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HomeMy WebLinkAbout10-3153e' Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 238762 BANK OF AMERICA, NATIONAL ASSOCIATION AS SUCCESSOR BY MERGER TO LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF OCTOBER 1, 2006, GSAMP TRUST 2006-HE7 4828 LOOP CENTRAL DRIVE HOUSTON, TX 77081-2226 Plaintiff V. DAVID E. MEASE LAURIE A. MEASE 160 EASY ROAD CARLISLE, PA 17013-9595 Defendants RLED-4DIC OF THE PR `111"tIMARY 20101 Y 13 FM 1: 04 Clrtt4 '? i r' - vNZ) Lvii i"TV ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. 10-31-5Z 0'-"i ( Iexi. CUMBERLAND COUNTY Q-5 *qa.oo P r3 Am/ W 9q:9 q15 e')'4)985 File #: 238762 .. NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File #: 238762 I. Plaintiff is BANK OF AMERICA, NATIONAL ASSOCIATION AS SUCCESSOR BY MERGER TO LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF OCTOBER 1, 2006, GSAMP TRUST 2006-HE7 4828 LOOP CENTRAL DRIVE HOUSTON, TX 77081-2226 2. The name(s) and last known address(es) of the Defendant(s) are: DAVID E. MEASE LAURIE A. MEASE 160 EASY ROAD CARLISLE, PA 17013-9595 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 06/23/2006 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to EQUITY ONE, INCORPORATED which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1956, Page 1720. By Assignment of Mortgage recorded 11/05/2007 the mortgage was assigned to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC which Assignment is recorded in Assignment of Mortgage Instrument No. 200741929. The PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 01/01/2010 and each month thereafter are due and unpaid, and by the terms File #: 238762 of said mortgage, upon failure of mortgagor to make such payments after a date specified 6. by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. The following amounts are due on the mortgage: Principal Balance $145,118.25 Interest $5,049.54 12/01/2009 through 05/11/2010 (Per Diem $31.17) Attorney's Fees $650.00 Cumulative Late Charges $433.60 06/23/2006 to 05/11/2010 Costs of Suit and Title Search $-5-50-00 Subtotal $151,801.39 Escrow Credit ($29183) TOTAL $151,513.56 7 8. Plaintiff is not seeking a judgment of personal liability (or an in person-am judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff File #: 238762 or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $151,513.56, together with interest from 05/11/2010 at the rate of $31.17 per diem to the date of judgment, and other costs, fees, and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. HALLINAN & SCHMIEG, LLP LJ Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheet -R. Shah-Jani, Esq., Id. No. 81760 ? J 'ne R. Davey, Esq., Id. No. 87077 auren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Attorneys for Plaintiff File #: 238762 s LEGAL DESCRIPTION ALL those certain two tracts of land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: TRACT # 1 BEGINNING at a stake on the southern side of Township Road 487, which stake is North 51 deg. 41 min. West 200 feet from a private road, and which stake is at the northeast corner of land now or formerly of Arthur J. Adams and Audrey G. Adams, his wife; thence by the southern side of said public road North 51 deg. 41 min. East 200 feet to a stake; thence by land now or formerly of Donald R. Bitner and Elaine Bitner, his wife, South 46 deg. 45 min. East 200 feet to a stake; thence by the same South 51 deg. 41 min. West 200 feet to a stake at line of land now or formerly of said Arthur J. Adams, et ux; thence by the same North 46 deg. 45 min. West 200 feet to a stake at the southern side of Township Route 487, the place of BEGINNING, in accordance with a survey of Thomas A. Neff, dated February 6, 1965. BEING the same property conveyed to John A. Rohrer and Betty M. Rohrer, his wife, by deed of Donald R. Bitner, et ux, dated August 27, 1971 and recorded in Cumberland County Deed Book 'G', Volume 24, Page 310. The said Betty M. Rohrer died on October 25, 2001. EXCEPTING FROM the above-described property, Tract #5 on plan recorded in Cumberland County Plan Book 54 at Page 69 as described in deed recorded in Cumberland County Deed Book 'J', Volume 33, Page 455. TRACT #2 File #: 238762 BEGINNING at the southern-most corner of property now or formerly of John A. Rohrer and Betty M. Rohrer, his wife, which point is also the corner of the tract now or formerly of Arthur J. Adams and Audrey G. Adams, his wife; thence along property now or formerly of John A. Rohrer and Betty M. Rohrer, his wife, North 52 deg. 24 min. East 356.27 feet to a point; thence on an arc to the right with a radius of 300 feet an arc length of 7.2 feet to a point; thence South 52 deg. 24 min. West 352.43 feet to a point; thence North 46 deg. 2 min. West 6.68 feet to a point, being the place of BEGINNING, being designated as Tract No. 6 in the Final Subdivision Plan for Gerald D. Regi and John A. Rohrer prepared by Larry V. Neidlinger, and recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 54, Page 69. BEING the same property conveyed to John A. Rohrer and Betty M. Rohrer, his wife, by deed of Gerald D. Regi, et ux, dated March 31, 1988 and recorded in Cumberland County Deed Book'J', Volume 33, Page 452. The said Betty M. Rohrer died on October 25, 2001. PROPERTY BEING; 160 EASY ROAD PARCEL# 29-06-0023-016 File #: 238762 The undersigned attorney hereby states that I am the attorney for the Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of my knowledge, information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsifications to DATE: File #: 238762 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~WtiU~~ of 4iuu(~Frlyp~~ .e~ FILE.I.~..~, «;~~ Jody S Smith Chief Deputy Edward L Schorpp Solicitor Bank of America, NA vs. David E. Mease (et al.) f - ~< 2610 i~~~~ 1 ~i ~~°i 9~ 38 ~L.14A~Ce7 7 ~Y~~~~Ef~ Case Number 2010-3153 SHERIFF'S RETURN OF SERVICE 05/14/2010 09:04 PM -Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on May 14, 2010 at 2100 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Laurie A. Mease, by making known unto Derrick Mease, Son of defendant at 160 Easy Road, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. GE LD WORTHINGT ,DEPUTY 05/14/2010 09:04 PM -Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on May 14, 2010 at 2100 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: David E. Mease, by making known unto Derrick Mease, Son of defendant at 160 Easy Road, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $49.40 May 17, 2010 GERALD WORTHINGTO ,DEPUTY SO ANSWERS, ,/ RON ~ R ANDERSON, SHERIFF (=i Gau ,tgSulte Shenff, T~elac,uft, fnc. `r THc. P ,.. ~ .. ~' ?D14 J~i-~ -g ~~ t ~ ~ 1 PE~d".y~Yi ~~;~.~,i~a Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 ATTORNEY FOR PLAINTIFF One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 BANK OF AMERICA, NATIONAL COURT OF COMMON PLEAS ASSOCIATION AS SUCCESSOR BY . MERGER TO LASALLE BANK CIVIL DIVISION NATIONAL ASSOCIATION, AS . TRUSTEE UNDER THE POOLING NO. 10-3153-CIVIL-TERM AND SERVICING AGREEMENT . DATED AS OF OCTOBER 1, 2006, CUMBERLAND COUNTY GSAMP TRUST 2006-HE7 Plaintiff vs. DAVID E. MEASE LAURIE A. MEASE Defendant(s) PHS #: 238762 PRAECIPE TO SUBSTITUTE VERIFICATION TO CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly substitute the attached verification for the verification originally filed with the complaint in the instant matter. Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff r ~ ~ ,h , ^ Lawrence T. Phelan, Esq., Id. No. 32227 ^ Francis S. Hallinan, Esq., Id. No. 62695 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 Date: 6-7-10 PHS #: 238762 VERIFICATION Diane Dixon Assistant Vice President hereby states that he/she is of LITTON LOAN SERVICING, LP ATTORNEY IN FACT FOR BANK OF AMERICA, NATIONAL ASSOCIATION AS SUCCESSOR BY MERGER TO LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF OCTOBER 1, 2006, G5AMP TRUST 2006-HE7, in this matter, that heJshe is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Name: Diane Dixon ~IAY $ 7 24i0 DATE: Title: Assistant Vice President Company: LITTON LOAN SERVICING, LP File #: 238762 Name: MEASE Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 _...Jaya. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 BANK OF AMERICA, NATIONAL ASSOCIATION AS SUCCESSOR BY MERGER TO LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF OCTOBER 1, 2006, GSAMP TRUST 2006-HE7 Plaintiff vs. DAVID E. MEASE LAURIE A. MEASE Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO.10-3153-CIVIL-TERM CUMBERLAND COUNTY CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of Plaintiff s Praecipe to attach Verification of Complaint was sent via first class mail to the following on the date listed below: PHS #: 238762 DAVID E. MEASE 160 EASY ROAD CARLISLE, PA 17013-9595 LAURIE A. MEASE 160 EASY ROAD CARLISLE, PA 17013-9595 __ __ __ _ Phelan Hallinan & Schmieg, LLP Atto e for Plaintiff C By: ` ^ Lawrence T. Phelan, Esq., Id. No. 32227 ^ Francis S. Hallinan, Esq., Id. No. 62695 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 Date: 6-7-10 PHS #: 238762 4 ~, FILED ~ "~,,.~~n` p„~?Y Z~Sd J`.~~~ 28 °~ ~~ 'Z~ rY :~,~~.,~ ~. Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 ~lieetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 BANK OF AMERICA, NATIONAL ASSOCIATION AS SUCCESSOR BY MERGER TO LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF OCTOBER 1, 2006, GSAMP TRUST 2006-HE7 vs. DAVID E. MEASE LAURIE A. MEASE Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No.10-3153-CIVIL-TERM ~ I~. 00 P b A7'M c,~9~'7~4q L'~ ay y 3(v~( ~, PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against DAVID E. MEASE, and LAURIE A. MEASE, Defendant(s) 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 $151,513.56 Interest - 05/12/2010 to 06/22/2010 $1,309.14 TOTAL $152,822.70 I hereby certify that (1) the Defendant's last known residence is 160 EASY ROAD, CARLISLE, PA 17013-9595, and (2) that notice has been given in accordance with Rule 237.1, copy attached. Lawrence T. Phelan, Esquire Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire eetal R. Shah-Jani, Esquire Jenine R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Joshua I. Goldman, Esquire Courtenay R. Dunn, Esquire Andrew C. Bramblett, Esquire Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: o PHS # 238762 PROTHONOTARY Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 BANK OF AMERICA, NATIONAL ASSOCIATION AS SUCCESSOR BY MERGER TO LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF OCTOBER 1, 2006, GSAMP TRUST 2006-HE7 vs. Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No.10-3153-CIVIL-TERM DAVID E. MEASE LAURIE A. MEASE VERIFICATION OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or it Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant DAVID E. MEASE is over 18 years of age and his last known residence is 160 EASY ROAD, CARLISLE, PA 17013-9595. (c) that defendant LAURIE A. MEASE is over 18 years of age and her last known residence is 160 EASY ROAD, CARLISLE, PA 17013-9595. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. U Lawrence T. P~la~'Esq., Id. No. 32227 ^ Francis S. Hallinan, Esq., Id. No. 62695 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ~heetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 Attorney for Plaintiff (Rule of Civil Procedure No. 236) -Revised BANK OF AMERICA, NATIONAL ASSOCIATION AS SUCCESSOR BY MERGER TO LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF OCTOBER 1, 2006, GSAMP TRUST 2006-HE7 vs. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No.10-3153-CIVIL-TERM DAVID E. MEASE LAURIE A. MEASE Notice is given that a Judgment in the above captioned matter has been entered against you on By: If you have any questions concerning this matter please contact: ^ Lawrence T. Phelan, Esq., Id. No. 32227 ^ Francis S. Hallman, Esq., Id. No. 62695 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ udith T. Romano, Esq., Id. No. 58745 [~Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 Attorney or Party Filing 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 * * THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLYRECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TD BEAN ATTEMPT TO COLLECTA DEBT, BUT ONLYENFORCEMENT OFA LIENAGAINST PROPERTY. ** BANK OF AMERICA, NATIONAL ASSOCIATION AS SUCCESSOR BY MERGER TO LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF OCTOBER 1, 2006, GSAMP TRUST 2006-HE7 Plaintiff v DAVID E. MEASE LAURIE A. MEASE Defendant(s) TO: LAURIE A. MEASE 160 EASY ROAD CARLISLE, PA 17013-9595 DATE OF NOTICE: June 4, 2010 COURT OF COMMON PLEAS CTVII, DTVISON NO. 10-315 3-CIVIL-TERM CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IlVIPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A VVRI"I'1'EN APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. PHS # 238762 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 HIItING 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. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 By: 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Jy~ith T. Romano, Esq., Id. No. 58745 heetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallinan &Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Lawrence T. Phel Es ., Id. No. PHS # 238762 BANK OF AMERICA, NATIONAL ASSOCIATION AS SUCCESSOR BY MERGER TO LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF OCTOBER 1, 2006, GSAMP TRUST 2006-HE7 Plaintiff DAVID E. MEASE LAURIE A. MEASE Defendant(s) TO: DAVID E. MEASE 160 EASY ROAD CARLISLE, PA 17013-9595 DATE OF NOTICE: June 4, 2010 COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-3153-CIVIL-TERM CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IIVII'ORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. PHS # 238762 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. Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION 1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle, PA 17013 2 LIBERTY AVENUE (717) 240-6195 CARLISLE, PA 17013 (717) 249-3166 By: Lawrence T. Ph ., Id. No. 32227 Francis S. Hallman, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. X8745 ~~eetal R. Shah-Jani, Esq., Id. No. 81760 ~Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallman &Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 238762 UDREN LAW OFFICES, . P C: ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN- '&SQUIRE ID #04302 STUART .WINNEG-,—EBQ.ITIBS ID #45362 _ - LORRAINE -DOYLE-, _-ESQUIRE. '-' ID 434 5-7 6- J. BRAUNSTEIN, ESQUIRE_- ID. #90675 HARRY B. REESE ESQUIRE - ID #310501 __ ELIZABETH WASSALL, ESQUIRE - ID#77788 KATHERINE E. KNOWLTON, ESQUIRE. ID#311713 WOODCREST CORPORATE CENTER 123 WOODCREST ROAi�:---�-U3"TE 200 _ _ .- CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingo@udren.cam BANK OF AMERICA, NATIONAL COURT OF COMMON PLEAS ,.., _ : ASSOCIATION AS SUCCESSOR BY CIVIL DIVISION MERGER TO LASALLE BANK : CUMBERLAND County MW =c NATIONAL ASSOCIATION, AS - TRUSTEE UNDER THE POOLING AND _ __-_ SERVICING-AGREEMENT DATED AS , NO. 10-3153-CIVIL-TERM r OF OCTOBER 1, 2006, GSAMP .'. TRUST 2006= - - - UDRENLAW OFFICES, P.C. -- _ - BY HAR4YA REESE, ESQUIRE PA 1D 310502 - --- --- _ 13020456-1 _ _ PHELAN HALLINAN& SCHMIEG,LLP Attorney for Plaintiff /attomeyName/ 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 BANK OF AMERICA,NATIONAL ASSOCIATION AS SUCCESSOR BY MERGER TO LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT COURT OF COMMON PLEAS DATED AS OF OCTOBER 1, 2006, GSAMP TRUST 2006-HE7 CIVIL DIVISION Plaintiff CUMBERLAND COUNTY VS. No. 10-3153-CIVIL-TERM DAVID E. MEASE e LAURIE A. MEASE r '' -<> CD Defendant WITHDRAWAL OF APPEARANCE f To the Prothonotary: Kindly withdraw my appearance on behalf of Plaintiff,BANK OF AMERICA, NATIONAL ASSOCIATION AS SUCCESSOR BY MERGER TO LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF OCTOBER 1, 2006, GSAMP TRUST 2006-HE7. Phelan Hallinan& Sc ieg, LLP Date: .Zlh4 By: Attorney for Plaintiff John Y.Kdit*Eq„kL Na 3W7 PHS#238762 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 Bank of America,National Association as COURT OF COMMON PLEAS successor by merger to LaSalle Bank CIVIL DIVISION National Association, as trustee under the Cumberland County Pooling and Servicing Agreement dated as of October 1, 2006, GSAMP Trust 2006- MORTGAGE FORECLOSURE HE7 Plaintiff v NO. 10-3153 Civil Term cjj DAVID A.MEASE; LAURIE A.MEASE; et p al ' Defendant(s) PRAECIPE TO WITHDRAW JUDGMENT AND DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly mark the above captioned matter as JUDGMENT WITHDRAWN and ACTION DISCONTINUED WITHOUT PREJUDICE, upon payment of your costs only. DATED: 06 (4 /3 UDREN LAW OFFICES, P.C. Attorney for Plaintiff J. Eric Kishbaugh, Esquire PA ID 33078 MJU#: 13020456 CASE#: 13020456-1