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Home My WebLink About10-3373Phelan, Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michelle M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq. Id. No. 58745 Sheetal R. Shah-Tani, Esq., Id. No. 81760 %,?-Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tobas, 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 Chrisovalaute P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No.206779 Andrew C. Bramblett, Esq., I.D. 208375 One Penn Center A Suburban Station Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Deutsche Bank National Trust Co., As Trustee Under The Pooling And Servicing Agreement Dated As Of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 4828 Loop Central Drive Houston, TX 77081 V. Connie L. Paylor Or Occupants 200 4th Street Summerdale, PA 17093 FILFU ., k. ; ,kr' T , p- ?? ,r 2010 MA i 20 AM 10: 33 CUt,t Lg p,JpU,"?iTY 1"?., l 4'L* N 'o t Attorney for Plaintiff Court of Common Pleas Civil Division Cumberland County No. 10 - 3313 Ci v i l l?er'M CIVIL ACTION - EJECTMENT **This firm is a debt collector attempting to collect a debt and any information obtained will be used for that purpose. If you have previously received a discharge in bankruptcy and this debt was not reaffirmed, this correspondence is not and should not be construed to be an attempt to collect a debt, but only enforcement of a lien against property.** 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 (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 and 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 or cannot afford one, go to or telephone the office set forth below to find out where you can get legal help. 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 CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 (888)-990-9108 PHS #: 239903 PA A7f? tO g51431 0 44.1 '4 11 1. Plaintiff is Deutsche Bank National Trust Co., As Trustee Under The Pooling And Servicing Agreement Dated As Of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1. 2. Defendant is Connie L. Paylor Or Occupants. 3. Plaintiff is the record owner of premises located at 200 4th Street, Summerdale, PA 17093, a legal description of which is attached. 4. Plaintiff became the owner of said premises as a result of the foreclosure and judicial sale by the Sheriff of Cumberland County, on March 3, 2010, as evidenced by the Sheriff's deed recorded March 24,. 2010 in the Office of the Recorder of Cumberland County in instrument # 201007328, a true and correct copy of which is attached hereto, made party hereof, and marked as Exhibit "A". 5. Plaintiff, by virtue of the above, is the record owner of said premises, and is entitled to possession thereof. The defendant is occupying the said premises without right and so far as the plaintiff is informed, without claim of title. 6. Plaintiff has demanded possession of the said premises from the said defendant who has refused to deliver up possession of same. WHEREFORE, plaintiff seeks to recover possession of said By: La r ce T. Phelan , Esq., Id. No 32227 Fr s S. Hallinan, Esq., Id. No. 62695 D ' 1 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. 817 Jenine R. Davey, Esq., Id. No. 870771 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 EXHIBIT "A" 001 R70 Tax Parcel No. 09-12-2994-052 Know all Men by these Presents That I, Ronny R. Anderson, Sheriff of the County of Cumberland, In the State of Pennsylvania, for and in consideration of the sum of $ 1.00 (One Dollar), to me in hand paid, do hereby grant and convey to Deutsche Bank National Trust Co., as Trustee under the Pooling and Servicing Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1. Writ No. 2007-925 Civil Term Deutsche Bank National Trust Co., as Trustee under the Pooling and Servicing Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 Vs Connie L. Paylor ALL THOSE TWO CERTAIN ADJACENT LOTS OR PARCELS OF LAND, TOGETHER WITH THE IMPROVEMENTS THEREON ERECTED, SITUATE IN EAST PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE NORTHEAST CORNER OF THE INTERSECTION OF FOURTH STREET AND SIXTEEN (16) FEET WIDE ALLEY; THENCE NORTHWARDLY ALONG THE EASTERN LINE OF FOURTH STREET, SIXTY (60)FEET TO "THE SOUTHERN LINE OF LOT NO. 93, SECTION "A' ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE EASTWARDLY ALONG THE SOUTHERN LINE OF LOT, NO. 93, SECTION A ONE HUNDRED SIXTY (160) FEET TO THE WESTERN LINE OF A SIXTEEN (16) FEET WIDE ALLEY; THENCE SOUTHWARDLY ALONG THE WESTERN LINE OF SAID SIXTEEN (16) FEET WIDE ALLEY, SIXTY (60) FEET TO THE NORTHWEST CORNER OF THE INTERSECI'ION OF SAID SIXTEEN (16) FEET WIDE ALLEY WITH THE SIXTEEN (16) FEET WIDE ALLEY FIRST MENTIONED; THENCE WESTWARDLY ALONG THE NORTHERN LINE OF THE SIXTEEN (16) FEET WIDE ALLEY FIRST MENTIONED, ONE HUNDRED SIXTY (160) FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOTS NOS. 91 AND 92, SECTION "A" IN THE PLAN OF LOTS KNOWN AS SUMMERDALE, PENNSYLVANIA., SAID PLAN' BEING RECORDED IN THE OFFICE FOR THE RECORDING OF DEEDS IN AND FOR CUMBERLAND COUNTY, IN PLAN BOOK 1, PAGE 44 (REVISED PLAN, BOOK 2, PAGE 109) HAVING THEREON ERECTED A ONE-STORY FRAME DWELLING NUMBER 200 FOURTH STREET, SUMMERDALE, PENNSYLVANIA. BEING KNOWN AS: 200 4TH STREET, SUMMERDALE, PA 17093 PROPERTY ID NO.: 09-12-2994-052 TITLE TO SAID PREMISES IS VESTED IN CONNIE L. PAYLOR BY DEED FROM LVA H. SINGLE, WIDOW DATED 6/17/88 RECORDED 6/21/88 IN DEED BOOK K33 PAGE 417. The same having been sold by ine to the said grantee on the 3`d day of March Anno Domini Two Thousand and Ten (2010) after due advertisement according to law, under and by Virtue of a Writ of Execution issued on the 8th of October Anno Domini 2009 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Seven (2007) Number 925 at the suit of Deutsche Bank National Trust Co., as Trustee under the Fooling and Servicing Agreement dated as of March 1, 2006, GSRPM Mortgage Loan Trust 2006-1 -vs- Connie L. Paylor In Witness Wereof, I have hereunto affixed my signature this 17 ?d," of March Anno Domini Two Thousand and Ten (2010) Anderson, Sheriff Commonwealth of Pennsylvania, ss. County of Cumberland Before the undersigned, David D. Buell, Prothonotary of the Court of Common Pleas of Cumberland County, Pennsylvania, personally appeared, Ronny R. Anderson, Sheriff of Cumberland County aforesaid, and in due form of law declared that the facts Set forth in the foregoing Deed are true, and that he acknowledged the same in order that Said deed might be recorded. Witness my hand and seal of said Court, this 17 day of March Anno Domini Two Thousand and Ten (2010) onotary t,tttsrtt?;; o?we.?ne? ? ?\? ? 1, t?C0?M011E9gMMtMt?ht Ot.M,?14 I hereby certify that the residence •.??• • '"?"?''-? And Post Office address of the ? ? • >S ?!4_r ..: if? Gtr •: ? Within Grantee is 4828 Loop Central Drive Houston, TX 77481 tt?? .« I?14tit ;,' Solicitor ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 201007328 Recorded On 3/2412010 At 11:03:55 AM * Instrument Type - DEED-SHERIFF'S Invoice Number - 62786 User ID - MBL * Grantor - PAYLOR, CONNIE L * Grantee - GSRPM MORTGAGE LN TRUST 2006-1 * Customer - CUMBERLAND COUNTY SHERIFF * FEES STATE WRIT TAX $0.50 STATE JCS/ACCESS TO $23.50 JUSTICE RECORDING FEES - $12.50 RECORDER OF DEEDS PARCEL CERTIFICATION $10.00 FEES AFFORDABLE HOUSING :$11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 EAST PENNSBORO SCHOOL $0.00 DISTRICT EAST PENNSBORO TOWNSHIP $0.00 TOTAL PAID $63.00 * Total Pages - 5 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA RECORDER O /DrDS * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. iuiMiA00IR70 imM VERIFICATION I hereby state 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 take this Verification, pursuant to Pa. RC.P.,1024 (c) and that they statements made in the foregoing Civil Action in Ejectment are true and correct to the best of his knowledge, information and belief. Furthermore, it is counsel's intention to substitute a verification from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 19 Pa, C.S. Sec 4904 relating to unsworn falsification to authorities. Date: 5\A? 0 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Deutsche Bank National Trust Company vs. Connie L Paylor cov'8'5r of culub".1 ?t OFF CE OF 3?-ERIFF Case Number 2010-3373 SHERIFF'S RETURN OF SERVICE 06/21/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on June 21, 2010 at 1436 hours, he was unable to serve a true copy of the within Complaint In Ejectment, upon the within named defendant, to wit: Connie L. Paylor. After several attempts the current occupants of 200 4th Street, Summerdale, Cumberland County, Pennsylvania 17093 will not answer the door. 06/21/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on June 21, 2010 at 1436 hours, he was unable to serve a true copy of the within Complaint In Ejectment, upon the within named defendant, to wit: Occupant of 200 4th Street, Summerdale, PA 17093. After several attempts the current occupants of 200 4th Street, Summerdale, Cumberland County, Pennsylvania 17093 will not answer the door. SHERIFF COST: $87.20 June 21, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (c) CountySuite Sheriff. Teleosoff. Inc. Y THE 2010 JUN 22 AM 8: 40 r ^-P E ` e.,WN t PENN Y ?`,?NIre1 • ' r T. r' ~ ,~; ~~ ~.~ c~,~3v~r-`d P~ 3: i~ ;,~r~~ ~. Deutsche Bank National Trust Co., As Trustee Under The Pooling and Servicing Agreement Dated As of March 1, 2006, G~SRPM Mortgage Loan Trust 2006-1 vs. Connie L. Paylor or occupants 200 4th Street Summerdale, PA 17093 AUG 0 5 2010 Court of Common Pleas Civil Division Cumberland County No. 10-3373 Action in Ejectment ORDER It is order this ~' "` day of A v ~ S~, 2010, that Plaintiff's Motion for Service of Complaint and all future pleadings, Pursuant to Special Order of Court is GRANTED, permitting service by: X First Class Mail to Connie L. Paylor or occupants at the property which is subject to this Ejectment Action*. Service by first class mail is effective upon the date of mailing. X Posting of the property which is subject to this Ejectment Action by Sheriff or non-party competent adult* * the nronerty at 200 4th Street, Summerdale, PA 17093 PHS# 239903 ~~hni~ L.~/r Copy r1.a.-'~cd ~~~~~d OF CUM David D. Buell A 14" e l enee 7(7 Simpson Prothonotary Z 1St Deputy Prothonotary �irkS. Sofionage, ESQ ;. Ar- Irene E. Morrow Solicitor 7750 2nd Deputy Prothonotary Office of the Prothonotary Cumberland County, Pennsylvania 16 — 3373 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER, 2013,AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE-THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square • Suite 100 • Carlisle, PA 17013 • (717)240-6195 • Fa,(717)240-6573