SHERIFF c; Geu!ib;Sudc S..enff. 7e2.ns:ifi. Inc. ~TDREN 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 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust :COURT OF COMMON PLEAS Company, as Trustee of the Home € CIVIL DIVISION Equity Mortgage Loan Asset-Backed :Cumberland County Trust Series INABS 2006-E, Home Equity Mortgage Loan Asset-Backed :MORTGAGE FORECLOSURE Certificates, Series INABS 2006-E under the Pooling and Servicing agreement dated Dec 1, 2006 888 E. Walnut Street Pasadena, CA 91101 Plaintiff v. Robert J. Jones €NO. 10-2608 Sharon L. Jones 30 Wagner Drive Carlisle, PA 17013 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: C3 v ~ C_°~ v ~ =n >- moo. ~ ~; tis rte: - -- ` ~ ' _ vim; ; i; -., - _ - =~ .. ~~~ t!~ Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) Robert J. Jones and Sharon L. Jones 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 $179,696.98 Interest Per Complaint 1,817.16 From 04/20/2010 to 06/15/2010 Late charges per Complaint 102.36 From 04/20/2010 to 06/15/2010 TOTAL X181,616.50 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 OF P.C. BY: Attorneys r Plaintiff EN, ESQUIRE STUART WINNE IRE ~!'F•00 PO AT'r't LORRAINE DOYLE, ESQUIRE C*155(,5~ ALAN M. MINATO, ESQUIRE ~,~o~~(va CHANDRA M. ARKEMA, ESQUIRE DAMAGES ARE HEREBY ASSESSED AS INDI D i~lo~kee I~u.(.~c0 DATE : ? dto l0 ~ THY 1 UDREN LAW OFFICES, P.C. MARK J. tTDREN, ESQIIIRE - ID #04302 STIIART WINNEG, ESQIIIRE - ID #45362 LORRAINE DOYLE, ESQIIIRE - ID #34576 ALAN M. MINATO, ESQIIIRE - ID #75860 CHANDRA M. ARREMA, ESQIIIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SIIITE 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 of the :CIVIL DIVISION Home Equity Mortgage Loan :Cumberland County Asset-Backed Trust Series INABS 2006-E, Home Equity :MORTGAGE FORECLOSURE Mortgage Loan Asset-Backed Certificates, Series INABS 2006-E under the Pooling and =NO. 10-2608 Servicing agreement dated Dec 1, 2006 Plaintiff v. Robert J. Jones Sharon L. Jones Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NEW JERSEY COUNTY OF CAMDEN 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 Servicemembers' Civil Relief Act (108 P.L. 189; 117 Stat. 2835; 2003 Enacted H.R. 100), and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Defendant: Age. Residence: Employment: Sharon L. Jones Over 18 As captioned above Unknown Robert J. Jones Over 18 As captioned aka Unknown Sworn to and- subscribed before me-this-?4TH day June, 2..010. No Got~~3 Title: Company: FOR PLAINTIFF OFFICES, P.C. UDRBN LAW OFFICES, P.C. MARK J. UDRBN, BSQUIRB - ID #A4302 STIIART WINNBG, BSQUIRB - ID #45362 LORRAINE DOYLB, 83QUIR8 - ID #34576 ALAN M. MINATO, BSQUIRB - ID #75860 CHANDRA M. ARKBMA, BSQUIRB - ID #203437 LOUIS A. SIMONI, BSQUIRB - ID #200869 ADAM L. RAYBS, BSQIIIRE - ID #86408 MARGUERITE L. THOMAS, BSQUIRB - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST RQAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsC~udren.aom Deutsche Bank National Trust :COURT Company, as Trustee of the CIVIL Home Equity Mortgage Loan FfLEf~-t~-e~l~'E. ATTORNEY FC~{li.~~~~i~~~•CAF?Y ZQlD APR ~ ! P~f r~: p ~ 4iV'M7Dif"{4:~tz-7t.+ 1,,,;',~3,,,iN~y' ~Ehd~l~l`L1~r~iA OF COMMON PLEAS DIVISION Asset-Backed Trust Series :Cumberland County INABS 2006-E, Home Equity Mortgage Loan Asset-Backed Certificates, Series INABS 2006-E under the Pooling and Servicing agreement dated Dec 1, 200& 888 E. Walnut Street Pasadena, CA 91101 Plaintiff v. Robert J. Jones Sharon L. Jones 30 Wagner Drive Carlisle, PA 17013 , Defendant(s) NO. ID '- ~I.Og ~lG ~ ~~ L 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 ~ ~ ~ ~ ~i~l ~~~. ~ ~~ Qauisehc ~aak itiatianal Trust:Co~npan~~, "srs "f'xtis€ee~; ".e~, a€.,. 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'€{!-~~fl8'~rv~f ~'erir~. ~ts.~e of server.: ~~~~,--!~'~" .~_....,~i~~ ~'~,~'~:~ ,.,~nciersi~tec~, .bain~ du!}~ s~~orn, aeprsses siLt~ sa~~: #~tlt~ ~ `~%e 'tip. if service, sl~ie ~•es ~if~ E~~'a:[ ~~ge~ aist~ uses. r~ of a parCy:: to f~is aet~rsn; Tla#eF'i'ii~e. t~€ ~~rvut: t~aaY ari the ~ia~ of ~: :.2t} 1.;.., .st .~o'~Io~k. „IS+I F'la~e.o€Serv#ce: ar 'ISfi~ t'~',.•H~Iisra ..-~t#,#I5~ _...~....u.»-__...~._ ._ - iri €~~tst#A. ~L,...34~8Z'.,_..._.____.._....__.._...._...____ Dacuraegts ~e_rvetl:: t3ie untier~i~rYe~i serue~i the dd~iirnettts descried ~; ~nt~plaprt.i~ iV~.~rtgtxgsr~ar~c2osu'rr ~ervie~e o€Process can: A ts~te anri. et~rreci..~c~py cif fhe afazesei~i. ?~QC~iiri.ettE{s~ ~:•$s served on': ~h~.rc~n 1~,.~nues Persati ~erveB; a~nlf .........-~".`~ _.. .,.~.... _____~.._._.....____.__..___._..._ t~iethcid..oi'Sr~iee; B~rgersc~nat~~, iiei:i~eriei~t#xeln in#a ttie lsantls ~rf ~e perso~I t~ be serveet: I)=i~~ delil~er#it~ t'!n into the h.~ds caf , a p~rsc~r~ o~'suittt#le.a~a.,'~vh~ versed,-.4r ~rha u~c~n.q~sesi:iatzin~ ~.#erl:. fh.a'-~.el~l~~ r~sicles ~:~i.tit 53rarr~n .i:,. ~Tanes at tie peace gi service, az~d ~hase.rela~iatRSixtp to ~e perso~7 is: D.ri~t~iot~ ufP.ersi~n 23ie'~rcan recei~~~.dacunset~.5 is describetil .as.~iii3or~:s: ~'.V:4 ~}O~A3tt~tFFS: ~Pr'~'. ~ . .Stciri;:Crt3~r. ... _; Hail ~~1cir ~r~.r~r!~. Fn~al Hair !t1 ~. Apprcaa..,-~L~e :~'- Apprc~x, ~ei~i1': ~_ ~: a A~~re~x: 'W:ei i ~:~a: T~ t}3e:fi~e~st ofrn;~ ~©~~~ezige and. l;:st~ie~',.sai'~i peI•son ~vss Itot ended. ir,.the ~I~-fvl~i.lita;y a# #.i}e.~iir~e raf service„. ~~~n~txere a€~erver: tinders:~Zraed. deci4u:es ul~der Fenaity at {aerFurtr Subsc.rii~ezi atit~:s~rtl~x. tck bef~are rme.~tts #hattfie~ore~,~in~,~~e.ancf.co~rrect ,`~-~, zier~c~#' ,~, '~` ?p ~~`' 5ierraturec~f5~a-~~er -- ____._ ...__.~~..._ --. ~`.o YZ:biic fLr_~~~,~~3~T_-~3vtKj .~ ~t~r~~~inr~i,: Lte. ~.~ .a:,y~?~ _ - carsr T.eaTrv{i+anir~r . ~l~:•. SHERIFF`S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith ~°'~~~ al; ~~~~'~'~~ Chief Deputy : ~ ~:,~~ .`:,-~?` Edward L Schorpp ~~ ~~~~~-:~~-~ Solicitor ar~e~ c+r ~ Sk£t2iRF Deutsche Bank National Trust Company vs. Case Number Robert J. Janes (et al.} 2010-2608 SHERIFF'S RETURN OF SERVICE 05/10/2010 Ronny R. Anderson, Sherif€, who being duty sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Sharon L. Jones, but was unable to locate her in his bailiwick.. He therefore returns the within Compiaint in Mortgage Foreclosure as not found as to the defendant Sharon L. Jones. Request for service at 30 Wagner Drive, Carlisle, PA 17013 is vacant. The Carlisle Postmaster has advised the defendant's new address is 7865 W. Highway 40 Lot 150, Ocala, FL 34482. 05/10/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Robert L. Jones, but was unable to locate him in his bailiwick. He #herefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Robert L. Jones, Reques# for service at 30 Wagner Drive, Carlisle, PA 17013 is vacant, The Carlisle Postmaster has advised the defendant's new address is 7865 W. Highway 40 Lot 150, Ocala, FL 34482. SHERIFF COST: $59.40 May 10, 2010 SO ANSWERS, C~~~ RON R ANDERSON, SHERIFF IIDREN LAiP OFFICgs, P.c. 1iAR1C J. IIDRBN, E$QIIIRE - ID #04302 STIIART WZNNBG, ESQIIIRg - ID #45362 LO~'sa'~ DO~YLE, $SQtTIRB - ID #34576 ALAN ad. MINPiTO, S3QVIRE - ID #75860 CHANDRA M. AR~CSl61-, 88QIIIRE - ID #203437 LOUIS A. SII®DNI, ESQIIIRB - ID #200869 ADAM L. RAYES, 38QIIIRE - ID #86408 ~6ARGIIERITg L. T80lSAS, ESQIIIRL - ID #204460 1iOODCR83T CORPORATE CS~QTBR 111 NOODCREB'P ROAD, SIIITE 200 CHERRY HILL, NJ 08003 856-669-5400 ATTORNEY FOR PLAINTIFF Deutsche Bank National Trust Company as B COURT OF COMMON PLEAS Trustee of the Home Equity Mortgage f,oan ~ CIVIL DIVISION Asset-Backed Trust Series INABS 2006-E, ;Cumberland County Home Equity Mortgage Loan Asset-Backed Certificates Series INABS 2006-E under the Pooling and servicing agreement dated Dec 1, 200b Plaintiff v. Robert J. Jones Sharon L. 3ones Defendant(s) TO: Sharon L. Jones 7865 W. Highway 40, #150 Ocala, FL 34482 Date of Notice: June 2, 2010 IMPORTANT NOTICE YOU ARE IN PERSONALLY FROM THE DATE HEARING AND Y TARE THIS PAP TELEPHONE THE INFORMATION A OFFICE MAY BE OFFER LEGAL S LISTED SE ENCUENTRA UIRIDA DE SU PA TE INO DE DIEZ (1 NECESIDAD DE COMPA SENTFNCIA EN SU CO] IMPORTANTE5. DEBE LISTED NO TIENE ABO~ EN PERSONA O LLAME ESCRITA ABAJO PARR E YOU HAVE FAILED ' AND FILE IN WRITI SET FORTH AGAINST ICE A JUDGMENT MA YOU~i. PROPERTY OR O AWYER AT ONCE. IF FORTH BELOW. THIS A LAWYER. IF YOU VIDE YOU WITH INFO LIGIBLE PERSONS AT LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 . NOTIFICACION ImPORTANTB STADO DE REBELDIA POR NO HABER TO! N ESTE CASO. AL NO TOMAR LA ACCIf AS DE ESTA NOTIFICACION EL TRIBU] ER LISTED EN CORTE O ESCfJCHAR PREU] LISTED PUEDE PERDER BIENES Y OTRO; AR ESTA NOTIFICACION A UN ABOGADO O SI NO TIENE DINERO SUFICIENTE ] TELEFONO,A LA OFICINA CUYA DIRECT TGUAR DONDE SE PUEDE CONSEGUIR AS. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 WRITTEN APPEARP+NCE COURT YOUR DEFENSES OR S YOU ACT WITHIN TEN DAYS D AGAINST YOU WITHOUT A 'ANT RIGHTS.YOU SHOULD ' HAVE A LAWYER GO TO OR ~RDRTO HIRE A WLP,W~YER .THIS ~UT_AGENCIE$ _THAT MA~' ISINNRO DE UN DICTAR VAYA N'OTICg: PIIR84ANT TO THE FAIR DEBT COLLECTION PRACTIC88 ACT, THIS LAN FIRM IS D88M$D TO 8E A DFST COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED 1Q'ILL BE IISSD FO E. .. L TYSv UIRE CHANDRA Ni . ARKENEA, Q LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE Woodcrest Corporate Center 111 Woodcrest road, Suite 200 Cherry Hill, New Jersey 08003-3620 NO. 10-2608 ~ .. r ATTORNEY FOR PLAINTIFF Deutsche Bank National Trust ':COURT OF COMMON PLEAS Company, as Trustee of the =CIVIL DIVISION Home .Equity Mortgage Loan :Cumberland County Asset-Backed Trust Series INABS 2006-E, Home Equity ,.,,, Mortgage Loan Asset-Backed ENO. 10-2608 ~ _~; Certificates, Series INABS K' `_ --~ 2006-E under the Pooling and ~~~!_ e:=.~ -;;~? Servicing agreement dated Dec `= - r , _~~?,~ 1, 2006 ``~ , ~ ,_ ' Plaintiff ~- --~ v • ~, r -~ Robert J. Jones L:~ Sharon L. Jones 4. Defendant(s) 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. ARREMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com 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: July 13, 2010 UD~REN L W OFFICES, P.C. BY: Attorneys for Plaintiff if-~.. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE 4 ~.. V E R I F T CAT I O N The undersigned, an officer of the Corporation which is the Plaintiff in the foregoing 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 : y- 2a-t~ Name : /urnett Tit 1 e : Assistant Vice President Company: OneWest Bank FSB as servicer on behalf of Deutsche Bank National Trust Company, as Trustee of the Home Equity Mortgage Loan Asset- Backed Trust Series INABS 2006- E, Home Equity Mortgage Loan Asset-Backed Certificates, Series INABS 200G-E under the Pooling and Servicing agreement dated Dec 1, 2006 Rabert J. Jones Sharon L. Jones Laan #1008760529 MJU #09120429-5 (Cumberland County, Pennsylvania) 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 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com ATTORNEY FOR PLAINTIFF ,r CJ~ti _. , ,,,;-~~ P" i'r'~.ti, ~~'i~''~~,~j Deutsche Bank National Trust :COURT OF COMMON PLEAS Company, as Trustee of the :CIVIL DIVISION Home Equity Mortgage Loan :Cumberland County Asset-Backed Trust Series INABS 2.006-E, Home Equity :MORTGAGE FORECLOSURE Mortgage Loan Asset-Backed Certificates, Series INABS 2006-E under the Pooling and Servicing agreement dated Dec 1, 2006 Plaintiff v. Robert J. Jones €NO. 10-2608 Sharon L. Jones Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Please issue Writ of Execution in the above matter: Amount due $181,616.50 Interest From 06/16/2010 5,610.88 to Date of Sale December 8, 2010 Ongoing Per Diem of 31.88 to actual date of sale including if sale is held at a later date Q (Costs to be added) ~ a~.oo PD a„y 54.40 CBF 921. oo ~~ ~~.oa ~. So ~. ~ !91.40 - Pa p~ UD OF P.C. BY: s f laintiff MARK J. ESQUIRE STUART WINNEG UIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ~a:~ p~~ ~ 1551055 E+~ c'~H55f0 RE lt~ri'f ~~~~ 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 2~ ± Q ~;y! ~ ~ ~ ~ ..:~ ~ : ~ 3 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 G(~sn,..:_. ,.,~~ 856-669-5400 ~':,, ~~,;'~~., , '~, pleadings@udren.com Deutsche Bank National Trust € COURT OF COMMON PLEAS Company, as Trustee of the Home CIVIL DIVISION Equity Mortgage Loan Asset-Backed 'Cumberland County Trust Series INABS 2006-E, Home Equity Mortgage Loan Asset-Backed :MORTGAGE FORECLOSURE Certificates, Series INABS 2006-E ; under the Pooling and Servicing agreement dated Dec 1, 2006 Plaintiff v. Robert J. Jones NO. 10-2608 Sharon L. Jones Defendant(s) CERTIFICATE TO THE SHERIFF I HEREBY CERTIFY THAT: I. The judgment entered in the above matter is based on an Action: A. In Assumpsit (Contract) B. In Trespass (Accident) X C. In Mortgage Foreclosure D. On a Note accompanying a purchase money mortgage and the property being exposed to sale is the mortgaged property. II. The Defendant(s) own the property being exposed to sale as: A. An individual X B. Tenants by Entireties C. Joint Tenants with right of survivorship D. A partnership E. Tenants in Common F. A corporation III. The Defendant(s) is (are): A. Resident in the Commonwealth of Pennsylvania X B. Not resident in the Commonwealth of Pennsylvania C. If more than one Defendant and either A or B above is not applicable, state which Defendant is resident of the Commonwealth of Pennsylvania. Resident: UD P.C. BY: Attorneys for Plaintiff MA REN, ESQUIRE STUART WINNE ,'ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, 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 r ,, < < , ALAN M. MINATO, ESQUIRE - ID ~ #75860 ~ , J ' ~, '~"`~~~ CHANDRA M. ARREMA, ESQUIRE - ~, , ,. ID #203437 WOODCREST CORPORATE CENTER ~ ~ j ' ~~`i ~ ~ -~ ~r' ~ ~ ~ ~ !'~ ~, 111 WOODCREST ROAD, SUITE 200 ~ ~ CHERRY HILL, NJ 08003-3620 C~;(J.-;~- -'''~~ 856-669-5400 r'c~ ~ ~~~~~~-+ ~'''f' pleadings@udren.com Deutsche Bank National Trust ;COURT OF COMMON PLEAS Company, as Trustee of the :CIVIL DIVISION Home Equity Mortgage Loan :Cumberland County Asset-Backed Trust Series INABS 2006-E, Home Equity =MORTGAGE FORECLOSURE Mortgage Loan Asset-Backed Certificates, Series INABS 2006-E under the Pooling and Servicing agreement dated Dec 1, 2006 Plaintiff v. Robert J. Jones €N0. 10-2608 Sharon L. Jones Defendant (s ) C E R T I F I CAT E I hereby state that as the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( X ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UD OF P.C. BY: [~ neys ctor Plaintiff MARK J. ESQUIRE STUART WINNEG, IRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, 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 F'' f ;:~ ~. ~~- ~ t ALAN M. MINATO, ESQUIRE - ID #75860 ",,~~ .f .++._ CHANDRA M. ARREMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER '' ~ "' ~ ~ r°" ~ ` 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 G(,'PJ's~ _'~f~` 856-669-5400 r':-..,<>4'L~,';=",;',~1 pleadings@udrea.com Deutsche Bank National Trust =COURT OF COMMON PLEAS Company, as Trustee of the :CIVIL DIVISION Home Equity Mortgage Loan :Cumberland County Asset-Backed Trust Series INABS 2006,-E, Home Equity =MORTGAGE FORECLOSURE Mortgage Loan Asset-Backed Certificates, Series INABS 2006-E under the Pooling and Servicing agreement dated Dec 1, 2006 Plaintiff v. Robert J. Jones €NO. 10-2608 Sharon L. Jones Defendant (s ) AFFIDAVIT PURSUANT TO RULE 3129.1 Deutsche Bank National Trust Company, as Trustee of the Home Equity Mortgage Loan Asset-Backed Trust Series INABS 2006-E, Home Equity Mortgage Loan Asset-Backed Certificates, Series INABS 2006-E under the Pooling and Servicing agreement dated Dec 1, 2006, 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: 30 Wagner Drive, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Robert J. Jones 7865 W. Highway 40, #150 Ocala, FL 34482 Sharon L. Jones 7865 W. Highway 40, #150 Ocala, FL 34482 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 Cach, LLC 4340 South Monaco Street Denver, CO 80237 4. Name and address of the last recorded holder of every mortgage of record: Name Address Deutsche Bank National Trust Company, as Trustee of the Home Equity Mortgage Loan Asset-Backed Trust Series INABS 2006-E, Home Equity Mortgage Loan Asset-Backed Certificates, Series INABS 2006-E under the Pooling and Servicing agreement dated Dec 1, 2006 888 E. Walnut Street Pasadena, CA 91101 5. Name and address of every other person who has any record lien on the property: Name Address East Pennsboro Township 98 South Enola Drive Enola, PA 17025 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 Department 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 30 Wagner Drive Carlisle, PA 17013 •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: July 13, 2010 UDRF.N T.Aw (1F~CES ~ p , C , torney ror Plaintitt MARK ESQUIRE STUART WINNEG, E UIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQIIIRE STIIART WINNEG, ESQIIIRE LORRAINE DOYLE, ESQIIIRE ALAN M. MINATO, ESQIIIRE CHANDRA M. ARREMA, ESQII' WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SIIITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust Company, as Trustee of the Home Equity Mortgage Loan Asset-Backed Trust Series INABS 2006-E, Home Equity Mortgage Loan Asset-Backed -Certificates, Series INABS 2006-E under the Pooling and Servicing agreement dated Dec 1, 2006 Plaintiff v. Robert J. Jones Sharon L. Jones Defendant(s) TO: ALL PARTIES IN INTEREST AND CLAIMANTS - ID #04302 - ID #45362 - ID #34576 - ID #75860 IRE - ID #203437 ATTORNEY FOg EI.A~N'~IFF ~~F~-~ c~r~.° ~_~°~~~~ r, r r' ~ „,< COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-2608 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Robert J. Jones Sharon L. Jones PROPERTY: 30 Wagner Drive Carlisle, PA 17013 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on December 8, 2010, at 10:00am, at the Commissioners Hearing Room, 2nd Floor, Courthouse Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 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. ~» 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 r)- ~ 1`~ r:.. --~-~~~t CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER Z~lQ ,~4;~ ~O ~~ ~~ ~ ; ~. 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 ~~tJr_;~ ;- . ,~ ~~~(~ 856-669-5400 r'l 40,' ~ i'~r~' pleadings@udren.com Deutsche Bank National Trust :COURT OF COMMON PLEAS Company, as Trustee of the :CIVIL DIVISION Home Equity Mortgage Loan :Cumberland County Asset-Backed Trust Series INABS 2006-E, Home Equity :MORTGAGE FORECLOSURE Mortgage Loan Asset-Backed Certificates, Series INABS 2006-E under the Pooling and Servicing agreement dated Dec 1, 2006 Plaintiff v. Robert J. Jones €NO. 10-2608 Sharon L. Jones Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Robert J. Jones 7865 W. Highway 40, #150 Ocala, FL 34482 Your house (real estate) at 30 Wagner Drive, Carlisle, PA 17013 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, Carlisle, PA to enforce the court judgment of $181,616.50, 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 actioa: 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.) +YOII MAY STILL BE ABLE TO SAVE YOUR PROPERTY, AND YOU HAVE OTHER RIGHTS 8V'8N IF THL SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. Yau 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 ull amount due is paid to the Sheriff and the Sheriff gives a deed to the buye. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which wase.id for your house. A schedule of distribution of the money bid for yourouse will be filed by the Sheriff within 30 days after the sale. This schede will state who will be receiving that money. The money will be paid r in accordance with this schedule unless exceptions (reasons why the=oPosed distribution is wrong? are filed with the Sheriff within ten (1(daYs after Schedule of Distribution is filed. 7> You may also have other rights and defenses, or woof getting your home back, if you act immediately after the sale. YOII SHOIILD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOII D~ ~~ A LAWYER OR CANNOT AFFORZ! ONE, GO TO OR TELEPHONE THS OFFICE L 8$LOW TO FIND OIIT WHERE YOII CAN GST LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle,'PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Associatio 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 * 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 ~ J ~ ~ .~ ,1i.. C l1 ~. =} ~ ; ~ J 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 ~ll~d "_ ,_, `~,~„~ 856-669-5400 l~i;~`J''~:`. ~'~~'~,',' pleadings@udren.com Deutsche Bank National Trust =COURT OF COMMON PLEAS Company, as Trustee of the :CIVIL DIVISION Home Equity Mortgage Loan :Cumberland County Asset-Backed Trust Series INABS 2006-E, Home Equity 'MORTGAGE FORECLOSURE Mortgage Loan Asset-Backed Certificates, Series INABS 2006-E under the Pooling and Servicing agreement dated Dec 1, 2006 Plaintiff v. Robert J. Jones €NO. 10-2608 Sharon L. Jones Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Sharon L. Jones 7865 W. Highway 40, #150 Ocala, FL 34482 Your house (real estate} at 30 Wagner Drive, Carlisle, PA 17013 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, Carlisle, PA to enforce the court judgment of $181,616.50, 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 Oi~1NSR' 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 TAKE 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 TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAYS A LAWYER OR CANNOT AFFORD ONE, GO TO OR T8L$PHONS THE OFFICE LISTED BELOW TO FIND OUT WHSRS YOII CAN GST LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-2608 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY, as Trustee of the HOME EQUITY MORTGAGE LOAN ASSET-BACKED TRUST SERIES INABS 2006-E, HOME EQUITY MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES INABS 2006-E under the Pooling and Servicing agreement dated 12/1/06, Plaintiff (s) From ROBERT J. JONES and SHARON L. JONES (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 $181,616.50 L.L.$.50 Interest from 6/16/10 to 12/8/10 ongoing per diem of $31.88 to actual date of sale including if sale is held at a later date -- $5,610.88 Atty's Comm % Due Prothy $2.00 Atty Paid $191.90 Other Costs Plaintiff Paid Date: 7/20/10 avid D. Buell, rothonotary (Seal) gy. Deputy REQUESTING PARTY: Name: ALAN M. MINATO, ESQUIRE Address: UDREN LAW OFFICES, PC WOODCREST CORPORATE CENTER 111 WWODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 75860 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER Ill WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank National Trust :COURT OF COMMON PLEAS Company, as Trustee of the :CIVIL DIVISION Home Equity Mortgage Loan :Cumberland County - cz) Asset-Backed Trust Series C ) INABS 2006-E, Home Equity Mortgage Loan Asset-Backed :NO. 10-2608 Zt? c:) r- Certificates, Series INABS x? r •? - rn 2006-E under the Pooling and ?D W C ° Servicing agreement dated Dec 1, 2006 mop a Plaintiff -- C Ln ?, v . Robert J. Jones Sharon L. Jones Defendant (s) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: November Z,? , 2010 UDREN OF' ICES, ?BY: Attorney-f-or Plaintiff Alan M. Minato, Esquire PA ID 75860 Deutsche Bank National Trust Company, as Trustee, et. al., Plaintiff(s) vs. Robert J. Jones. et. al,. Defendant(s) Service of Process by APS International, Ltd. 1-800-328-7171 APS International Plaza 7800 Glenroy Road Minneapolis, NIS SS439-3122 APS File 0: 107697-0001 AFFIDAVIT OF DUE AND DILIGENT ATTEMPT UDREN LAZY OFFICES Service of Process on: I I --Robert J. Jones Ms. INenni Crommartv Court Case No. 10-2608 I 1 I Wooderest Rd.. Ste. 200 Cherry Hill, NJ 08003-3620 ' Customer File: 09120429-5 State of.. County o Name of Server: undersigned. being duly sworn, deposes and says that at all times mentioned 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 Robert J. Jones and after due and diligent efforts, was unable to effect service. Attempts: The following is a list of the attempts made to effect service: f / t DatesNime/Address Attempted: 30 Wagner Drive, Cnrlisla PA 17013 Reason for UattsMme/Address Reason for N Dateslrime/Address Reason for Non-Service: Based upon the above stated facts, Affiant believes the defendant is avoiding service. Signature of Server: Undersigned declares under penalty of perjury that th of g is true and ipaturc rver APS Internatio 1, Ltd. COMMONWEALTH OF PENNSYLVANIA Notarial Seal M. Michelle Guyton, Notary Public Carlisle 8oro, Cumbedand County My Commission Expires July 1, 2012 i Member, Pennsylvania Association of Notaries Deutsche Bank National Trust Company, as Trustee, cf. at.. ' Pla;ntitf?s) . YS. Robert J. Jones, et. al., Defendant(s) Service of Process by APS International, Ltd. IN" 1-800-328-7171 _ APS International Plaza 7800 Clearoy Road ?. Minneapolis, MN 55439-3122 APS File #: 1076974001 AFFIDAVIT OF DUE AND DILIGENT ATTEMPT I UDREN LAN' OFFICES Ms. Heani Crommartv 11 I Wooderest Rd., Ste. 200 Cherry Hill. NJ 08003-3620 i Service of Process on- -Sharon L.. Jones Court Case No. 10-2608 Customer File: 09120429-$ State of.. ss. = - =- . - - - - - - - - - - - - - - - - - County 4::7cl f Name of Server: undersigned, being duly sworn, deposes and says that at all times mentioned 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 Sharon L. Jones and after due and diligent efforts, was unable to effect service. Attempts: The following is a list of the attempts made to effect service: 9ates/1'imel.%ddress Attempttd• 30 Wagner Drive. Carlisle. PA 1700 Reason for Noa-Sentice: Date%/fimdAddres Reason for vates/rime/Addret Reason for Non-Service: Based upon the above stated facts, Affiant believes the defendant is avoiding service. Signature of Server: Undersigned declares under penalty of perjury that t or oin is true d correct. lgnature of trv r APS Inte altional, Ltd. .11 COMMONWEALTH OF PENNSYLVANIA Notarial Seal M. Michelle Guyton, Notary Public Carlisle Boro, Cumberland County My Commission Expires July 1, 2012 Member, Pennsylvania Association of Notaries Service of Process by Deutsche Bank Nitional Tfust Company, as Trustee, et. al., APS International, Ltd. Plaintiff(s) 1-800-328-7171 vs. Robert J. Jones, et. al., Defendant(s) APS International Plaza 7800 Glenroy Road Minneapolis, MN 55439-3122 APS File #: 107247-0001 AFFIDAVIT OF DUE AND DILIGENT ATTEMPT UDREN LAW OFFICES Ms. Henni Crommarty 111 Woodcrest Rd., Ste. 200 Cherry Hill, NJ 08003-3620 Customer File: 09120429-5 --Robert J. Jones Court Case No. 10-2608 State of•. EL VVLE:OA ) ss. County of: Pi it V C AP ) Name of Server: _(Zp jilt j- 1J. Jet c 4wo"3 S , undersigned, being duly sworn, deposes and says that at all times mentioned 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 Robert J. Jones and after due and diligent efforts, was unable to effect service. Attempts: The following is a list of the attempts made to effect service: Datesfrime/Address Attempted: 7865 W. Highway 40, #150, Ocala, FL 34482 Reason for Non-Service: VR>kl?L'£ To Efwi cr maynts mma r-mr-i Al imeawr ps :FA Dates/Time/Address Attempted: W VV{. G 11D-/&-10AT7 y CG O- 0-M-1 0 AM Reason for Non-Service: ?OAnM Z Dates/Time/Address Attempted: l?"? (p•?0 kT- 7-*oc #K /10--1r /O i4'S Reason for Non-Service: LJ Based upon the above stated facts, Affiant believes the defendant is avoiding service. Signature of Server: Undersigned declares under penalty of perjury that the foregoing is true and correct. _ OS-o7-(0 Signature of Server APS International, Ltd. Service of Process on: Subscribed and sworn to before me this L day of No! . , 20 1-0 Notary fub lie / J (Commission Expires) KENNETH W. KELLEY, A CWaA ion DD 656388 OM June 15, 2011 NY F* Momo 900447019 Service of Process by Deutsch Bank National Trust Company, as Trustee, et. al., APS International, Ltd. 'Plaintiff(s) VS. 1-800-328-7171 Robert J. Jones, et. al., Defendant(s) APS International Plaza 7800 Glenroy Road Minneapolis, MN 55439-3122 APS File #: 107247-0001 AFFIDAVIT OF DUE AND DILIGENT ATTEMPT UDREN LAW OFFICES Ms. Henni Crommarty 111 Woodcrest Rd., Ste. 200 Cherry Hill, NJ 08003-3620 Customer File: 09120429-5 Service of Process on: --Sharon L. Jones Court Case No. 10-2608 -------------------- - ---------------- State of: EL_a1 %:,9* ) ss. County of: t'1/kl? &oi-1 ) Name of Server: IC - W. /ylfr G%yXXs&tT,t , undersigned, being duly sworn, deposes and says that at all times mentioned 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 Sharon L. Jones and after due and diligent efforts, was unable to effect service. Attempts: The following is a list of the attempts made to effect service: Dates/Time/Address Attempted: 7865 W. Highway 40, #150, Ocala, FL 34482 Reason for Non-Service: l1A/"L ll: TO EFFECT- 16-AyTAG.IE aW THE VEF V1Aft&y_ AP E-p- Dates/rime/Address Attempted: Reason for Non-Service: Dates/rime/Address Attempted: Reason for Non-Service V Based upon the above stated facts, Affiant believes the defendant is avoiding service. Signature of Server: Undersigned declares under penalty of perjury Subscribed and sworn to before me this that the foregoing is true and correct. day of c? Kai(' , 20 ? Signature of Server Notary Public (Commission Expires) APS International, Ltd. KEN E7 H ?N. KELLEY, JR. "' CbmmWion DD 656368 E'PrGs June 15,2011 IIDREN 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 of the :CIVIL DIVISION Home Equity Mortgage Loan Cumberland County Asset-Backed Trust Series INABS 2006-E, Home Equity Mortgage Loan Asset-Backed :NO. 10-2608 Certificates, Series INABS 2006-E under the Pooling and Servicing agreement dated Dec 1, 2006 Plaintiff V. Robert J. Jones Sharon L. Jones Defendant(s) MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT o rn r-n mt _ r- -<> iV O© r?• C) -n Plaintiff, by its counsel, moves this Honorable Court for an order directing service of the Notice of Sale upon Defendant(s), Sharon L. Jones and Robert J. Jones by regular mail and certified mail and in support thereof avers the following: 2. Process was unable to be served at 30 Wagner Drive Carlisle, PA 17013, which is the mortgaged premises. A copy of the Return of Service is attached hereto as Exhibit A. 1. Process was unable to be served at the then last known address of said Defendant (s) at 7865 W. Highway 40, #150, Ocala, FL 34482. A copy of the Return of Service is attached hereto as Exhibit B. 3. Pursuant to Pa.R.C.P. 430, Plaintiff made a Good Faith Investigation, the report thereof being attached hereto as Exhibit C. 4. Said investigation was unable to determine an alternate address for said Defendant(s). 5. The last known address of Defendant(s) is as set forth in the attached Exhibits. 6. A Judge has not ruled upon any other issue in this or a related matter, and there is no other issue before a Judge to be ruled upon. 7. There is no opposing counsel of record and therefore, no concurrence of opposing counsel can be sought. 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), Sharon L. Jones and Robert J. Jones. UDREN LAW OFFICES, P.C. BY: Attorneys for P aintiff Adam L. KaM, EsQWM PA ID 86+4M Service or Process hV DriitscimBank -jtiaa2, Trust Cassspanw,.as 'trust-r; e,. al.- APS International, Ltd. t°tats?itfffs3 . Hobert J- jor:es, et, oi„ De_tenilaw(s) x r t tt€'S €atixrrsrtiiarsal Yi xs1 - IND Glenroy Roast APS File F#s 1076 7'•.ElE" T AFFID I°1 OF DUE AND DII.LIGENI ' A17ENTPT Scri iet of PrescPss on: VDIREN LANV OMC.£S Raberi'J. Janes 14fs..ttcaoi Crezunlarty court cases Nor itl 2fiffs E 3' ( Woudrrest R-d., Ste, 2W Cherry Hill'.. Z 08003-3€20 cuslamer File, E#; Ni3me.ef Server: undersigned. ?' undersigned. s., 4'tedErl dui. ' sworn, ,: det)flSt: and :r9ft: says that at all times; mentioned herein. s&e was of legal age and was not a pa> to this action-, Decut[jen € erved* The undersigned nttainp€ed to serve the documents described as., Matit r of Sheriffs We of Real ?ruperty Service of €'rucess an: The undersigned attempted to serve the documents an Rxnbert.I ones staid after care and diligent ef#orts, xvas unable to effect service- ,attompts: The following is a fist of the anempts made to effect ser-vi' e:: 30 'ftgner Drivt. Cn ftie. PAS. ) 7013 t t)utts+'I'imdrtx)dress,tiYrristst=[T: TC.?6Wa i•4Ai':u6i.$r-L `teG f'"? Fa. I-"''.. ``"- ,,F.r.'?k'°'..' !'sr°'''?• rs,". rr Y fem. t3ut?st?imtl:?,c)dresF:4[€ctnptetl: 4? ?"" K,- ,?°'?'.. "? ;fir,. ?' ?-- r Lr.'"'4? '-r ,?„'? w:? . Keaton (fir NaTl-Smiee: >f ? :ms t3A1t`.afriY,i ?. t'si rl°s5 ,t e*nyil=tl f'7 .,` - ,•r". ? .. ' ,-.:?r ` " ::' r-? A ?• rt =7 - Reason for M1an-Serene: eased upsets the above stated faces, Affiant ?`sieves the defendant is avaiding service. Signature of Server-: f.indersivAed declares under penaity of pcrjurT Subsrc= 48 and -;Ni ,rn to before me this`111 that u i :qrcR D4 g is mte and dtiNA, t cIver ! it+41:7ir" ua .r= ?*' ''•-_...-.- t?0711Y'71Y552&"r6?'?.?hh:S AY InternafE%o4di, Ltd. ''yea'. <' 5ad4+: Tt: 'NNSY?..'JANi:r, axe ;rs, ; ?: _ ;3unS± MIBIT A 13tttt_sthe u Nothmal Trust Company, as lwis-tec. et: at.,. t?laii?titr#~i kohert..L Jones, et. a!.:, Defendant;sl SerVice of Pracess by nternatianal, Ltd. -go 1 -6-328-7171 ° A PS tnteran6orsa4 Fiore 78w Glearky Road '4tinnealrp3is, ;;il? 5?3J-3l22. Servive, of Process am. UMEN't.A4V OFFICES -Sharon L. ,ione_% SIS. I-leavi Crohm. artt court case Not W-12 08 !Ili 'oadeeeSa. Rd- Ste. .260 Cherry Hilt. NJ 08001-36-70 Clustarn-er File: 09420329•s iStzate of ^gYd tp"<x ? r ss. County Name of Server- ?+ ?~° ? ?' aandersioned, bei€;? c#tlt??'s.worn,. deposes a says lhat. al '1411 trme5 mentioned herein, sAie was of legal age and was not u party to that action: Doa`ionents Served: the tlndcrsianed attempted to Nerve the doctatrtents described as. Notice of Sheriff's Sale of Real property sett tee cil"Pruefts on: The cnadersitrned ativn rpted to &me the documents nn Sharon L. v ones and after due wid diligent efforts, vm unable to effect sr~mce. ttetatpts; The following is a list of the attempts inade to effect serviev 30 Wagger brhm Carlisle. PA 17013 ? !l 3)exrsl!'S tut/std tlres4 .4 teem pied: ,_"4 Y? s: ,,A .-r ?'r"[4'?4^',j ^.:^'s.#'F'+ +L'.z'r !..i??'r L';''' ?"'. `^'•r;.r.. T'c" , >` .•":, tic *wi for !4aa• ?t.rtsee f wO..Timeladdrez Reason for t)a tQS?T'iutef,?ttd m Rctttasu tsx `vn-""sor?;•`sct 8 ed tttton the -ah ave staled facts, Affiant believes the. defendant is avtlidinD Swn?ice. Signature or SMcr. Unde tutted declares under penalty of pegury ` u is.ar'ste..d and ,wIlrn to lxfbne me this that t -am+eoing is irk 'nd correct. ; CaY 0` Aetsw uiblic rtes?mtsstnr i xt fis'!:w 4' #. - y,. 'itttltirt O, •aLr`.'t.: - t[ t' _ AP Lnterki.ttiatt~;al..Ltd. !L Q'H 14?-jm S, F. Service of Process by Deutsche Bank National Trust Company, as Trustee, et. al., APS International, Ltd. Plaintiff(s) VS. 1-800-328-7171 Robert L Jones, et. al., Defendant(s) APS International PIaTS? 141 7800 Glooroy Road Minneapolis, MN 55439-3122 APS File #: IM74MI AFFIDAVIT OF DUE AND DILIGENT ATTEMPT UDREN LAW OFFICES Ms. Henni Crommarty 111 Woodcrest Rd., Ste. 200 Cherry Hill, NJ 08003-3620 Customer File: 09120429-5 -Robert J. Jones Court Case No. 10-2608 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -_ - - - - - State Of. FL "Moo ' } ss. County of: M/lfZCAl%.1 } Name of Server: (Zoprit r w. p4 e- V LIXWO S , undersigned, being duly sworn, deposes and says that at all times mentioned 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 Sheriff's Sale of Real Property Service of Process on: The undersigned attempted to serve the documents on. Robert J. Jones and after due and diligent efforts, was unable to effect service. Attempts: The following is a list of the attempts made to effect service: Dateu Time/Address Attempted: 7865 W. Highway 40, #150, Ocala, FL 34482 Remo for Non-Scrvice: VP.A*I-f- TV EMCr M,AVC& E bN rMP- D"pM Jr )a, - DamsMme/Addresr Attempted: Reason for Non-Service: Datestrime/AddressAttempted: l_Q-?fo-lo T'Veik et /1 p.-aT-IO itT Reason for Non-Service: U Based upon the above stated facts,. Affant believes the defendant is avoiding service. Signature of Server: Undersigned declares under penalty of perjury that the foregoing is and correct. oS- 07-.!2_ Signature of Server APS International, Ltd. Service of Process on: Subscribed and sworn to before me this L day of N.,q . , 20 1 a Notary Public ` / J (Commission Expires), mow. KE-LEY, JR. MMM 1 EXHIBIT B Service of Process by Deutsche Bank National Trast Company, as Trustee, at al., APS International, Ltd. Plaintiff(s) VS. 1-800-328-7171 Robert J. Jones, et at, Defendant(s) AM International Plaza 9800 Glenroy Road Minneapolis, MN 55439-3122 APS File ii: 107217-0001 AFFIDAVIT OF DUE AND DILIGENT ATTEMPT UDREN LAW OFFICES Ms. Henni Crommarty 111 Woodcrest Rd., Ste. 200 Cherry Hill, NJ 08003-3620 Customer File: 09120429-5 Service of Process on: -Sharon L. Jones Court Case No. 10-2608 _ _ _ _ _ - -- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ State of: - f LA?i>VQ? - ) SL County oft( 1?•1 ) Name of KMIW 0..04 t Ctt VY , undersigned, being duly sworn, deposes and says that at all times mentioned 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 Sheriff s Sale of Real Property Service of Process on: The undersigned attempted to serve the documents on Sharon L. Jones and after due and diligent efforts, was unable to effect service. Attempts: The following is a list of the attempts made to effect service: DateuTime/Addras Attempted: 7865 W. Highway 40, 0150, Ocala, FL 34482 Reason forNou-Service: I.I A#&Lf- 1-0 i-FfEC-T- S C.F C*1 T F- UE?F?iAl1/r AFIE- C DatesMme/Address Attempted Reawn for DatesMmdAddms Attempted: Reason for Non-Service; ['Based upon the above stated facts, Affiant believes the defendant is.avoiding service. Signature of Server: Undersigned declares under penalty of perjury Subscribed and sworn to before me this that the foregoing is true and correct. day of MW 20 C?'?-rJ 1- So _ < Signature of Server Notary Public (Commission Expires) APS International, Ltd. I(FMM W KELLEY ?on ?R E 'M J W* 15,, 2011 roNfinh,?,,,e0p,y, Page 1 of 2 PLAYERS NATIONAL LOCATOR AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number: 09120429-5 Attorney Firm: Mark J Udren & Associates Case Number: Subject: Robert J Jones and Sharon L Jones A.K.A: Robert Jacob Jones, Sharon Beachy-Jones, Sharon B Jones, Sharon L Beachy, Sharon L Saam, Sharon Saam Beachy Property Address: 30 Wagner Drive Carlisle, PA 17013 Last Known Address: 7865 West Highway 40, #150 Ocala, FL 34482 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 3, 2010 1 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): 202-46-xxxx 161-62-xxxx B. EMPLOYMENT SEARCH: We were unable to verify current employment for Robert J Jones and Sharon L Jones. C. INQUIRY OF CREDITORS: Creditors indicated the last reported address for Robert J Jones and Sharon L Jones is 30 Wagner Drive, Carlisle, PA 17013 with no valid home number. INQUIRY OF TELEPHONE COMPANY A. DIRECTORY ASSISTANCE SEARCH: Directory assistance does not have a listing for Robert J Jones and Sharon L Jones. INQUIRY OF NEIGHBORS We contacted (717) 249-3585 registered at 38 Wagner Drive, Carlisle, PA 17013 and spoke with a neighbor who stated Robert J Jones and Sharon L Jones moved from 30 Wagner Drive, Carlisle, PA 17013 and did not have a forwarding address. INQUIRY OF POST OFFICE A. NATIONAL ADDRESS UPDATE: As of October 29, 2010 the National Change of Address (NCOA) has no change for Robert J Jones and Sharon L Jones from 30 Wagner Drive, Carlisle, PA 17013. MOTOR VEHICLE REGISTRATION EXHIBIT C A. MOTOR VEHICLE & DMV OFFICE: Page 2 of 2 We were unable to verify current drivers license information for Robert J Jones and Sharon L Jones. OTHER INQUIRIES A. DEATH RECORDS: As of October 29, 2010, the Social Security Administration has no death record on file for Robert J Jones and Sharon L Jones 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: Robert - May 1956 Sharon - December 1966 AFFAIANTInd Krekeler -? K Notary ubl c, 1110 ory Seal Subworn efore me Mmr 0 10 8t a a of Mluouhr?l St. any Corn oml o i ?u11 O?Z 662014 7 UBLIC 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 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 of the :CIVIL DIVISION Home Equity Mortgage Loan ::Cumberland County Asset-Backed Trust Series INABS 2006-E, Home Equity Mortgage Loan Asset-Backed -NO. 10-2608 Certificates, Series INABS 2006-E under the Pooling and Servicing agreement dated Dec 1, 2006 Plaintiff v. Robert J. Jones Sharon L. Jones 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 sherif f ' 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 And B, 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 Af f idavit of Good Faith Investigation marked Exhibit C. WHEREFORE, Plaintiff prays and respectfully requests service of the Notice of Sale upon Defendant(s) by regular mail and certified mail. UDREN LAW OFFICES, P.C. BY : to? Attorneys for P ntiff Adam L. KOM, EqWMe PA ID 86406 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: December 1, 2010 CES, P.C. UDRE LAW OF C11, BY: Attorneys for Plaintiff Adam L. Kayes, EsgWm PA ID 864138 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 of the :CIVIL DIVISION Home Equity Mortgage Loan :Cumberland County Asset-Backed Trust Series INABS 2006-E, Home Equity Mortgage Loan Asset-Backed :NO. 10-2608 Certificates, Series INABS 2006-E under the Pooling and Servicing agreement dated Dec 1, 2006 Plaintiff V. Robert J. Jones Sharon L. Jones De f endant (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: x Regular First Class Mail Date Served: December 1, 2010 TO: Robert J. Jones Sharon L. Jones 30 Wagner Drive Carlisle, PA 17013 7865 W. Highway 40, #150, Ocala, Fl 34482 UDRE LAW/I OFF CES , P.C. IUQM BY: Attorneys for PlAintif f Adam L. Kaye, E"WM PA ID 86406 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Deutsche Bank National Trust Company, as Trustee of the Home Equity Mortgage Loan Asset-Backed Trust Series ::NO. 10-2608 INABS 2006-E, Home Equity Mortgage Loan Asset-Backed Certificates, Series INABS c © 2006-E under the Pooling and _ zc-n Servicing agreement dated Dec r- 1, 2006 cn? © Plaintiff r ? co o ? C1 > V. Robert J. Jones CD r'c r .°C">? Sharon L. Jones Defendant(s) O R D E R AND NOW, this '8th day of )tc't,MUvf , 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), Sharon L. Jones and Robert J. Jones, 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), Sharon L. Jones and Robert J. Jones at 30 Wagner Drive Carlisle, PA 17013, 7865 W Highway 40, #150 Ocala, FL 34482 and by posting the mortgaged premises located at 30 Wagner Drive Carlisle, PA 17013. rnall£cL 64 1J. y BY THE COURT: 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 Company, as :COURT OF COMMON PLEAS Trustee of the Home Equity Mortgage Loan ::CIVIL DIVISION Asset-Backed Trust Series INABS 2006-E, Home :Cumberland County Equity Mortgage Loan Asset-Backed Certificates, Series INABS 2006-E under the Pooling and Servicing agreement dated Dec 1, 2006 _?? °= --t Plaintiff r7l?a Fn -- r-tl ? P'.« LD Robert J. Jones -v C -n Sharon L. Jones NO. 10-2608 i - Defendant(s) ;? tom' AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by order of Court, then proof of compliance with said order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: January Z7, 2011 UDREN LAW OFFICES, P.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 Deutsche Bank National Trust :COURT OF COMMON PLEAS Company, as Trustee of the :CIVIL DIVISION Home Equity Mortgage Loan :Cumberland County Asset-Backed Trust Series INABS 2006-E, Home Equity 'MORTGAGE FORECLOSURE Mortgage Loan Asset-Backed Certificates, Series INABS 2006-E under the Pooling and Servicing agreement dated Dec 1, 2006 Plaintiff V. Robert J. Jones €NO. 10-2608 Sharon L. Jones Defendant (s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Deutsche Bank National Trust Company, as Trustee of the Home Equity Mortgage Loan Asset-Backed Trust Series INABS 2006-E, Home Equity Mortgage Loan Asset-Backed Certificates, Series INABS 2006-E under the Pooling and Servicing agreement dated Dec 1, 2006, 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: 30 Wagner Drive, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Robert J. Jones Sharon L. Jones 7865 W. Highway 40, #150 Ocala, FL 34482 30 Wagner Drive, Carlisle, PA 17013 7865 W. Highway 40, #150 Ocala, FL 34482 30 Wagner Drive, Carlisle, PA 17013 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 Cach, LLC 4340 South Monaco Street Denver, CO 80237 4. Name and address of the last recorded holder of every mortgage of record: Name Address Deutsche Bank National Trust Company, as Trustee of the Home Equity Mortgage Loan Asset-Backed Trust Series INABS 2006-E, Home Equity Mortgage Loan Asset-Backed Certificates, Series INABS 2006-E under the Pooling and Servicing agreement dated Dec 1, 2006 5. Name and address of on the property: Name East Pennsboro Township Address 98 South Enola Drive Enola, PA 17025 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 Department Domestic Relations Section Commonwealth of PA, Department of Revenue 888 E. Walnut Street Pasadena, CA 91101 every other person who has any record lien 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 30 Wagner Drive Carlisle, PA 17013 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 : January '1'7 , 2011 UDREN LAW OFFICEV, P BY: Att 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 of the Home Equity Mortgage Loan Asset-Backed Trust Series INABS 2006-E, Home Equity Mortgage Loan Asset-Backed Certificates, Series INABS 2006-E under the Pooling and Servicing agreement dated Dec 1, 2006 Plaintiff V. Robert J. Jones Sharon L. Jones Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON CIVIL DIVISION Cumberland County PLEAS NO. 10-2608 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Robert J. Jones and Sharon L. Jones PROPERTY: 30 Wagner Drive, (Middlesex Township) Carlisle, PA 17013 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 .7 O 0" (D T L (n L, O O 3 (D w fn w V V TI fQ CD V/ cr O co co r P. O 7 CD 0 N 0 N co U1 3 Cr (D Q r -? y O - cn s A - W - N - - p O CO V ?? U7 A W N ? ?Dy CD M N d m ? 3 m C/) t7 O c '2 q w d y O ` C- CD (D C) co D m y i 0 (.3 y 00 nom ODd (n Co (4 ?o Z ;o 0 Om0 C/) 0 ? ? 00 O? z N -' CD 0 (o - U) m-0 I? D W< K m m ? a) m C D 0000 0 r 0 ?; m v Z O K CZ m a m, ,m C? - c o - CL I mom Z a(7 ? oo N N W N ?m (? c ,?nZ cc 0 o -I O ? po xm z m0 N = -<MD m ^-« v fD-j 0 On w m ? cn o N 0? M > m4 00 D r? 24 0 mN m > = n 0 n O-H ID y a i = C >c --i m CD ?. Z 3 ?0C7 D Z O U) O CD v v ? Q Om -n o0 -1 D"' Z)1 r a 3 w U)p C C N vi _ n D - W O r - m o 0 to - 3 v, CD 0 z Cl) cn r- m c) -0 D?m q o o 00 N D r V -i z ? m D (D o V D KZ D ,i -4 D a OD 0 -n z 0 o 0 (J w W m to CD o W m .Z1 -0 ? ? ?? O 0 n 7 ;o CD 0 c m c ( N (D (D y ?• -a n a m (O o y o . _.N (D El 11: MO CD c 8 $, $ x _t =m =a j 3? t3` .f CD (;Du ma 3 y O CD .Tl 2. m (D -.4 ;03 m CL ? o Q ox.m m c O O - (n c •?- o o , `O3om-0 o:c n p a 2 m SD1 ma33.oo. ?a ??m0 oU) °-oe (D? (O yc0Di o j m o< S am m y o fDO ? ?3?aoy. ' SdS? 0 v N ao 7 m c onan .(Z.7 777 O y 7 C O ' mn°o?oo ( C p y N O o c _ D J (nm o m m ' ? ? ? Ha ?m Q.m3 00 C.d ? d c C n O O Jj D3!R OO L? (D N m 3v o . . m vn MID 5'. °f -E3 0 OCD m09.3=••- oSao; O = Jyy x RCD3 m OoQo m v 0o, ? c ? m ? m -n 3? a y d.N O O n N M O N J O (D O 7 "`(O 5g m m SOC x y c a ?' ?l (n y?(D W Q O Q J O N w o S aJ J m (D (D ? Q =? 01 (D - y o m d N N O ? - S y y ? X d N N 3 Nmv?;3 -n ?n (D m2 a c 3 m m m ^a?CD m o m 3 w ?7 .Z1 3. obi w oo `? 3 . o EP H N J J a. g °° ?ro° HJ 1T CD t MARK J. UDREN, ESQUIRE NJ MANAGING ATTORNEY TINA MARIE RICH OFFICE ADMINISTRATOR UDREN LA W OFFICES, A C. WOOD CREST CORPORATE CENTER III WOODCREST ROAD SUITE 200 CHERRYHILL, NEW JERSEY 08003-3620 856. 669. 5400 FAX: 856. 669. 5399 FREDDIE MAC PENNSYLVANIA DESIGNATED COUNSEL Prothonotary of Cumberland County Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 Re: Deutsche Bank National Trust Company, as Trustee of the Home Equity Mortgage Loan Asset-Backed Trust Series INABS 2006-E, Home Equity Mortgage Loan Asset-Backed Certificates, Series INABS 2006-E under the Pooling and Servicing agreement dated Dec 1, 2006 VS. Robert J. Jones & Sharon L. Jones Cumberland County C.C.P. No. 10-2608 Dear Prothonotary: In connection with the above captioned matter, enclosed please find Verification of Service by Certified Mail and Regular Mail Pursuant to Court Order. I have enclosed a copy of the first page to be time stamped and returned in the enclosed self-addressed stamped envelope. Thank you for your assistance with this matter. /hac Enclosures 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 of the :CIVIL DIVISION Home Equity Mortgage Loan :Cumberland County Asset-Backed Trust Series INABS 2006-E, Home Equity Mortgage Loan Asset-Backed Certificates, Series INABS 2006-E under the Pooling and Servicing agreement dated Dec 1, 2006 Plaintiff V. Robert J. Jones Sharon L. Jones NO. 10-2608 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 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: December 14, 2010 Robert J. Jones and Sharon L. Jones 30 Wagner Drive Carlisle, PA 17013 7865 West Highway Ocala, FL 34482 I verify that the I understand that penalties of 18 falsification to < 40, #150 statements made herein are true and correct and false statements made herein are subject to the Pa.C.S. Section 4904 relating to unsworn authorities. Dated: January 2011 UD BY At f-EXHIBIT A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Deutsche Bank National Trust Company, as Trustee of the Home Equity Mortgage Loan Asset-Sacked Trust Series ENO. 10-2608 INABS 2006-E, Home Equity Mortgage Loan Asset-Backed rr Certificates, Series INABS 2006-E under the Pooling and servicing agreement dated Dec 1, 2006 Plaintiff V. Robert J. Jones Sharon L. Jones Defendant (s) O R D E R AND NOW, this day o f `J EC,E rrt?j ?_ , 2 010 , 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), Sharon L. Jones and Robert J. Jones, 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), Sharon L. Jones and Robert J. Jones at 30 Wagner Drive Carlisle, PA 17013, 7865 W Highway 40, #150 Ocala, FL 34482 and by posting the mortgaged premises located at 30 Wagner Drive Carlisle, PA 17013. BY THE COURT: EXHIBIT 8 r i H O P) o ? Fj W H :r4 n Fj- a 0 rn w 0 N0 (D (U r n . rod C4 ?n 0 N? m m 10 oN w ® L Z COO eO-i?cc- 1 n C Im (} 71 mom O m P w vm Z ' m ?- -F Ir Ir 1! OSAW MIAL USE N [? w -,? - co co • 0 0 , redW.Od Fee in 0 C O O O Retum Rew" Fee (Endoraement %gWr.M Pockna* O C3 RestkW Ddvery Fee C3 O (Endon --ft Required) rU nJ C3' G Tote) Pasta" & Fees m m r` r` t Jones Sharon L --.... . . 30 Wagner Drive I,.. r... or PO Box N& i sine; irf Carlisle, PA 17013 -------------------------- r rrr-,??Le 4--, rt• ?TY r. Hasler c ? {f3 0 $, N o t3?i 03 A? 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M ao Post" $ M C3 O C3 Ceditd Fes L r r-3, C3 Return Receipt Fee Postmark O , 0 (Endoraerrrent Required) r Here ?----= O O Reetdcted (Endoreamant Requi ed ru ! ru m , m total Poe" a Fees r%- r- ° ° C3 _, S - .- . haron L Jones - -- -- -- s_..- C O . . b}v ... -° -- r- tti orPOt3wAb 7865 W. Highway 40, #150 .. Gh. stage, ZIP?4 ?•-- - `__ Ocala, FL 34482 PAO Hasler CL N qt 0 T N [ Ui G o o 00 I O M EXHIBIT R. I . L j $N A S 3 N e v I 0 0 O W ru O O O O O O Q" to cA 0 C-4 I n .? m 00 ar (D n all 1- 4 C3. L 3a N 6 P 9 N1.-, 0 O ,fa ?0 13 ? _ O m !0 70 .k P. m 13tD n M -• 03 F n 13 13 OW ?? i S c a 8 LN6-000-ZO'099L NSd (es/eney) 90021snBnV'O096 uuoj S 'Aiinbu! us B,,,,w uegm 11 lussaid PUB Idleeei slq; GABS :1pV18OdN llew pue eBelsod 4llM logel xijle pus 4oslep 'Pepeeu iou 91018081 ifty pe9llre0 ayl uo ? owlsod ell •Bupputulsod iol eogjo lsod 841 la ? -lus e4l wesaid esseld 'pensep s! ld!eoea 11811Y peyllJe0 843 uo Vewlso a l! i e4l 47lM eoeldllaw eta ?ijew jo as o e "NaA?( 8pe?1esy luewesaopue 9 a MM s e )I I 41, asJAPV 7u a pezpo4lne s,eeseejppa pP 43 0l peloulsaj eg taw ALaA!!ep 'eel ieuoglppe ue joj i si idlsoei 1lsW pe!jl>Je jno?t uo aawisod Qsdsn Penbei JaAlvm e 9 oijeoee of '.powenbea idweW wrgaa !eoeelldlpw ewOpU3j '001 41 J ki 4oaAe geo!ldde ppe Pue elogle a4l Ol 4!86 uuoj Sd) 019061: wnle a pua ! ow0woo "d 'e?A?es ldleoey wryey u jo load ep!Aad of pelsenbei ?C d leJgo of tieNlsp eq awl reoey wnley a 'eel leuolllppe us ?oj I Jo j 1!a '1!eW pejem!Bea jo Mnsul jeplswo eseeld 'selgenleA W PGMIJGO twm a3alA0ad SI 30VN3A00 3ONVEinSN! ON s e ?11ew leuopeW84u! to ssep Aua col elg811ens 1ou $1119" P91Pu80 ¦ ®I! W lsu pewgwoo eq A*1NO AM [levy Pe9lu90 ¦ *- nuspuluw817us1rodu4 Y0M sJ8eh Oml col 80uueS l%sod 84l Ag WON JUMIGp 10 PJ039J V ¦ eoe!dl!aw .inoA jol jegguepl enb!un V o idleoel Bull!ow V ¦ _ :SGPiAad 118W P81111189 -EXHIBIT 8, H O O v ?u 0 ao O P) al tr H Ul (D A) ij rt r x C4 F'- F4 W 0 OD P) (D N "C, in O N Lyl O C- 0 oS ? CS M :0 -4 iv°O ?M? z?r" C- yr' m !?, A >0O . Z M ru ru nj ru ??? M1 N Q,, Q' AL USE -0 ?v cc cc O O pis $ -? C3, O COMW Fes O PAcW Fes Poetmerk C3 C O (Endt Required) Here O P-ftM Delmy Fes p 0 (Endonsmem Required) nj nj ?. m O TOW Poatspe s Feee $ .??. ?..? r- P- o 0 ----- ---- .. ... Robert J. Jones C3 v a-t )io; N r- aPoamw 7865 W. Highway 40, #150 --- Ocala, FL 34482 --------------- Ha51er C 3 to " N a Q c7} 03 fM? 3 .a N a N rn ?o 00 o ' M 8 mw ? Rio cD EXHIBIT 13 3' W A"- ? N O ca c 2 1 C C 1 LL ? 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O O N C 0 'o . m 7 O O C O n C D' 3 om? ? c G O N d o ? n inm mom= m m° m° a> m > O 4.mw c? 3 N c m m w 'm 3 m n m d ? o3 2 3 v n 3 n O n `0 n D CL CD x y .y dn'm 3 m vCD CC., r L.4 3 -0, -0, n? o?3 9D n x D-' Co 3 , a vow d ?d r m CD n 0'O 3 a o m _,?^ -? 3 O m m 3 m 10 O m O n o ?` C m m Co N of y= fA 50 .. x . a. 2 m?cm'? OO ?w N (n C LD CJ O .-i N Q ` ? O O n> j m QCj CD D m y om?;3' 3 m m l Z N O1 n m3d3 m S ? ? 3 y O 0 0 C c 3 y -n (n m 2 01 m m av?? m o W o 3 y3m a o N N o tn m Q EXH 113 IT B x L m? - n ] MARK J. UDREN, ESQUIRE NJ MANAGING ATTORNEY TINA MARIE RICH OFFICE ADMINISTRATOR UDREN LA W OFFICES, P. C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD SUITE 200 CHERRY HILL, NEW JERSEY 08003-3620 856. 669. 5400 FREDDIE MAC PENNSYLVANIA DESIGNATED COUNSEL CAA: 656. 66Y. Prothonotary of Cumberland County Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 Re: Deutsche Bank National Trust Company, as Trustee of the Home Equity Mortgage Loan Asset-Backed Trust Series INABS 2006-E, Home Equity Mortgage Loan Asset-Backed Certificates, Series INABS 2006-E under the Pooling and Servicing agreement dated Dec 1, 2006 VS. Robert J. Jones & Sharon L. Jones Cumberland County C.C.P. No. 10-2608 Dear Prothonotary: In connection with the above file, enclosed please find Praecipe to File Proof of Service for filing. Also enclosed is an extra copy of the Praecipe to be time stamped and returned in the enclosed self-addressed stamped envelope. Thank you for your assistance with this matter. incerely yours, end arty Foreclosure Specialist \ V" /hac Enclosure 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 of the :CIVIL DIVISION Home Equity Mortgage Loan :Cumberland County Asset-Backed Trust Series INABS 2006-E, Home Equity Mortgage Loan Asset-Backed :NO. 10-2608 Certificates, Series INABS 2006-E under the Pooling and Servicing agreement dated Dec 1, 2006 Plaintiff V. Robert J. Jones Sharon L. Jones Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: January 77 , 2011 UDREN LAW OFFIC C. BY: A o ey f laintiff 36 W IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION .Deutsche Bank National Trust Company, as Trustee of the Home Equity Mortgage Loan Asset-Backed Trust Series NO. 10-2608 INABS 2006-E, Home Equity Mortgage Loan Asset-Backed Certificates, Series ZNABS 2006-E under the Pooling and Servicing agreement dated Dec 1, 2006 Plaintiff V. Robert J. Jones Sharon L. Jones Defendant(s) O R D E R AND NOW, this 841-- day of +J?CErhb?'J1 _ ')n, n „r .., 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), Sharon L. Jones and Robert J. Jones, 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), Sharon L. Jones and Robert J. Jones at 30 Wagner Drive Carlisle, PA 17013, 7865 W Highway 40, #150 Ocala, FL 34482 and by posting the mortgaged premises located at 30 Wagner Drive Carlisle, PA 17013. BY THE COURT: EXH181-T r- Deutsche Book National Trust Company, as Trustee, et. al., Plaiatifgs) vs. Robert J. Jones & Sharon L. Jones, et. aL, Defeednat(s) UDREN LAW OFFICES 1%IL Ifenai Crommarty 111 Woodcrest Rd., Ste 200 Cherry Hill, NJ 08003-3620 Service of Process by APS International, Ltd. 1-800-328-7171 APS International Plaza 7800 Glenroy Rd. Minneapolis, MN 55439-3122 APS File 0: 1083534901 AFFIDAVIT OF SERVICE - Individual Service of Proems on: -Robert J. Jones, By Posting Court Case No. 1()-2603 State of: rliG! ss. - County o Name of Server: , undmi ' fined, being duly sworn, deposes and says that at the time of service, s/he was of legal age and w•as not a party to this action; Date/7 itne of Service: that on the/day of , 20 0_, at ?i- Sclock eM Place of Service: at 30 Wagner Drive in ,Carlisle, PA .17013 Documents Served: _ the undersigned served the documents described as: Notice of Sheriff's Sale of Real Property w/ Order Service of Process on: A true and correct copy of the aforesaid document(s) was served on: Person Served, and Robert J. Jones, By Posting Method of Service: By personally delivering them into the hands of the person to be served . X By delivering them into the hands of of suitable age, who verified, or who upon questioning stated, that he/she resides witthn Robert J. Jones, By Posting at the place of service, and whose relationship to the person is: Description of Person The person receiving documents is described as follow Receiving Documents: s: Sex ; Skin Color ;Hair Color ;facial Hair Approx. Age Approx. Height Approx. Weight X To the best of my knowledge and belief said person was not d , engage in the US Military at the time of service. Signature of Server: Undersigned declares under penalty of perjury that t oregoing is and correct. tg o rv abl, ion XP res) APPS International, Ltd. COMMONWEALTH OF PENNSYLVANIA St A .?.,( Notarial Seal M. Michelle Guyton, Notary Public Carlisle Boro, Cumberland County My Commission Expires July 1, 2012 4?n a >r Penns r!+ ^ , z A.ssodation of Notaries Deutsche Book National Trust Company, as Trestee, et. al., Phindlf(s) vs. Robert J. Jones & Sharon L. Jones, et. A. Defendant(s) UDREN LAW OFFICES 111s. Heaai Cream", I I I Wooderest Rd., Ste. 200 Cherry Hill, NJ OM3-3620 Service of Process by APS International, Ltd. 1-SM32&7171 APS International Plaza 7800 Glearoy Rd. Minneapolis, MN 55439-3122 APS File tf: 1083534011 AFFIDAVIT OF SERVICE -- Individual Service of Process on: -Sharon L. Jones, By Posting Court Case No. 10-2608 State of: as. -- --- - - County o Name of Server: , undersigned, being duly sworn, deposes and says that at the time of service, s/he was of legal age and was not a party to this action; DateMme of Service: that on the ,? des of y + 2o/lL, at Y----ao'clock /o M Place of Service: at 30 Wagner Drive in Carlisle, PA 17013 Documents Served: the undersigned served the documents described as: Notice of Sheriff's Sale of Real Property w/ Order Service of Process on: A true and correct copy of the aforesaid document(s) was served on: Person Served, and Sharon L. Jones, By Posting Method of Service: By personally delivering them into the hands of the person to be served . By delivering them into the hands of 349 597z V1") of suitable age, who verified, or who upon questioning stated, that he/she resides with Sharon L. Jones, By Posting at the place of service, and whose relationship to the person is: Description of Person The person receiving documents is described as foll Receiving Documents: ows: Sex ;Skin Color Hair Color ; Facial Hair Approx. Age ; Approx. Height Approx. Weight To the best of my knowledge and belief, said person was not engaged in the US Military at the time of service. Signature of Server: Undersigned declares under enalt f p y o perjury Sub d s to before me I that the forego ing is a and correct. ? of crv APPS International, Ltd zX lw {'o"IMONAEALTH OF PENNSYLVANIA Notarial sea' M. Michelle Guyton, Notary Public Carlisle Boro, Cumberland County My Commission Expires duly 1, 2012 4 Ronny R Anderson Sheriff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Jody S Smith Chief Deputy> Richard W Stewart Solicitor TF; Deutsche Bank National Trust Company vs. I Case Number Robert J. Jones (et al.) 2010-2608 SHERIFF'S RETURN OF SERVICE 10/13/2010 10:17 AM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on 10-13-10 at 1015 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 Robert J. & Sharon L. Jones, located at, 30 Wagner Drive, Carlisle, Cumberland County, Pennsylvania according to law SHERIFF COST: $908.92 SO ANSWERS, October 27, 2010 RON R ANDERSON, SHERIFF ?WHfSI-r a ;ci Couo*.ySuite Shen`(, Te?eosott. inc.