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Home My WebLink About10-3540(I 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 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 .' ' WOODCREST CORPORATE CENTER - ? n -n 111 WOODCREST ROAD, SUITE 200 = - CHERRY HILL, NJ 08003-3620 0 856-669-5400 pleadings@udren.com Deutsche Bank National Trust :COURT OF COMMON PLEAS Company, as Trustee for ABFC =CIVIL DIVISION 2005-AQ1 Trust, Asset-Backed Certificates, Series 2005-AQ1 :Cumberland P.O. Box 961730 Irving, TX 75063-1730 Plaintiff V. Betty J. Baker County 954 Hummel Avenue € NO. 10 - 3544 Lemoyne, PA 17043 Defendant(s) 0-ivil Term COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL O SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. 4.9d.00 PA e* ts%om e9aw LAWYERS REFERRAL SERVICE Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las 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 provisioner 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 O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. Plaintiff is the legal holder of the Mortgage that is the subject of this action. Current assignments of mortgage of record are as follows. Assignor: Ameriquest Mortgage Company Assignments of Record to: Deutsche Bank National Trust Company, as Trustee for ABFC 2005-AQ1 Trust, Asset-Backed Certificates, Series 2005-AQ1 under the Pooling and Servicing Agreement Dated June 1, 2005 Recording Date: 02/13/2009 Instr. No.: 200903955 Plaintiff is in the process of formalizing the assignment of mortgage in its favor for recording. 2. Defendant (s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant (s) , Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant (s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 954 Hummel Avenue MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of Lemoyne COUNTY: Cumberland DATE EXECUTED: 02/07/2005 DATE RECORDED: 02/17/2005 BOOK: 1897 PAGE: 2296 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. I ' 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 05/19/10: Principal of debt due $68,237.06 Unpaid Interest at 9.95% from 12/01/09 to 05/19/10 (the per diem interest accruing on this debt is $18.60 and that sum should be added each day after 05/19/10) 3,182.43 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $271.83 and that sum should be added on the first of each month after 05/19/10) 527.68 Late Charges (monthly late charge of $36.98 should be added in accordance with the terms of the note each month after 05/19/10) 517.72 Suspense Balance (430.96) NSF Charges 130.00 Recoverable Balance 200.00 Attorneys Fees (anticipated and actual to 5% of principal) 3,411.85 TOTAL $76,380.78 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 $76,380.78 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: 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 Exhibit A Legal Description ALL THAT CERTAIN piece or parcel of land situate in the. Borough of Lemoyne, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the southern line of Hummel Avenue at the distance of 20 feet measured in an easterly direction from the line dividing Lots No. lb and 17, Block "F", in the hereinafter mentioned Plan of lots; thence in a southerly direction along lands of Raymond S. Zimmerman, 140.45 feet, more or less, to a 15 foot alley; thence in a westerly direction along sail alley, 20 feet, more or less, to a point thence in a northerly direction along the line running through the center of the partition wall of the double brick dwelling house erected in part on the herein described lot,140A5 feet, more or less, to a point on the southerly line of Hummel Avenue; thence in an easterly direction along Hummel Avenue 20 feet, more or less, to a point, the place of BEGINNING. Tax ID No. 12-22-0824-228 For informational purposes only - Property also known as: 954 Hummel Ave. Lemoyne, PA 17043-1737 R.epon Date 0512412010 A URdl `?" 111111111111111111111111 February 17, 2010 7104 5400 2100 2763 9656 IIIIrI IIII III IIII III III III IIII IIII IIII II? IIII Betty J Baker 954 Hummel Avenue Lemoyne, PA 17043 F.^.u..TAKE ACT 91 NOTICE YOU HOME 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. IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE FOUR The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) maybe able to help to save your home. This notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address, and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACIO'N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIO'N OBTENGA UNA TRADUCCIO'N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRE'STAMO 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. HOMEOWNER'S NAME(S): Betty J Baker PROPERTY ADDRESS: 954 Hummel Avenue Lemoyne, PA 17043 LOAN ACCT. NO.: 4001472424 ORIGINAL LENDER: Ameriquest Mortgagor Company CURRENT LENDER/SERVICER: American Home Mortgage Servicing, Inc. EXHI'lBG u A Page two 4001472424 HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOUMAYBE 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 YOUDO NOT APPLYFOR 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 HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCYACTION - 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 CURRENTL Y PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLYAND SHOULD NOT BE CONSIDERED AS ANATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) Page three HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date): NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 954 Hummel Avenue, Lemoyne, PA 17043 IS SERIOUSLY IN DEFAULT because: 4001472424 A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payments from 12/01/2009: (b) Late charge(s): (c) Other charge(s): NSF and Advances (d) Less: Credit Balance (e) Total amount required as of 02/16/2010: $2,664.42 $406.78 $210.00 $430.96 $2,850.24 HOW TO CURE THE DEFAULT - You may cure this default within THIRTY (30) DAYS from the date of this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,850.24, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check, or money order made payable and sent to: American Home Mortgage Servicing, Inc. 1525 S. Beltline Rd. Coppell, TX 73019 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of date of this Notice, the lender intends to exercise its right to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender 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. 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) DAYperiod and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying 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 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 five (5) 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. Page four 4001472424 HOW TO CONTACT THE LENDER Name of Lender: American Home Mortgage Servicing, Inc. Address: 1525 S. Beltline Rd. Coppell, TX 75019 Telephone Number: 1-877-304-3100 Fax Number: 1-866-497-1263 Contact Person: Brandon Wirth, Glenda Mathews E-mail Address: Brandon.wirth@ahmsi3.com, Glenda.mathews@ahmsi3.com EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff s Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may not 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. YOUMAYALSO HAVE THE RIGHT. ° TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. ° TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. ° TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) ° TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. ° TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. ° TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CAN BE FOUND ON PAGES S-7. American Home Mortgage Servicing, Inc. is attempting to collect a debt, and any information obtained will be used for that purpose. Federal law gives you thirty days after you receive this letter to dispute the validity of this debt or any part of it. Unless you dispute the debt within that 30 day period, we will assume that it is valid. If you notify us in writing at the address below within the thirty day period that the debt, or any portion thereof, is disputed, we will: 1) Provide to you verification of the debt or a copy of any judgment entered against you. 2) Provide to you the name and address of your original creditor, if the original creditor is different from the current creditor. Sincerely, American Home Mortgage Servicing, Inc. American Home Mortgage Servicing, Inc. 1525 S. Beltline Rd. Coppell, TX 75019,1-877-304-3 100 * Indicates Counties Serviced Acorn Housing Corporation 846 North Broad Street Philadelphia, PA 19130 (215) 765-1221 'Bucks, Chester, Delaware, Montgomery, Philadelphia Action Housing Inc 425 6th Avenue, Suite 950 Pittsburgh, PA 15219 (412) 281-2102 'Allegheny, Beaver, Butler, Fayette, Greene, Washington, Westmoreland Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 (717) 334-1518 'Adams, Cumberland, Franklin, York Advocates for Financial Independence 1806 S Broad Street, Suite 1B Philadelphia, PA 19145 (215) 389-2810 'Philadelphia Advocates for Financial Independence 202 East Hinkley Avenue Ridley Park, PA 19078 (215) 389-2810 'Delaware Allegheny County Acorn 5907 Penn Avenue, Suite 300 Pittsburgh, PA 15206 (412) 441-6551 'Allegheny American Credit Counseling Institute 21 S Church Street West Chester, PA 19380 (888) 212-0741 'Chester American Credit Couseling Institute 526-528 Dekalb Street Norristown, PA 19401 (610) 971-2210 (888) 212-6741 'Montgomery, Delaware American Credit Counseling Institute 530 W Street Road, Suite 201 Warminster, PA 18974 (215) 444-9429 (888) 212-0741 'Bucks, Montgomery, Philadelphia Amedcan Credit Counseling Institute 937 North Hanover Street Pottstown, PA 19460 (888)212.6741 'Barks, Bucks, Montgomery American Credit Counseling Institute 229 East Chestnut Street Coatesville, PA 19320 (888) 212-6741 'Chester, Lancaster Amedcan Financial Counseling Services 871 N. Easton Road Glenside, PA 19038 (267) 228-7903 'Mifflin American Financial Counseling Services 405 West Germantown Pike Norristown, PA 19403 (267) 228-7903 'Mifflin, Montgomery American Financial Counseling Services 2880 Bergey Road Suite 4 Hatfield, PA 19440 (267) 228-7903 'Barks, Chester, Montgomery American Financial Counseling Services 175 Strafford Avenue, Suite One Wayne, PA 19087 (610) 971-2210 (888) 212-0741 'Bucks, Chester, Delaware, Mongomery, Philadelphia American Financial Counseling Services 906 Penn Avenue Wyomissing, PA 19610 (267) 228-7903 (800) 490-3039 'Barks American Financial Counseling Services 871 N. Easton Road Glenside, PA 19038 (267) 228-7903 `Montgomery American Financial Counseling Services 1917 Welsh Road Philadelphia, PA 19115, PA 19610 (267) 228-7903 'Bucks, Montgomery, Philadelphia American Red Cross - Hanover Chapter 529 Carlisle Street Hanover, PA 17331 (717) 637-3766 'Adams, Franklin, York American Red Cross of Chester 1729 Edgemont Avenue Chester, PA 19013 (610) 874-1484 'Chester, Delaware APM 2147 Norht Sixth Street Philadelphia, PA 19122 (215) 235-6788 'Chester, Delaware, Philadelphia, Bucks Armstrong CO Community Action Agency 124 Armsdale Road, Suite 211 Kittanning, PA 16201 (724) 548-3405 'Armstrong Base, Inc. 447 South Pdnoe Street Lancaster, PA 17603 (717) 392-5467 'Lancaster Blair County Community Action Agency 2100 6th Avenue, Suite 102 P.O. Box 1833 Altoona, PA 16602 (814)946.3651 *Blair Booker T. Washington Center 1720 Holland Street Ede, PA 16503 (814) 453-5744 'Crawford, Erie, Warren Bucks County Housing Group 200 West Bridge Street Morrisville, PA 19067 (866) 866-0280 'Bucks Bucks County Housing Group 2324 Second Street Pike, Suite 17 Wrightstown, PA 18940 (866) 866-0280 'Bucks Bucks County Housing Group 470 Old Dublin Pike Doylestown, PA 18901 (866) 866-0280 'Bucks Bucks County Housing Group 349 Durham Road Penndel, PA 19047 (866) 866-0280 'Bucks Bucks County Housing Group 515 West End Blvd Quakertown, PA 18951 (866) 866-0280 'Bucks Budget Counseling Center 247 North Fifth Street Reading, PA 19601 (610) 375-7866 'Barks, Chester, Schuylkill Carroll Park Community Council, Inc. 5218 Master Street Philadelphia, PA 19131 (215) 877-1157 'Chester, Detaware, Philadelphia Catholic Social Services Saint Catherine Manor 5 Knox Road Scranton, PA 18505 (570) 558-3019 'Wyoming, Wayne, Bucks, Lackawanna, Monroe, Philadelphia CCCS of Delaware Valley 1230 New Rodgers Road, Suite F1 Bristol, PA 19007 (215) 563-5665 'Bucks CCCS of Delaware Valley 1777 Sentry Parkway W, Suite 200 Blue Bell, PA 19422 (215) 563-5665 `Montgomery CCCS of Delaware Valley 280 North Providence Road Media, PA 19063 (215) 563-5665 'Chester CCCS of Delaware Valley Marshal Building 790 E Market St, Suite 170 West Chester, PA 19382 (215) 563-5665 'Chester, Bucks CCCS of Delaware Valley Catholic Social Services Building 7340 Jackson Street Philadelphia, PA 19136 (215) 563-5665 'Bucks, Philadelphia CCCS of Delaware Valley One Cherry Hill, Suite 215 Cherry Hill, PA 08002 (215) 563-5665 'Philadelphia CCCS of Lehigh Valley 3671 Crescent Court East Whitehall, PA 18052 (610) 8214011 (800) 837-9815 'Barks, Bucks, Carbon, Lancaster, Lehigh, Northhampton, Schuylkill CCCS of Northeastern PA 201 Basin Street, Suite 6 Williamsport, PA 17701 (570) 323-6627 `Centre, Clinton, Lycoming, Northumberland, Union CCCS of Northeastern PA 202 W Hamilton Avenue State College, PA 16801 (814) 238-3668 'Blair, Centre, Clearfield, Clinton, Huntingdon, Juniata, Mifflin CCCS of Northeastern PA 401 Laurel Street Pittston, PA 18640 (570) 602-2227 'Bradford, Carbon, Columbia, Lackawanna, Lycoming, Monroe, Montour, Northumberland, Pike, Sullivan, Tioga, Union, Wayne, Wyoming CCCS of Northeastern PA 411 Main Street, Suite 104 Stroudsburg, PA 18360 (570) 420-8980 *Bradford, Carbon, Monroe, Pike, Wayne CCCS of Western PA 1 North Gate Square #2 Garden Center Or Greensburg, PA 15601 (888) 511-2227 `Fayette, Greene, Indiana, Somerset, Washington, Westmoreland CCCS of Western PA 55 Clover Hill Road Dallastown, PA 17313 (888) 511-2227 *Fulton, Crawford, Lancaster * Indicates Counties Serviced CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 (888) 511-2227 'Adams, Cumberland, Dauphin, Franklin, Perry, Synder, York Chester Community Improvement Project 412 Avenue of the States P.O. Box 541 Chester, PA 19016 (610) 876-8663 'Chester, Delaware, Montgomery, Philadelphia Diversified Community Service Dixon House 1920 South 20th Street Philadelphia, PA 19145 (215) 336-3511 'Bucks, Chester, Delaware, Philadelphia Indiana Co. Community Action Prog. 827 Water Street Box 187 Indiana, PA 15701 (724) 465-2657 'Armstrong, Cambria, Clearfield, Indiana, Jefferson, Westmoreland CCCS of Western PA 312 Chestnut Street, Suite 227 Meadville, PA 16335 (888) 511-2227 'Lawrence CCCS of Western PA 41 East Chestnut Street Washington, PA 15301 (888) 511-2227 'Westmoreland CCCS of Western PA 4402 Peach Street Erie, PA 16509 (888) 511-2227 `Crawford, Erie, Warren CCCS of Western PA 524 Franklin Avenue Aliquippa, PA 15001 (888) 511-2227 `Cambria CCCS of Western PA 917 A Logan Boulevard Altoona, PA 16602 (888) 511-2227 'Armstrong, Bedford, Blair, Cambria, Centre, Clearfield, Huntingdon, Juniata, Mifflin, Union CCCS of Western PA Pullman Commerce Center 112 Hollywood Dr Butler, PA 16001 (888) 511-2227 'Butler, Clarion, Jefferson, Mercer, Venango CCCS of Western PA River Park Commons 2403 Sidney Street Pittsburgh, PA 15203 (888) 511-2227 'Allegheny Center for Family Services, Inc. 213 Center Street Meadville, PA 16335 (814) 337-8450 'Columbia, Venango Centro Pedro Clever, Inc 627 West Erie Avenue Philadelpia, PA 19140 (215) 227-7111 'Philadelphia Comm. On Econ Opportunity of Luzeme Co. 163 Amber Lane Wilkes-Barre, PA 18702 (570) 826-0510 'Carbon, Luzeme, Schuylkill, Wyoming Community Action Commission of Capital Region 1514 Derry Street Harrisburg, PA 17094 (717) 232-9757 'Cumberland, Dauphin, Franklin, Perry, Synder Community Action Committee of the Lehigh Valley 1337 East Fifth Street Bethlehem, PA 18015 (610) 691-5620 'Barks, Carbon, Lehigh, Monroe, Northhampton Community Action Development Comm CADCOM 113 E Main Street Norristown, PA 19401 (610) 277-6363 'Montgomery Community Action Southwest 150 W Beau Street, Suite 304 Washington, PA 15301 (724) 225-9550 `Monroe Community Action Southwest 58 E Greene Street Waynesburg, PA 15370 (724) 852-2893 'Allegheny, York, Fayette, Greene, Washington, Westmoreland Comm. on Econ. Opportunity of Luzeme County 163 Amber Lane WilkesBarre, PA 18702 (570) 826-0510 (800) 822-0359 'Wyoming Congreso 216 West Somerset Street Philadelphia, PA 19133 (215) 763-8870 'Philadelphia Council of Spanish Speaking Organization 705-09 North Franklin St Philadelphia, PA 19123 (215) 627-3100 'Philadelphia Credit Counseling Center 832 Second Street Pike Richboro, PA 18954 (215) 396-1880 'Bucks Fair Housing Partnership of Greater Pittsburgh, Intercultural Family Services Inc. Inc. 4225 Chestnut Street 2840 Liberty Ave., Suite 205 Philadelphia, PA 19104 Pittsburgh, PA 15222 (215) 386-1298 (412) 391-2535 'Philadelphia 'Allegheny Fayette Co. Community Action Agency Inc 137 North Beeson Avenue Uniontown, PA 15401 (724) 437-6050 'Fayette, Somerset FOB CDC 1201 West Only Avenue Philadelphia, PA 19141 (215) 549-8755 'Bucks, Chester, Delaware, Philadelphia Garfield Jubilee Associates 5138 Penn Avenue Pittsburgh, PA 15224 (412)665.5200 'Allegheny Germantown Settlement 5538 Wayne Avenue Bldg C Philadelphia, PA 19144 (215) 849-3104 'Bucks, Chester, Delaware, Montgomery, Philadelphia Greater Erie Commun. Action Committee 18 West 9th Street Erie, PA 16501 (814) 459-0581 'Crawford, Erie, Venango, Warren HACE 167 W Allegheny Ave., 2nd Floor Philadelphia, PA 19140 (215) 426.8025 'Bucks, Chester, Delaware, Philadelphia Hispanic Alliance for Community Advancement 2740 North Front Street Philadelphia, PA 19133 (215) 667-8932 'Monroe Housing Assoc. of Delaware Valley 658 North Watts Street Philadelphia, PA 19123 (215) 978-0224 'Philadelphia, Monroe Housing Opportunities of Beaver Co. 320 College Avenue, Unit 1 Beaver, PA 15009 (724) 728-7511 'Beaver, Lawrence Housing Partnership of Chester County 41 West Lancaster Avenue Downingtown, PA 19335 (610) 518-1522 'Chester, Delaware, Montgomery Korean Comm. Develop. Services Center 6055 North 5th Street Philadelphia, PA 18505 (215)276.8830 'Philadelphia Lawrence County Social Services, Inc. 241 West Grant Street P.O. Box 189 New Castle, PA 16103 (724) 658-7258 'Lawrence Liberty Resources 714 Market Street, Suite 100 Philadelphia, PA 19106 (215) 634-2000 'Philadelphia Loveship, Inc. 2320 North 5th Street Harrisburg, PA 1711 (717) 232-2207 'Cumberland, Dauphin, Perry Lycom-Clntn Cc Comm fo Comm Action 2138 Lincoln Street P.O. Box 3568 Williamsport, PA 17703 (570) 326-0587 'Centre, Clinton, Lycoming, Union Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 (717) 762-3285 'Adams, Cumberland, Franklin, Fulton, Perry Media Fellowship House 302 South Jackson Street Media, PA 19063 (610) 565-0434 'Chester. Delaware Mon Valley Unemployment Committee 1800 West SL, 3rd Floor Homestead, PA 15120 (412) 462-9962 'Allegheny, Washington, Westmoreland Mt. Airy, USA 6703 Germantown Ave., Suite 200 Philadelphia, PA 19119 (215) 844-0021 'Philadelphia Nazareth Housing Services 301 Bellevue Road Pittsburgh, PA 15229 (412) 931-6996 'Allegheny * Indicates Counties Serviced Neighborhood Housing Services of Reading 213 N 5th St., Suite 1030 Reading, PA 19601 (610) 372-8433 'Barks Neighborhood Housing Services, Inc. 710 5th Avenue, Suite 1000 Pittsburgh, PA 15219 (412) 281-9773 'Allegheny New Kensignton Community Development 2515 Frankford Avenue Philadelphia, PA 19125 (215) 427-0350 *Warren The NORCAM Group 4200 Crawford Avenue Suite 200 Northam Cambria, PA 15714 (814) 948.4444 'Cambria, Clearfield Northern Tier Community Action Corp. 135 West 4th Street P.O. Box 389 Emporium, PA 15834 (814)4861161 *Cameron, Elk, Mckean, Potter Northwest Counseling Service 5001 North Broad Street Philadelphia, PA 19141 (215) 324-7500 *Bucks, Chester, Delaware, Montgomery, Philadelphia Nueva Esperanza 4261 North 5th Street Philadelphia, PA 19140 (215) 324-0746 'Philadelphia Opportunity Inc. 301 East Market Street York, PA 17403 (717) 424-3645 `Montgomery The Partnership CDC 4020 Market Street, Suite 100 Philadelphia, PA 19104 (215) 662-1612 'Monroe Pennsylvania Housing Finance Agency 2275 Swallow Hill Rd., Bldg 200 Pittsburgh, PA 15220 (412) 429-2842 'Allegheny PHFA 211 North Front Street Harrisburg, PA 17110 (800-) 342-2397 *Cumberland, Dauphin Philadelphia Council for Comm. Advmnt. 100 N 17th St, Suite 600 Philadelphia, PA 19103 (215) 567-7803 (800)930.4663 'Chester, Delaware, Montgomery, Philadelphia Philadelphia Senior Center 509 South Broad Street Philadelphia, PA 19147 (215) 546-5879 *Philadelphia Schuylkill Community Action 225 N. Centre Street Pottsville, PA 17901 (570) 622-1995 'Barks, Carbon, Lebanon, Lehigh, Luzeme, Northumberland, Schuylkill Shenango Valley Urban League, Inc. 601 Indiana Avenue Farrell, PA 16121 (724) 981-5310 'Crawford, Lawrence, Mercer South Philadelphia H.O.M.E.S. 1444 Point Breeze Avenue Philadelphia, PA 19146 (215) 334-4430 'Philadelphia Southwest Community Development Corp. 6368 Paschall Avenue Philadelphia, PA 19142 (215) 729-0800 `Montgomery St. Martin Center 1701 Parade Street Erie, PA 16503 (814) 452-6113 *Crawford, Erie, Venango, Warren Tableland Services Inc. 535 East Main Street Somerset PA 15501 (814) 445-9628 *Cambria, Fayette, Somerset, Westmoreland Tabor Community Services 308 E King Street, Suite 1 Lancaster, PA 17602 (717) 397-5182 (800) 788-5062 'Chester. Lancaster. Lebanon The Trehab Center of Northeastern PA 10 Public Avenue P.O. Box 366 Montrose, PA 18801 (570) 278-0338 (800) 982-4045 'Susquehanna The Trehab Center of Northeastern PA 115 SR 92S Tuckhannock, PA 18657 (570) 836-6840 (800) 982-4045 `Wyoming The Trehab Center of of Northeastern PA 1225 Main Street Honesdale, PA 18431 (570) 253-8941 (800) 982-4045 'Bradford, Sullivan, Susquehanna, Tioga, Wayne, Wyoming The Trehab Center of Northeastern PA 144 E East Avenue Wellsboro, PA 16901 (570) 724-5252 (800) 982-4045 *Tioga The Trehab Center of Northeastern PA German Street P.O. Box 389 Dushore, PA 18614 (570) 928-9667 (800) 982-4045 'Sullivan The Trehab Center of Northeastern PA The Enterprise Center 703 S. Elmer Ave., Suite M-6 Sayre, PA 18840 (570) 888-0412 (800)982.4045 'Bradford United Communities Southeast Philadelphia 2029 South 8th Street Philadelphia, PA 19148 (215) 467-0700 'Philadelphia United Neighborhood Centers of Northeastern PA 425 Alder Street Scranton, PA 18505 (570) 346-0759 'Lackawanna, Wyoming, Wayne, Luzeme Urban League of Philadelphia 1818 Market Street Philadelphia, PA 19103 (215) 561-6070 *Bucks, Delaware, Philadelphia Urban League of Philadelphia 610 Wood Street Pittsburgh, PA 15229 (412) 931-0996 *Allegheny Voices for Independence 1107 Payne Avenue Erie, PA 16503 (814) 874-0064 (800) 838-9890 `Erie Warren-Forest Counties Economic Opportunity Council 1209 Pennsylvania Ave W. P.O. Box 547 Warren, PA 16365 (814) 726-2400 *Forest, Waren West Oak Lane CDC 6259 Limekiln Pike Philadelphia, PA 1914 (215) 224-0880 `Monroe 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 A r?r1f9 Attorneys fdr 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 UD1tEN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF `~ MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 20 0 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingst~udren.com Deutsche Bank National Trust ?COURT OF COMMON. PLEAS Company, as Trustee for ABFC :CIVIL DIVISION 2005-AQ1 Trust, Asset-Backed :Cumberland County Certificates, Series 2005-AQ1 P.O. Box 961730 :MORTGAGE FORECLOSURE n ~ -- Irving, TX 75063-1730 ~ ~ Plaintiff _ _..~. - , _ . _ _ c __ _ ; , . -~ __~' ~ C.. r .:: ~ ~ i ~:_:: Betty J. Baker €NO. 10-3540 N W c W 954 Hummel Avenue .p-,,- Lemoyne , PA 17 0 4 3 ~ `~~ Defendant (s) - ~~ ~r_> PRAECIPE FOR JUDGMENT FOR FAILURE TO v;~ i-'` ANSWER AND ASSESSMENT OF DAMAGES N~ ~' TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) Betty J. Baker 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 $76,380.78 Interest Per Complaint 1,209.00 From 05/21/2010 to 07/23/2010 Late charges per Complaint 73.96 From 05/21/2010 to 07/23/2010 Escrow payment per Complaint 543.66 From 05/21/2010 to 07/23/2010 TOTAL 578,207.40 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. UDREN LAW OFFICES, P.C. BY: DAMAGES ARE HEREBY ASSESSED AS DATE : ~~`~ /D Attorneys fd~ Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE ~~2RAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ~ 1~.0o P~ A7t~ C* (510075 2'~a~s I TED ~0~(++2 OTHY ~~(~~~~ r .~..- ~, L7DREN LAW OFFICES, P.C. MARK J. UDREN, ESQIIIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQIIIRE - ID #34576 ALAN M. MINATO, ESQIIIRB - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOIIIS A. SIMONI,. ESQUIRE - ID #2fl0869 ~AM L. RAYES, ESQIIIRE - ID #86406 MARGUERITE L. THOMAS, ESQIIIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SIIITS 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadiags~udrea.com Deutsche Bank National Trust Company, as Trustee for ABFC 2005-AQ1 Trust, Asset-Backed Certificates, Series 2005-AQ1 P.O. Box 961730 Irving, TX 75063-1730 Plaintiff v. ATTORNEY FOR PLAINTIFF c'> ~ ._ ~ ~ ~:-' p .~ "~1 ~ r~r`~; `a6: ~ ~a~~ ~`{ _l.. rrt "~" r ~ .~ r-- + ~.~ .r. t~ ~'.~ ~' ~~~ ~- ~ °~_ :y ~ .._ ~ IT1 .• ~ ~R ~ „ CJ ' W y COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County Betty J. Baker (~ ~, 954 Hummel Avenue € NO . ~ d r ~`3F0 L:~tv~ l lP.l'M~ Lemoyne, PA 17043 Defendant(s) _ COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if~you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOII SHOVED TAKE THIS PAPER TO YOUR LAWYER AT ONCB. 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 YOII CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO BLIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. l ~~~ ~ ~~ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewar# Solicitor ~~tr+~'? ~ +~w1~.~~d A '~:~ :~ ~;~.,;~.r~,~ x;. OFfIGE.4F ~E 6~Rir-~ Deutsche Bank National Trust Company Case Number vs. Betty J. Baker 2010-3540 SHERIFF'S RETURN OF SERVICE 08/14/2010 07:18 PM -Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on June 14, 2010 a# 1915 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Betty J. Baker, by making known unto herself personally, at 954 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing tc her personally the said true and correct copy of the same. ~~~~ TIM LACK, DEPUTY SHERIFF` COST: $58.80 June 16, 2010 SO ANSWERS, .~.. RON R ANDERSON, SHERIFF (c? CamlaSWta Sherilt. Teleosoft. Inc. UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #345?6 ALAN M. MINATO, ESQUIRE - ID #75660 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITB L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY BILL, NS 06003 856-669-5400 #1DQ50394-Z Deutsche Bank National Trust Compamy, as Trustee for ABFC 2005-AQ1 Trust, Asset- 8acked Certificates, Series 2005-AQ1 Plaintiff v. Betty J. Baker Defendant (s) TO: Bettyy J. Baker 954 Hummel Avenue Lemoyne, PA 17043 Date of Notice: Juiy 12, 2010 IMPORTANT NOTICE ATTORNEY FOR PLAINTIFF COURT OF COM~dON PLEAS CIVIL DIVISION Cumberland County NO. 10-3540 YOII ARE IN DEFAULT BECAUSE YOU HP.VB FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM TBE DATE OF THIS NOTICE, A JUDC~ffidT MAY BE ENTERS"D AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO SIRS A LAWYER, IBIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 NOTIFICACION IMPORTANTE LISTED SE ENCUENTR.A EN ESTADO DE REBELDIA POR NO EiABER TOMADO LA ACCION REQUIRIDA DE SU_PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMING DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NBCESIDAD DE COMPARARECER LISTED EN CORRE O ESCQGHAR PREUBA ALGUNA, DICTAR SENTENCIA EN 3U CONTRA, LISTED PUEDE PERDER BTENES Y OTROS DERECHOS, IMPORTANTES. DBBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAbIENTE SI LISTED NO TIENE ABOGADO, O SI NO TIENE DINERO 3UFICIENTE PARR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRSCCION SE ENCUEN'rRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PU'EDE CONSEGUIR ASSISTENCIA LEGAL. SERVICTO DE RBFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland Cauat Bar Association 2 Liberty Avenue Carlisle, PA 27013 717-249-3166 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. va ~au~a -n a.awav, +a~yty i.a..rr LORRAINL DOXLE,.ESQIIIRB ALAN M. MINATO, ESQUIRE CSANDRA M. ARKEMA, ESQUIRE ADAM L. ICAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. MARK J. iJDREN, ESQUIRE - ID STUART WINNEG, ESQUIRE - ID LORRAINE DOYLE, ESQUIRE - ID ALAN M. MINATO, ESQUIRE - ID CHANDRA M. ARKEMA, ESQUIRE - WOODCREST CORPORATE CENTER #04302 #45362 #34576 #75860 ID #203437 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust Company, as Trustee for ABFC 2005-AQl Trust, Asset-Backed Certificates, Series 2005-AQ1 Plaintiff v. Betty J. Baker Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE N0. 10-3540 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: Betty J. Baker Over 18 As captioned Unknown Sworn to and subscribed before me this 23RD day pf July, „2010. Notary `Pdb~~~5 AKA ~ ~5 Gc°" above ~Q Name : .~~>,~ ~-zsr--c.~, ~~ Title: ATTORNEY FOR PLAINTIFF Company: UDREN LAW OFFICES, P.C. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. LTDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust :COURT OF COMMON PLEAS Company, as Trustee for ABFC :CIVIL DIVISION 2005-AQl Trust, Asset-Backed `Cumberland County Certificates, Series 2005-AQ1 Plaintiff :MORTGAGE FORECLOSURE v . ~ _~ Betty J. Baker NO. 10-3540 :T .~ ~ "~ Defendant (s ) c `=' -~ ; -n -~ ~- ~.. { PRAECIPE FOR WRIT OF EXECUTION 'b- TO THE PROTHONOTARY: ~ ~ ~ ~'~ -„ -~ Please issue Writ of Execution in the above matter: ~ ~_- `-? 1~ ' Amount due $78,207.40 Interest From 07/24/2010 2,566.80 to Date of Sale December 8, 2010 Ongoing Per Diem of 18.60 to actual date of sale including if sale is held at a later date 0 (Costs to be added) $ a #-a~. oo p ~ ~~ 5b.go C'.eF 9a.oo UDREN LAW OFFICES, P.C. l~.oo a.so ~~ BY : Attorneys f aintiff #184.30 ~ PD A1Tt MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ~d•oo pve eo • 5o ta, C~ 15(00~~ ~' ~~5`135 ~ ~ UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust ?COURT OF COMMON PLEAS Company, as Trustee for ABFC :CIVIL DIVISION 2005-AQ1 Trust, Asset-Backed :Cumberland County ~ n ~ -;:; Certificates, Series 2005-AQ1 ~~,;~4-.c... tom. _~ Plaintif f = MORTGAGE FORECLOSURE .. ~ ~. _.._ '-~_ c `~ ~ ; :1 ~.:_S -~ -ice' t Betty J. Baker € NO. 10-3540 i _ ~a-r Defendant (s ) _ ~ ~ ~ __ , - CERTIFICATE TO THE SHERIFF <~ ~ ~;' ~ ~ _ ~ _ ~ _ ~_~ I HEREBY CERTIFY THAT: ~~.. I. The judgment entered in the above matter is based on an Acti on: 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: X A. An individual 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): X A. Resident in the Commonwealth of Pennsylvania 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: UDREN LAW OFFICES, P.C. Attorneys fo~Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. 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 for ABFC :CIVIL DIVISION 2005-AQl Trust, Asset-Backed :Cumberland County Certificates, Series 2005-AQ1 Plaintiff :MORTGAGE FORECLOSURE v. Betty J. Baker `NO. 10-3540 Defendant(s) C E R T I F I C A T 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. UDREN LAW OFFICES, P.C. BY: ~_ _.~ Attorneys f6r Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ~'UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust :COURT OF COMMON PLEAS Company, as Trustee for ABFC =CIVIL DIVISION 2005-AQ1 Trust, Asset-Backed :Cumberland County Certificates, Series 2005-AQ1 Plaintiff :MORTGAGE FORECLOSURE Betty J. Baker =NO. 10-3540 ~~ o ° Defendant (s ) r'~~ ~~ ~~~ c- ~~ ~,,;~ AFFIDAVIT PURSUANT TO RULE 3129.1 ~`'W -` ~ - Deutsche Bank National Trust Company, as Trustee for ABF~r~200l~-3 r'_: AQ1 Trust, Asset-Backed Certificates, Series 2005-AQ1, Pla[~nt~ff in the above action, by its attorney, Mark J. Udren, ESQ.; se~•s~-'~{ forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 954 Hummel Avenue, Lemoyne, PA 17043 1. Name and address of Owner(s) or reputed Owner(s): Name Address Betty J. Baker 954 Hummel Avenue Lemoyne, PA 17043 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 None 4. Name and address of the last recorded holder of every mortgage of record: Name Address Deutsche Bank National Trust P.O. Box 961730 Company, as Trustee for ABFC Irving, TX 75063-1730 2005-AQl Trust, Asset-Backed Certificates, Series 2005-AQ1 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept 1 Courthouse Sguare Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue 13 North Hanover Road 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 954 Hummel Avenue Lemoyne, PA 17043 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 23, 2010 UDREN LAW OFFICES, P.C. .~--- BY : ~,,,, Attorneys f r Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust :COURT OF COMMON PLEAS Company, as Trustee for ABFC :CIVIL DIVISION c o 2005-AQl Trust, Asset-Backed Cumberland County ~,}~<~_ ~° ._~ Certificates, Series 2005-AQ1 ~,~;' c c- :; --; Plaintiff :MORTGAGE FORECLOSURE r ~ - ..__ ~~~ r~ ,_- v. w Betty J. Baker NO. 10-3540 „ ~ =' ~= ; Defendant (s ) _ , ~, ' ~ ~-u ~p ~;~;~ .c- NOTICE OF SHERIFF'S SALE OF REAL PROPERTY . TO: Betty J. Baker 954 Hummel Avenue Lemoyne, PA 17043 Your house (real estate) at 954 Hummel Avenue, Lemoyne, PA 17043 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 $78,207.40, 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.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE-OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 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 HAVE A LAWYER OR CANNOT AFFORD ONS, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 ASSOCIATION DE LICENCIDADOS Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-3540 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 for ABFC 2005-AQ1 TRUST, ASSET-BACKED CERTIFICATES, SERIES 2005-AQl, Plaintiff (s) From BETTY J. BAKER (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 $78,207.40 L.L.$.50 Interest from 7/24/10 to 12/8/10 Ongoing per diem of $18.60 to actual date of sale including if sale is held at a later date --$2,566.80 Atty's Comm Atty Paid $189.30 Plaintiff Paid Date: 7/23/10 (Seal) Due Prothy $2.00 Other Costs David D. Buell, Pr thonotary By: Deputy REQUESTING PARTY: Name: LORRAINE DOYLE, ESQUIRE Address: UDREN LAW OFFICES, PC WOODCREST CORPORATE CENTER 111 WOODCREST RD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Te I ephone: 856-669-5400 Supreme Court ID No. 34576 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 CH RA 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 ATTORNEY FOR PLAINTIFF Deutsche Bank National Trust Company, as ECOURT OF COMMON PLEAS Trustee for ABFC 2005-AQ1 Trust, Asset-Backed ::CIVIL DIVISION Certificates, Series 2005-AQ1 Cumberland County Plaintiff n r.a q C r -n v. CD Betty J. Baker cnr- N p Defendant (s) NO. 10-3540 2 O O AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.'2n = O-n Plaintiff, by its/his/her Attorney hereby verifies 1. A copy of the Notice of Sheriff's Sale attached hereto as Exhibit "A", was sent to other interested party known as of the date Writ of Execution, on the date(s) appearing Mailing. :Za JW1 CD rrl -1 that : < Cn -?C a true and correct copy of which is every recorded lienholder and every of the filing of the Praecipe for the on the attached Certificates of 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: November(G , 2010 N LAW OFFI .C. Attorneys for Plai f MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE 4CLAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. M1NATO, 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, COURT OF COMMON PLEAS as Trustee for ABFC 2005-AQ1 Trust, CIVIL DIVISION Asset-Backed Certificates, Series 2005- € Cumberland County AQ1 Plaintiff NO. 10-3540 V. Betty J. Baker Defendant(s) TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Betty J. Baker PROPERTY: 954 Hummel Avenue, Lemoyne, PA 17043 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. 'XH/81TA y 1 > W N O ? N W T `n 6 ?c 3 rp N r ?mg CT f j CO -o N N W O ? 3 Z 3 d ? 1 m 1 ? t m Z' Sr cv = 1 K ?3?w car 1 w °' m m O m ?7 -` -0 9`91 0-10 S m m ? 0,4, 0 Spam^mp °5 9t, i Is .:1 O W m v a o' CST 0 s r Q.m W N coo ? N ? 1.0-1 70 n =i v t '0 z0 GOc c Z x GO+?? 3 N?m v ? cyyrC ;m WtD 0 o N ? T ? W C) 0vC3 M?m O T ?n 'y m W 016H26519216 0 ,? Aga 2n i, eC 1t Etur,?r„'' r+r G, ? C o QQ _ `'", 0 00 i5 7 r O -? a ° 4dm i 70 m j °a+ fp n o m - ?a y oG17 m z mTA o owo N n 3 N Q ? ? a c y ?? Wa m, ? v v c 7m ? ?30 C y O aeaw, y ? w C 7 F GO-? cOi pt_ v+ (C .`o v ¢g al 0 ' C 3 Q? m ^m Ry 04 4 6- T7U W °K 70 y O -stN gat -n U) . ?? 9- I y (D SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ,?rc'? et tGun?brr? Jody S Smith ?a ?b Chief Deputy Richard W Stewart Solicitor OFF CE TmE S-ERIFF Deutsche Bank National Trust Company Case Number vs. Betty J. Baker 2010-3540 SHERIFF'S RETURN OF SERVICE 10/08/2010 03:26 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on 10-08-10 at 1522 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 Betty J. Baker, located at, 954 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania according to law. 10/12/2010 07:56 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on 10-12-10 at 1956 hours, she served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Betty J. Baker, by making known unto, Betty J. Baker, personally, at, 954 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $899.92 October 26, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF EXH431r B (c; CountySuite Shent Teleosoft. Inc. UDREN LAW OFFICES, P.G. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 06003-3620 856-669-5400, pleadings@udren.com Deutsche Bank National Trust :COURT OF COMMON PLEAS Company, as Trustee for ABFC :CIVIL DIVISION , - '"- 2005-AQ1 Trust, Asset-Backed ""Cumberland County Certificates, Series 2005-AQ1 to t -1)c:, Plaintiff V. NO. 10-3540 Betty J. Baker _ Defendant(s) PETITION FOR POSTPONEMENT OF SHERIFF'S SALE Plaintiff, by its counsel, petitions the Court for a (2) two month postponement of the Sheriff's sale scheduled in the above captioned matter and in support thereof avers the following: 1. A Sheriff's sale of the mortgaged property involved herein, located at 954 Hummel Avenue, Lemoyne, PA 17043 was originally scheduled for December 8, 2010, then postponed to February 2, 2011 due to loss mitigation review, then postponed to March 2, 2011. 2. The Plaintiff now seeks the postponement of the Sheriff's sale (2) two month(s) postponement of the Sheriff's sale is necessary to allow Plaintiff to review the pending Home Affordable Modification Program (RAMP) application. 3. Pursuant to local rule the defendant(s) are unrepresented by counsel and plaintiff has no manner in which to seek concurrence except by mail. 4. No Judge has been assigned to this matter. WHEREFORE, Plaintiff respectfully prays and requests that the Sheriff's sale of the mortgaged property be postponed to the May 4, 2011 Sheriff's sale. Respectfully submitted, UDREN LAW OFFICES, P.C. BY: athan lf, Esquire Attorney for Plaintiff Local nsel Chi"64 K Arkema, Esquire - OA 10 203437 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadings@udren.com Deutsche Bank National Trust =COURT OF COMMON PLEAS Company, as Trustee for ABFC :CIVIL DIVISION 2005-AQ1 Trust, Asset-Backed :Cumberland County Certificates, Series 2005-AQ1 Plaintiff V. ::NO. 10-3540 Betty J. Baker Defendant(s) PLAINTIFF'S MEMORANDUM OF LAW Pennsylvania R.C.P. 3129.3(b) allows for'the postponement of a Sheriff's sale. In the present matter, the sale has been previously postponed. Plaintiff now seeks an additional postponement to allow time to review (RAMP) application. Therefore, in order for the Plaintiff to be able to properly conduct itself at the Sheriff's sale, a postponement of the sale is necessary. Pa.R.C.P. 3129.3(a) allows the postponement of the sale more than once, and without new notice, by Special Order of Court. Accordingly, for the reasons hereinabove stated, and as more particularly set forth in the Motion, Plaintiff respectfully requests continuance of the Sheriff's Sale of the mortgaged premises, located at 954 Hummel Avenue, Lemoyne, PA 17043, to the May 4, 2011 Sheriff's sale as set forth in the Motion. Respectfully submitted, UDREN LAW OFFICES, P.C. BY: Attorney for Plaintiff C MWr& M. Arcema, Esquire . . 10.203437 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadings@udren.com Deutsche Bank National Trust :COURT OF COMMON PLEAS Company, as Trustee for ABFC :CIVIL DIVISION 2005-AQ1 Trust, Asset-Backed Cumberland County Certificates, Series 2005-AQ1 Plaintiff V. NO. 10-3540 Betty J. Baker Defendant(s) CERTIFICATE OF SERVICE The undersigned certifies that true and correct copies of the attached Petition for Postponement of Sheriff's Sale was served upon the following person(s) named herein at their last known address or their attorney of record by: xxXx Regular First Class Mail Certified Mail Other Date Served: March 1, 2011 TO: Betty J. Baker 954 Hummel Avenue Lemoyne, PA 17043 UDREN LAW OFFICES, P.C. R&than C1 Wolf, . Esquire Local Counsel BY: Attorney for Plaintiff ChWWra M. Arkema, Esquire PA t0 203437 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Deutsche Bank National Trust Company, as Trustee for ABFC 2005-AQ1 Trust, Asset-Backed Certificates, Series 2005-AQ1 NO. 10-3540 Plaintiff V. Betty J. Baker Defendant(s) O R D E R AND NOW, this / ev day of March, 2011, after consideration of Plaintiff's Petition for Postponement of Sheriff's Sale of the mortgaged property located at 954 Hummel Avenue, Lemoyne, PA 17043, it is hereby ORDERED that the said Sale currently scheduled for March 2, 2011, is extended (2) two month(s) to the regularly scheduled Cumberland County Sheriff's Sale scheduled for May 4, 2011. No further advertising or additional notice to lienholders or Defendant(s) is required provided the postponement is announced at the March 2, 2011 Sheriff's Sale. BY CO J. TO: Betty J. Baker 954 Hummel Avenue Lemoyne, PA 17043 = =-' ` Udren Law Offices, P.C. - 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 Attn: Sale Department `._j Office of the Sheriff Cumberland County Courthouse , One Courthouse Square Carlisle, PA 17013-3387 Copses j a,i/e ??/+ / Ilr j'& _0 3 6 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION Deutsche Bank National Trust Company, as Trustee for ABFC ' rn ZOO 2005-AQ1 Trust, Asset-Backed Certificates, Series 2005-AQ1 €NC. 10-3540 Plaintiff ,. V Betty J. . Baker Defendant(s) O R D E R AND NOW, this 4e day of May, 2011, after consideration of Plaintiff's Petition for Postponement of Sheriff's Sale of the mortgaged property located at 954 Hummel Avenue, Lemoyne, PA 17043, it is hereby ORDERED that the said Sale currently scheduled for May 4, 2011, is extended (1) one month to the regularly scheduled Cumberland County Sheriff's Sale scheduled for June 1, 2011. No further advertising or additional notice to lienholders or Defendant(s) is required provided the postponement is announced at the May 4, 201 ff's Sale. BY E COURT: Edward E. Guido J. TO:/Betty J. Baker / 954 Hummel Avenue M Lemoyne, PA 17043 COP X691 UUU???? Udren Law Offices, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 Attn: Sale Department Office of the Sheriff -in ?cLa Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 r? --t r- n 0 M :Ta Q -?C7 Cj -n ?i? UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 Deutsche Bank National Trust .COURT OF COMMON PLEAS Company, as Trustee for ABFC `-CIVIL DIVISION - 2005-AQ1 Trust, Asset-Backed :Cumberland County Certificates, Series 2005-AQ1 m Box 961730 P.O. :z -Orr Irving, TX 75063-1730 ENO. 10-3540 D N , u? Plaintiff -sr- ;Z: C: V. C7: Betty J. Baker ?- 954 Hummel Avenue ?- Lemoyne, PA 17043 Defendant(s) PRAECIPE TO WITHDRAW JUDGMENT AND DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly mark the above captioned matter JUDGMENT WITHDRAWN and ACTION DISCONTINUED WITHOUT PREJUDICE, upon payment of your costs only. DATED: February 29, 2012 10050394-1 .a-, for Plaintiff HARRY B. REESE, PA ID 310501 J