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Home My WebLink About10-5352r 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-Jahi, 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 1. 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 247056 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2006KS3 1100 VIRGINIA DRIVE P.O. BOX 8300 FORT WASHINGTON, PA 19034 V. Plaintiff RONALD GOODREAU KIM GOODREAU 125 3RD STREET BOILING SPRINGS, PA 17007-6004 Defendants !7 - LJ AUG 16 An 10= 3d ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. /0- -S 3 ? cm'-' CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE ky1, 06 / ,j a#y ekhf fgor-7Y Xk?,?_yb Sr.L? File #: 247056 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 #: 247056 1. Plaintiff is U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2006KS3 1100 VIRGINIA DRIVE, P.O. BOX 8300 FORT WASHINGTON, PA 19034 2. The name(s) and last known address(es) of the Defendant(s) are: RONALD GOODREAU KIM GOODREAU 125 3RD STREET BOILING SPRINGS, PA 17007-6004 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 12/29/2005 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A NOMINEE FOR EQUIFIRST CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1936, Page 3539. 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 12/01/2009 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 247056 6. The following amounts are due on the mortgage: Principal Balance $162,341.59 Interest $6,277.60 11/0 1/2009 through 08/04/2010 (Per Diem $22.9984) Attorney's Fees $650.00 Cumulative Late Charges $702.00 03/01/2009 to 08/04/2010 Property Inspections/Property Preservations $74.05 Non Sufficient Funds Charge $60.00 Costs of Suit and Title Search $550.00 Escrow Deficit 78.29 Subtotal $170,733.53 Suspense Credit 928.39 TOTAL $169,805.14 7. 8. Plaintiff is not seeking a judgment of personal liability (or an in personam 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 or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. File #: 247056 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $169,805.14, together with interest from 08/04/2010 at the rate of $22.9984 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 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 ? She all R. Shah-Jani, Esq., Id. No. 81760 ? J me 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 #: 247056 LEGAL DESCRIPTION ALL that certain lot or piece of land situate in the Village of Boiling Springs, South Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at an iron post on Third Street at line of lands now or formerly of J.C. Lehman Estate; thence along Third Street, South eighty-one (81) degrees forty (40) minutes West fifty-five (55) feet to an iron post at the northeast corner of Third and Walnut Streets; thence along Walnut Street, North nine (9) degrees five (5) minutes West, one hundred thirty-three and two-tenths (133.2) feet to a point, corner of Barn, at corner of Walnut Street and an alley; thence along said alley North eighty-two (82) degrees no (0) minutes East fifty-four and four-tenths (54.4) feet to a point on said alley at lands now or formerly of said J.C. Lehman Estate; thence along said lands now or formerly of said J.C. Lehman Estate, South nine (9) degrees twenty (20) minutes East one hundred thirty-two and six-tenths (132.6) feet to an iron post on Third Street, the place of BEGINNING. CONTAINING fifty-two and one half perches. BEING the same premises which Marian B. Matz, Widow, by her Deed dated July 14, 1987 and recorded on July 14, 1987, in the Office of the Recorder of Deeds, in and for Cumberland County, Pennsylvania, in Deed Book U, Volume 32, Page 407, granted and conveyed unto John B. Adcock and Linda G. Adcock, Grantors herein. PROPERTY ADDRESS: 125 3RD STREET, BOILING SPRINGS, PA 17007-6004 PARCEL # 40-29-2482-189 File #: 247056 VERIFICATION 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: for Plaintiff File #: 247056 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~'r'!CE Sheriff ~ ~~ ~~~'~y~TA~ ~a~,~titp of `urn~brr~~~ Jody S Smith ~ _~ x o ~ ~~ " ~ P~ 2t ~ ~ Chief Deputy ,~~ ,t .v~, :~~>, t Richard W Stewart Solicitor c~~leE ~'ri.4~~ER~FF ~B~hLr'~i'~t1.1 ~~NTM PENPvS"1'LVANIA US Bank National Association Case Number vs. Ronald Goodreau (et al.) 2010-5352 SHERIFF'S RETURN OF SERVICE 08/18/2010 11:37 AM -Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on August 18, 2010 at 1137 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Kim Goodreau, by making known unto Ronald Goodreau, Husband of defendant at 125 3rd Street, Boiling Springs, Cumberland County, Pennsylvania 17007 its contents and at the same time handing to him personally the said true and correct copy of the same. G RONALD HOOVER, DEPUTY 08/18/2010 11:37 AM -Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on August 18, 2010 at 1137 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Ronald Goodreau, by making known unto himself personally, at 125 3rd Street, Boiling Springs, Cumberland County, Pennsylvania 17007 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $49.40 August 26, 2010 ~GG~ RONALD HOOVER, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF ;c1 CountySuite Sheriff. Teleosoft Inc. F11-ED-OFFICE OF THE PROTHONOTARY 5'? SEA' q0 A4 I ?• . = CUM ERLA1,11O COUNTY PEA `("VAN,1A 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 1. 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 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2006KS3 VS. RONALD GOODREAU KIM GOODREAU : CUMBERLAND COUNTY : COURT OF COMMON PLEAS CIVIL DIVISION 14. oo P A op 1087 No. 10-5352 CIVIL 0d4897y` 247056 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 RONALD GOODREAU and KIM GOODREAU, Defendant(s) for failure to file an Answer to Plaintiffs 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 $169,805.14 Interest - 08/05/2010 to 09/28/2010 $1,264.91 TOTAL $171,070.05 I hereby certify that (1) the Defendant's last known address is 125 3RD STREET, BOILING SPRINGS, PA 17007-6004, and (2) that notice a been given in accordance with Rule 237.1, copy attached. N A r., 1A A n A LJ L wrence T.?Zelan, Esq., Id. N6-7n= ? rancis 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 1. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: 430 PHS # 247056 PROTHONOTARY 247056 Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Attorney for Plaintiff 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 U.S. BANK NATIONAL ASSOCIATION CUMBERLAND COUNTY AS TRUSTEE FOR RASC 2006KS3 VS. : COURT OF COMMON PLEAS : CIVIL DIVISION RONALD GOODREAU No. 10-5352 CIVIL KIM GOODREAU 247056 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 RONALD GOODREAU is over 18 years of age and resides at 125 3RD STREET, BOILING SPRINGS, PA 17007-6004. (c) that defendant KIM GOODREAU is over 18 years of age and resides at 125 3RD STREET, BOILING SPRINGS, PA 17007-6004. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: Y17. Phelan,-Esq., Id. No. 32227 S. Hallinan, Esq., Id. No. 62695 aniel G. Schmieg, Esq., Id. No. 62205 IVI 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 1. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Attorney for Plaintiff 247056 (Rule of Civil Procedure No. 236) - Revised U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2006KS3 CUMBERLAND COUNTY COURT OF COMMON PLEAS VS. RONALD GOODREAU KIM GOODREAU 125 3RD STREET BOILING SPRINGS, PA 17007-6004 CIVIL DIVISION No. 10-5352 CIVIL Notice is given that a Judgment in the above captioned matter has been entered against you on 0410 By: 4W- If you have any questions concerning this matter please contact: ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Fichele ' S. Hallman, Esq., Id. No. 62695 ? G. Schmieg, Esq., Id. No. 62205 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 Attorney or Party Filing 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 "THIS 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 TO BE AN ATTEMPT TO COLLECTA DEBT, BUT ONLYENFORCEMENT OFA LIENAGAINST PROPERTY. ** 247056 e .- U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2006KS3 COURT OF COMMON PLEAS CIVIL DIVISON Plaintiff v. RONALD GOODREAU KIM GOODREAU Defendant(s) TO: KIM GOODREAU 125 3RD STREET BOILING SPRINGS, PA 17007-6004 DATE OF NOTICE: September 8, 2010 NO. 10-5352 CIVIL 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. 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. 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. PHS # 247056 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 Lawrenc helan, Esq., Id. No. 32227 Fra . 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 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza. Philadelphia, PA 19103 PHS 4 247056 V . `-f U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2006KS3 COURT OF COMMON PLEAS CIVIL DIVISON Plaintiff v. RONALD GOODREAU .U ,M GOODREAU Defendant(s) TO: RONALD GOODREAU 125 3RD STREET BOILING SPRINGS, PA 17007-6004 DATE OF NOTICE: September 8, 2010 NO. 10-5352 CIVIL 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. 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. 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. PHS # 247056 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: t-awrence T. an, Esq., Id. No. 32227 Francis S allinan, 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 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 247056 •`i PR.>ECIPF F(~R ~'-'RI :~ nF EtF('['Tln\-(~tOR:::.~GF Ff}RECLOSCRE) P. R. C. Y. 31 t3U-31 t33 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC COURT OF COMMON PLEAS 2006KS3 Plaintiff CIVIL DIVISION v• NO.: 10-5352 CIVIL RONALD GOODREAU KIM GOODREAU Defendant(s) CUMBERLAND COUNTY To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 09/29/2010 to Date of Sale ($28.51 per diem) TOTAL O ~ a~.oo P~ n-r~-y 'Kt.4o CBF ga.oo " I'~•oo " a .50 " ~-- ~d.oo Aue Co S0 I.1, Note: -Please attach description of property. PHS # 247056 ~~ Ia14Q~o ~~' aso~s RE I~rit ~,~ /'w.? !~- C ~7 r ~.~ a^r-a -, ~r -:? ---1 $171 070.05 c; •' '.,`a , r= $ 4,419.05 ~=_ c~ -~ __.. -< ~`~ $175,489.10 ~~~ rney for Plaintiff 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 ~Court~enay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 0 ~Y, ~-'~ i` ~"A -~-, ~ ~~ -~:a --~ ~~ c°~ ~ ~-~ .:=s -C ~•'~, 'Ct .~ C ~ ~ ~ n .fl ~ O n ~ J, "" c~ M ~ ¢ p" a ~ ~~~~ ~ c~ o ~ o~~ ¢W~ ~ ~ ~~~ ~~~ w ~~°~ w w N w~ ~ o~ c c ¢~ "~ O ~ ~~N ~~~ "' M d'~ Vn~oMo O QI r"~ M ~ ~ ~ 0~0 ~ ~ M ~ ~V~ ~ ~ ~ ~ ~~ ~ W ~ o o~ °Ccn~ t~ooQ,z~•~. ~ W ~ azzzZ ozo~oaN„~~o o d~N oZ E• N AwwOy''a ~:oW°'n ~r~~y°~~WWw'~W.Ww;~Ww~ ~~ ~~ Oa ~ W ao ~ aa~~.~ ~ ~ ~ ~;~ ~ o~ ~ ~w ~d:a „ ~ > ~ ~;> ~ O CAA a~ ~ ~ ~ ~~ ~.~ >-o ~W'~•~,~a.~A ~ W a. -- pq ~ -~ ~ w° at ~ ~ C7 y E-: ~ ~; pi •~ C ~ ..7 chi ~ ~ ~' U w ¢ a CJC7ODC7[~CJDpC]QDpOCJ~ Phelan Hallinan &Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2006KS3 Plaintiff v. RONALD GOODREAU KIM GOODREAU Defendant(s) Attorneys for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION NO.: 10-5352 CIVIL CUMBERLAND COUNTY c-a ~--. ~ ~ ~ ~ -~ CERTIFICATION -~; =~. ~ ~: ~-~ -+ The undersigned attorney hereby states that he/she is the attorney for the Plaintiff m ~a aboug caed matter and that the premises are not subject to the provisions of Act 91 because: ~'~~;~ ~--~ ~` ~ ( ) the mortgage is an FHA Mortgage f-, ",~ -~ - ~- ~=, ( ) the premises is non-owner occupied '~' ` `~`•' ~ ~'~ ( ) the premises is vacant .:.~:; c~, (X) Act 91 procedures have been fulfilled { This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. By: Attv~ or Plaintiff 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 oshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 U: BANK NATIONAL ASSOCIATION AS TRUSTEE CFO RASC 2006KS3 ~~ laintiff v. RQNALD GOODREAU KIM GOODREAU Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 10-5352 CIVIL CUMBERLAND COUNTY PHS # 247056 AFFIDAVIT PURSUANT TO RULE 3129.1 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2006KS3 , Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 125 3RD STREET, BOILING SPRINGS PA 17007-6004. , 1. Name and address of Owner(s) orreputed Owner(s): ~ r.,, ~ Name Address (if address cannot be reasonably '-= '-~--' ~ ascertained, please so indicate) r~ ~ -, ~=-r~ _._, .~ ~~~ rY~.._. ~; a RONALD GOODREAU 125 3RD STREET c 'y ~ o •iz -:, BOILING SPRINGS PA 17007-6004 ``~ =° - "~~ ~' ` KIM GOODREAU 125 3RD STREET ~ ; , ; -° BOILING SPRINGS, PA 17007-6004 3-'~° :~ ~ ~ s~ 2. Name and address of Defendant(s) in the judgment: -C ~`+ '~ Name Address (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and last known address of every judgment creditor whose judgment is a record lien on th e real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) MERS AS A NOMINEE FOR EQUIFIRST P.O. BOX 2026 CORPORATION FLINT, MI 48501-2026 MERS, INC. 3300 SW 34~ AVENUE, STE. 101 OCALA, FL 34474 EQUIFIRST CORPORATION 500 FOREST POINT CIRCLE CHARLOTTE, NC 28273 EQUITY ONE, INCORPORATED 301 LIPPINCOTT DRIVE MARLTON, NJ 08053 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) 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 (if address cannot be reasonably ascertained, please indicate) None. 7. ,~ Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may ~,i be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department of Justice U.S. Attorney for the Middle District of PA COMMONWEALTH OF PENNSYLVANIA BUREAU OF INDIVIDUAL TAX INHERITANCE TAX DIVISION DEPARTMENT OF PUBLIC WELFARE TPL CASUALTY UNIT ESTATE RECOVERY PROGRAM MERS AS A NOMINEE FOR AMERICA'S SERVICING COMPANY AMERICA'S SERVICING COMPANY 125 3RD STREET . BOILING SPRINGS, PA 17007-6004 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 6TH FLOOR, STRAWBERRY SQUARE DEPT. 280601 HARRISBURG, PA 17128 P.O. BOX 8486 WILLOW OAK BUILDING HARRISBURG, PA 17105-8486 P.O. BOX 2026 FLINT, MI 48501-2026 2701 Wells Fargo Way MAC x9998-012 Minneapolis, MN 55467-8000 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.A. § 4904 relating to unsworn falsification to authorities. October 21.2010 By: Atto y for Plaintiff 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 ~shua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 U.S. B,~NK NATIONAL ASSOCIATION AS TRUSTEE FOR COURT OF COMMON PLEAS RASC 2006K53 CIVIL DIVISION Plaintiff NO.: 10-5352 CIVIL vs. RONALD GOODREAU CUMBERLAND COUNTY KIM GOODREAU Defendant(s) ~ ~ ~: ,~, •, -~ NOTICE OF SHERIFF'S SALE OF REAL. PROPERTY ~' ~ ~ ~ ~ ; _~ -,~ r ~ . TO: RONALD GOODREAU ~}' `- "'' ~' ~~ c KIM GOODREAU ~~ ~~" r-- c:~ ~ `~' `~~ 125 3RD STREET ^ ~' ~~ - ~~~' ~' BOILING. SPRINGS, PA 17007-6004 ~ ~ ~ c..J ~ • e ~~„ ~-~ ~~~ -< * * THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION .OBTAINED WII.L BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 125 3RD STREET, BOII.ING SPRINGS, PA 17007-6004 is scheduled to be sold at the Sheriff's-Sale on 03!02!2011 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $171,070.05 obtained by U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2006KS3 (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late chazges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 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.) ~~OU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the. Sheriff s Sale is not stopped, your property will be sold to the highest bidder: You may fmd out the price bid by calling 215-563-7000. 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 215-563-7000. 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 shaze of the money which was paid for your house. A proposed schedule of distribution of the money bid. for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will. be made available for inspection in his office. This schedule will state who will be receiving that maney. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distributions wrong) are filed with the Sheriff within ten~(10) days after the filing of the proposed schedule. 7. You may also have other rights and. defenses,. or ways of getting .your home back, if you :act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL that certain lot or piece of land situate in the Village of Boiling Springs, South Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at an iron post on Third Street at luxe of lands now or formerly of J.C. Lehman Estate; thence along Third Street, South eighty-one (81) degrees forty (40) minutes West fifty-five (55) feet to an iron post at the northeast. corner of Third and Walnut Streets; thence along Walnut Street, North nine (9) degrees five (5) minutes West, one hundred thirty-three and two tenths (133.2) feet to a point, corner of Barn, at corner of Walnut Street and an alley; thence along said alley North eighty-two (82) degrees no (0) minutes East fifty-four and four-tenths (54.4) feet to a point on said alley at lands now or formerly of said J.C. Lehman Estate; thence along said lands now or formerly of said J.C. Lehman Estate, South nine (9} degrees twenty (20) minutes East one hundred thirty-two and six-tenths (132.6) feet to an iron post on Third Street, the place of BEGINNING. CONTAINING filly-two and one half perches. Title to said premises is vested in Ronald Goodreau and Kim Goodreau, his wife, from John B. Adcock and Linda G. Adcock, his wife, in a deed recorded 12/4!2003 in Book 260 Page 3464. PREMISES BEING: 125 3RD STREET, BOII.ING SPRINGS, PA 17007-6004 PARCEL NO.40-29-2482-189 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-5352 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due U.S. BANK NATIONAL ASSOCIATION, as Trustee for RASC 2006KS3, Plaintiff (s) From RONALD GOODREAU and KIM GOODREAU (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 $171,070.05 L.L.$.50 Interest from 9/29/10 to Date of Sale @ ($28.51 per diem) -- $4,419.05 Atty's Comm % Due Prothy $2.00 Atty Paid $181.90 Plaintiff Paid Date: 10/27/10 Other Costs V avid D. Buell, Prothonotary (Seal) REQUESTING PARTY: Name: COURTENAY R. DUNN, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP ONE PENN CENTER, SUITE 1400 1617 JFK BOULEVARD PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 206779 By: Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2006KS3 Plaintiff, V RONALD GOODREAU KIM GOODREAU Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: tiJ C"D M co J 0 J As required by Pa. R.C.P. 3129.1(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, i f ort on he Affidavit and as amended if applicable. A copy of the Certificate of Mailin For 38 ? and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is ach d rptn Vvhihit «s» Date: 113-11 11 Y t'Lawrence T. Phelan, Esq., Id. No. 327 /? 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 ? S eetal R. Shah-Jani, Esq., Id. No. 81760 ? enure 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 ? Allison F. Wells, Esq., Id. No. 309519 Attorney for Plaintiff IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY C-2 COURT OF COMMON PI CIVIL DIVISION r7 No.: 10-5352 CIVIL ?a v fi r1l F C C+ ) ?", ICJ r PHS # 247056 t U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE COURT OF COMMON PLEAS FOR RASC 2006KS3 Plaintiff CIVIL DIVISION V. RONALD GOODREAU NO.: 10-5352 CIVIL KIM GOODREAU Defendant(s) CUMBERLAND COUNTY PHS # 247056 AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2006KS3, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 125 3RD STREET, BOILING SPRINGS, PA 17007-6004. Name and address of Owner(s) or reputed Owner(s): Name RONALD GOODREAU KIM GOODREAU 2. Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE Address (if address cannot be reasonably ascertained, please so indicate) 125 3RD STREET BOILING SPRINGS, PA 17007-6004 125 3RD STREET BOILING SPRINGS, PA 17007-6004 Address (if address cannot be reasonably ascertained, please so indicate) Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) APPLIED CARD BANK 120 NORTH KEYSER AVENUE C/O EDWIN ABRAHAMSEN, ESQUIRE SCRANTON, PA 18504 APPLIED CARD BANK 800 DELAWARE AVENUE WILMINGTON, DE 19801 Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) MERS AS A NOMINEE FOR EQUIFIRST CORPORATION MERS, INC. EQUIFIRST CORPORATION EQUITY ONE, INCORPORATED MERS, INC. P.O. BOX 2026 FLINT, MI 48501-2026 3300 SW 34"" AVENUE, STE. 101 OCALA, FL 34474 500 FOREST POINT CIRCLE CHARLOTTE, NC 28273 301 LIPPINCOTT DRIVE MARLTON, NJ 08053 1901 E. VOORHEES ST., STE. C DANVILLE, IL 61834 EQUITY ONE, INCORPORATED EQUITY ONE, INCORPORATED 235 MAIN STREET STE 117 DICKSON CITY, PA 18519 LACKAWANNA EXECUTIVE PARK DICKSON CITY, PA 18519-1652 Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) 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 (if address cannot be reasonably ascertained, please indicate) None. 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 (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT 125 3RD STREET BOILING SPRINGS, PA 17007-6004 Domestic Relations of 13 North Hanover Street Cumberland County Carlisle, PA 17013 Commonwealth of Pennsylvania P.O. Box 2675 Department of Welfare Harrisburg, PA 17105 Internal Revenue Service Advisory 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 U.S. Department of Justice Federal Building, P.O. Box 11754 U.S. Attorney for the Middle District of PA 228 Walnut Street Harrisburg, PA 17108 COMMONWEALTH OF PENNSYLVANIA 6TH FLOOR, STRAWBERRY SQUARE BUREAU OF INDIVIDUAL TAX DEPT. 280601 INHERITANCE TAX DIVISION HARRISBURG, PA 17128 DEPARTMENT OF PUBLIC WELFARE P.O. BOX 8486 TPL CASUALTY UNIT WILLOW OAK BUILDING ESTATE RECOVERY PROGRAM HARRISBURG, PA 17105-8486 MERS AS A NOMINEE FOR AMERICA'S P.O. BOX 2026 SERVICING COMPANY FLINT, MI 48501-2026 AMERICA'S SERVICING COMPANY 2701 Wells Fargo Way MAC x9998-012 Minneapolis, MN 55467-8000 MERS AS A NOMINEE FOR LEHMAN P.O. BOX 2026 BROTHERS HOLDINGS INC FLINT, MI 48501-2026 LEHMAN BROTHERS HOLDINGS INC 2617 College Park Drive Scottsbluff, NE 69361 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 at false statements herein are made subject to the penalties of 18 Pa. C.S.A. 9 4904 relating to unworn falsific ion to orities. January, 2011 B tt ey or Plaintiff 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 ? S etal R. Shah-Jani, Esq., Id. No. 81760 ? nine 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 1. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 ¦ £ o L6 30oodZ woad 0311dw Me 9?5?V p.100 squabooo w o9vo7 $ M zo rrwoo A3N W .....? ?r „ '?bds31'? 9 .r T" a all ?I I 8 S? k i g' a i ? z O o Y dd o a M Ue w a e D W ' ? ? e?? -! H a vo o ? ? p! U Y e c? ' p$ Cr• ,'7? °? p?q ? 7?G i ? ?j rF o U U f!?' ??j 01 •' W O??f?G ???e?? 8 Yn??nal• 0?G9po??oppV;;z Q?o?zOQz w y0?`'? Te?$p ?'° a Op?U,aaDI ?arU F z ;n R ?; ? ? o e Aq a o O D ? F Aq v? O ? ? t3 ! Ir. ez a Ya °? a 3 a? o V a ?j a??N??FOG .D ,y G N Z, ? ?' a ti N tii ? V1 • 0 : Ei 4 3000 dIZ W08-4 031IHW LlOZ 8zNbf 99ZLLZb000 o106'ZO $ M zo S W1p9 A.Mild C ME k? O 5 1SOd S3??b wll I.1 IZI N A 0 0 C x y am ox a a a ? W W ?;o as A p a? ?O ? wW w y E.y ° °' ?'?dN?QO ?ZU xZUdO A3FOEAdU Ox a x? od o;wA w„az 02 w ?wc?x??aoo ao? Q•??aZ?a:?aN?aU??a °3, a .a U_ b ? z Q0 a r, N M le A1 NA U F w ? ri aE.,d??a ?i pGV:°OGF°...° wen WWu uHQ, 'Ozd?zw? ?jOWZ Z UZ?U Z d z°a°3zo°zo ??AWaAWNA kn I ?o O N a W F A w A O A z W°a a * I* I* I* I* I* I? I? u S ? ?i39E E??g u a,o E a' ? W E o ? ? O c 9 h U u O ? u o y N O W ? ? O t?ipp' E 7 OC ir?9 C •. ? W O ?^ O O O C •a m Ern Fw'aF? ?o a E s; ?o w°a a 00 z? oa b C h L a i AFFIDAVIT OF SERVICE PLAINTIFF U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2006KS3 DEFENDANT RONALD GOODREAU KIM GOODREAU SERVE KIM GOODREAU AT: 125 3RD STREET BOILING SPRINGS, PA 17007-6004 CUMBERLAND COUNTY PHS # 247056 SERVICE TEAM/ lac COURT NO.: 10-5352 CIVIL TYPE OF ACTION XX Notice of Sheriffs Sale SALE DATE: 03/02/2011 C: Cr3 - M N Q ZO CD -n F p C D t=? .. } y 4 r< t 3 SERVED , Defendant on the eday of T1r1UVP,-Aq , 20 Served and made known to _ KIMOQD 10' o o o'clock M., at 742 t W PD, C"t.ls W E, 17,4 - in the manner described below: Defendant personally served ? Adult family member ith whom Defendant(s) reside(s). Relationship is I,tS $ b _ Adult in charge of Defendant's residence who refused to give name or relationship. _ Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant's office or usual place of business. _ an officer of said Defendant's company. Other: Description: Age b S Height 57 " Weight ( D Race W Sex /IA Other I, P62MI0 A40 l-(.., a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subsc??}''bed KIMBERLY CURTY beforeme this 14fz day NOTARY PUBLIC of ??v , 20 1/. - / STATE OF NEW JERSEY V , v G MY COMMISSION EXPIRES MARCH 7, 2013 No By; NOT SERVED 20_, at _ o'clock _. M., Defendant NOT FOUND because: cant _ Does Not Exist _ Moved - Does Not Reside (Not Vacant) -No Answer on at at Service Refused Other: Sworn to and subscribed before me this day ofd By: Notary: ATTORNEY FOR PLAM FF Lawrence T. PMIr, Esq., Id. No. 32227 Francis S. Hating, Fmq, Id. No. 62695 Daniel G. Schutt Esq, Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69649 Judith T. Romano, Emil, hL No. 59745 Model IL ShW-Jai, Esq., Id. No. 81760 Jedne It. Dee, Esq, Id. No. UMT7 LAunn R T¦bas, Esq., Id. No. 93337 Vieek Srivastava, Esq., Id. No. 212331 Jay B. Jones, Esq., hL No. 86657 Peter J. Muhahy, Fsq., Id. No. 61791 Andrew L Sphwk Furl., Id. No. 84439 Jahn McCmness, Fsq., Id. No. 90134 Chrsovahnte P. F%dws, Fsq, Id. No. 94621 Joshua L Goldman, Esq, Id. No. 205047 Cause®y R Der, Esq, Id. No. 216779 Andmv G Bramblell, Esq, Id. No. 208375 One Per center at Suburboms Station 1617 Jahn F. Kennedy Blvd, suite 1401 Pbthde"* PA 191031814 (215) 5637000 PLAINTIFF AFFIDAVIT OF SERVICE CUMBERLAND COUNTY U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2006KS3 PHS # 247056 PREV toutLy MT 5'e2V Eo (1 ((21(0 DEFENDANT SERVICE TEAM/ kac RONALD GOODREAU COURT NO.: 10-5352 CIVIL KIM GOODREAU SERVE RONALD GOODREAU AT: TYPE OF ACTION 125 3RD STREET XX Notice of Sheriff's Sale BOILING SPRINGS, PA 17007-6004 SALE DATE: 03/02/2011 SERVED Served and made known to RO D GOODREAU , Defendant on the ??day of ? 4 t : k , O'clock A. M., at 'T4 2 LIEN P 4ig s LE, PA 14, in the manner described below: V Defendant personally served. - Adult family member with whom Defendant(s) reside(s). Relationship is _ Adult in charge of Defendant's residence who refused to give name or relationship. - Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant's office or usual place of business. _ an officer of said Defendant's company. _ Other: Description: Age 0 Height r7 ?1 Weight I a0 Race W Sex M Other 3 ?M m { T) ?E CD -rz C-) = -r; , at p C:) D ? tom: may, I, K A4+i b MA LL , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. ,# 0jb'N'r N d Cp (N d ESTj 6?/ Tj 0 N A i 5 c t.:05 ED 7t HIT _V - Does Not Exist _ Moved _ Does Not Reside (Not Vacant) -No Answer on at at KIMBERLY CURTY - Service Refused NOTARY PUBLIC Other: STATE OF WW JERSEY Sworn to and subscribed MY COMMISSION EXPIRES MARCH 7, 2013 before me this day of -. By: of , 20 If. Notary- By: SER On the a of 20_, at - o'clock _. M., Defendant NOT FOUND because: Sworn to and subsc ?j1 D.9'N7'S M0k/ f2ff I Dl= Q 74- .2- &LEn? P-o+o before me this 1441day C1+A-L I 5L-EI P4 Notary: ATTORNEY FOR PLAENTIFF ]rw'aioe T. Phelan, Esq, K Na 32227 Frauds S. Ha6nan, Eq., Id. Na 62695 DoWel G. Sehsim Eq, Id. Na 62285 Mhide M. Bradford, Fig, Id. No. 69849 Judith T. Rornano. Esq., Id. Na 58745 Shedal R Shahid, Eq., Id. Na 81760 Jenhrc R Davey, Esq., Id. Na 87077 Unrest R. Tahas, Esq., Id. Na 93337 Vivek Sdvaslasa, Eq, Id. Na 202331 Jay 8. Jones, Es%, Id. Na 86657 Peter J. Molohy, Ent- Id. No. 61791 Andrew L Sphadc, Esq, Id. Na 84439 Jahac MaCn?racas, Esq., Id. Na 90134 Chrbovahaote P. FYakos, Eq., Id. Na 94670 Jmhoa 1. Goldnn t, Fsq., id. Na 205047 Coodemy R Dunn, Esq., Id. Na 206779 Andrew C. Bamebldl, hL Na 208375 One Penn Center al Su Station 1617 John F. Kennedy BI.d., Safe 1400 Philadelphia, PA 19103-1814 (215) 5637000 ,-% /;I SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FILED-OFFICE Sheriff o1 4.rrit +1I THE I'ROTHONOTAtly j r Jody S Smith Chief Deputy Richard W Stewart Solicitor ?pttltt'? t't'j??fd Off 7 '-V;' F 2011 APR -1 AN 10: CUMBERLAND COUNTY PENNSYLVANIA US Bank National Association Case Number vs. Ronald Goodreau (et al.) 2010-5352 SHERIFF'S RETURN OF SERVICE 12/29/2010 04:05 PM - Deputy Robert Bitner, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 125 3rd Street, Boiling Springs, PA 17007, Cumberland County. 12/29/2010 04:05 PM - Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Ronald Goodreau, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 125 3rd Street, Boiling Springs, PA 17007, Defendants do not reside at above address, get mail at a Post Office Box, no physical address associated with the Post Office Box. 12/29/2010 08:35 PM - Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Kim Goodreau, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 125 3rd Street, Boiling Springs, PA 17007, Defendants do not reside at above address, get mail at a Post Office Box, no physical address associated with the Post Office Box. 03/02/2011 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, Carlisle, Cumberland County, PA, on March 2, 2011 at 10:00 a.m. He sold the same for the sum of $ 1.00 to Attorney Daniel Schmieg, on behalf of U.S. Bank National Association, et. al., 1100 Virginia Drive, P.O. Box 8300, Fort Washington, PA 19034 being the buyer in thi: execution, paid to the Sheriff the sum of $ SHERIFF COST: $776.24 March 31, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF 1-/6 otSPC4. Ct, 4P4 ??a 9 is Goun'rSuite Snenit Teleasct, Inc. U.S. BANK NATAON ASSOCIATION AS TRUSTEE FOR RASC 2006KS3 Plaintiff V. RONALD GOODREAU KIM GOODREAU Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 10-5352 CIVIL CUMBERLAND COUNTY PHS # 247056 AFFIDAVIT PURSUANT TO RULE 3129.1 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2006KS3, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 125 3RD STREET, BOILING SPRINGS, PA 17007-6004. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) RONALD GOODREAU KIM GOODREAU 2. Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE 125 3RD STREET BOILING SPRINGS, PA 17007-6004 125 3RD STREET BOILING SPRINGS, PA 17007-6004 Address (if address cannot be reasonably ascertained, please so indicate) Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) MERS AS A NOMINEE FOR EQUIFIRST P.O. BOX 2026 CORPORATION FLINT, MI 48501-2026 MERS, INC. 3300 SW 34'x' AVENUE, STE. 101 OCALA, FL 34474 EQUIFIRST CORPORATION 500 FOREST POINT CIRCLE CHARLOTTE, NC 28273 EQUITY ONE, INCORPORATED 301 LIPPINCOTT DRIVE MARLTON, NJ 08053 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 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 Add ress (if address cannot be None reasonably ascertained, please indicate) . 7. Name and address .of eery other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department of Justice U.S. Attorney for the Middle District of PA COMMONWEALTH OF PENNSYLVANIA BUREAU OF INDIVIDUAL TAX INHERITANCE TAX DIVISION DEPARTMENT OF PUBLIC WELFARE TPL CASUALTY UNIT ESTATE RECOVERY PROGRAM MERS AS A NOMINEE FOR AMERICA'S SERVICING COMPANY AMERICA'S SERVICING COMPANY 125 3RD STREET BOILING SPRINGS, PA 17007-6004 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 6TH FLOOR, STRAWBERRY SQUARE DEPT. 280601 HARRISBURG, PA 17128 P.O. BOX 8486 WILLOW OAK BUILDING HARRISBURG, PA 17105-8486 P.O. BOX 2026 FLINT, MI 48501-2026 2701 Wells Fargo Way MAC x9998-012 Minneapolis, MN 55467-8000 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.A. § 4904 relating to unsworn falsification to authorities. October 21, 2010 By: Atto y for Plaintiff 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 ?shua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 x , .- U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR COURT OF COMMON PLEAS RASC 2006KS3 : CIVIL DIVISION Plaintiff . : NO.: 10-5352 CIVIL VS. RONALD GOODREAU CUMBERLAND COUNTY KIM GOODREAU Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: RONALD GOODREAU KIM GOODREAU 125 3RD STREET BOILING SPRINGS, PA 17007-6004 "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, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 125 3RD STREET, BOILING SPRINGS, PA 17007-6004 is scheduled to be sold at the Sheriff's Sale on 03/02!2011 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $171,070.05 obtained by U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2006KS3 (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 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.) A 1 OU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 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 215-563-7000. 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. 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 the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL that certain lot or piece of land situate in the Village of Boiling Springs, South Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at an iron post on Third Street at line of lands now or formerly of J.C. Lehman Estate; thence along Third Street, South eighty-one (81) degrees forty (40) minutes West fifty-five (55) feet to an iron post at the northeast corner of Third and Walnut Streets; thence along Walnut Street, North nine (9) degrees five (5) minutes West, one hundred thirty-three and two tenths (133.2) feet to a point, corner of Barn, at corner of Walnut Street and an alley; thence along said alley North eighty-two (82) degrees no (0) minutes East fifty-four and four-tenths (54.4) feet to a point on said alley at lands now or formerly of said J.C. Lehman Estate; thence along said lands now or formerly of said J.C. Lehman Estate, South nine (9) degrees twenty (20) minutes East one hundred thirty-two and six-tenths (132.6) feet to an iron post on Third Street, the place of BEGINNING. CONTAINING fifty-two and one half perches. Title to said premises is vested in Ronald Goodreau and Kim Goodreau, his wife, from John B. Adcock and Linda G. Adcock, his wife, in a deed recorded 12/4/2003 in Book 260 Page 3464. PREMISES BEING: 125 3RD STREET, BOILING SPRINGS, PA 17007-6004 PARCEL NO. 40-29-2482-189 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 10-5352 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW 'TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due U.S. BANK NATIONAL ASSOCIATION, as Trustee for RASC 2006KS3, Plaintiff (s) From RONALD GOODREAU and KIM GOODREAU (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 $171,070.05 L.L. $.50 ):nterest from 9/29/10 to Date of Sale @ ($28.51 per diem) -- $4,419.05 Atty's Comm % Atty Paid $181.90 Plaintiff Paid Date: 10/27/10 (Seal) REQUESTING PARTY: Due Prothy $2.00 Other Costs 1 David D. Buell, Pr thonotary By: Deputy Name: COURTENAY R. DUNN, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP ONE PENN CENTER, SUITE 1400 1617 JFK BOULEVARD PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 206779 TRUE COPY FROM RECORD In TbsUmony whereof, t here unto set my hand and F4r of Bald Cotxt at C dWe, Pa. Thisdayof_-: 2011) . I", Qp1 Proth onotary On November 22, 2010 the Sheriff levied upon the defendant's interest in the real property situated in South Middleton Township, Cumberland County, PA, Known and numbered as, 125 3rd Street, Boiling Springs more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 22, 2010 By: Real Estate Coordinator "A- )(un awl r PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA . ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 28, February 4, and February 11, 2011 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Li a Marie Coyne, Editor SWORN TO AND SUBSCRIBED before me this 11 day of Februar2011 A/ Notary I/ NOTARIAL SEA DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 CUMBERLAND LAW JOURNAL Writ No. 2010-5352 Civil US Bank National Association VS. Ronald Goodreau Kim Goodreau Atty.: Daniel Schmieg By virtue of a Writ of Execution NO. 10-5352 CIVIL, U.S. BANK NA- TIONAL ASSOCIATION AS TRUSTEE FOR RASC 2006KS3 vs. RONALD GOODREAU, KIM GOODREAU, owner(s) of property situate in South Middleton Township, Cumberland County, Pennsylvania, being 125 3RD STREET, BOILING SPRINGS, PA 17007-6004. Parcel No. 40-29-2482-189. Improvements thereon: RESIDEN- TIAL DWELLING. ,JUDGMENT AMOUNT: $171,070- .05, 21 y The Patriot-News Co. 2020 Tecbnolo?gy Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 Zbe?lahiot-News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 1/28/11 2010-5352 Civil Term US Bank Natlanal Association 214/11 V's Ronald (loodreau _ 2111/11 Kim Gaodreau ?Atty: Danh11 Schn ieg I -F' `} By virtue of a Writ of Execution NO. 10- ` . .. ...... . 5352 CIVIL U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR:RASC2006KS3 Sworn to and/subscribed befdY"e this 22 day of February, 2011 A. D_ VS. RONALD GOODREAU 1 KIM GOODREAU KIM owner(s) of propery situate in South Middleton Township, Cumberland County, Notary Public Pennsylvania, being (Municipality) 125 3RD STREET, BOILING COMMONWEALTH OF PENNSYLVANIA SPRINGS, PA 17007-15004 Notarial Seal Parcel No. 40-29-2482-189 ' Sherrie L Kisrter, Notary Public: (Acreage or street address) I-ower Parton Twp., Dauphln County Improvements thereon: RESIDENTIAL MY Corrtmi%iort Explres Nov. 26 2011 DWELLING _ , Member. Pennsylvania Associatlon of Notaries JUDGMENT AMOLNT: $171,070.01) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which RASC 2006KS3 is the grantee the same having been sold to said grantee on the 2nd day of March A.D., 2011, under and by virtue of a writ Execution issued on the 27th day of October, A.D., 2010, out of the Court of Common Pleas of said County as of Civil Term, 2010 Number 5352, at the suit of RASC 2006KS3 Tr against Ronald & Kim Goodreau is duly recorded as Instrument Number 201109960. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of 14 A.D. o? O ?1 X? of Deeds Rec*W of d County, Carlisle, PA My Commission res the Frst Monday of Jan. 2014