HomeMy WebLinkAbout11-1217
"THIS IS NOT AN ARBITRATION CASE"
"AN ASSESSMENT OF DAMAGES HEARING IS NOT REQUIRED"
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
c?
US Bank National Association, as trustee for CIVIL DIVISION -'- ,
the holders of the First Franklin Mortgage ' t ==
Loan Trust Mortgage Pass-Through NO.: k) ?n
Certificates, Series 2006-FF2 ISSUE NO.: -
TYPE OF PLEADING:',
Plaintiff,
vs. CIVIL ACTION - COMPLAINT TN
EJECTMENT --
Jenny R. I-Tuber CODE-
FILED ON BEHALF OF:
Defendant. US Bank National Association, as trustee for
the holders of the First Franklin Mortgage
Loan Trust Mortgage Pass-Through
Certificates, Series 2006-FF2
COUNSEL OF RECORD FOR THIS
PARTY:
Scott A. Dietterick, Esquire; Pa. I.D. #55650
Kimberly A. Bonner, Esquire; Pa. I.D. #89705
Joel A. Ackerman, Esquire; Pa I.D. #202729
Ashleigh L. Levy, Esquire; Pa I.D. 4306799
ZUCKER, GOLDBERG & ACKERMAN,
LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
ofticek-)zucker olg dberg.corn
File No.: XCP- 138746-EV/gg
TO: Defendant(s)
YOU ARE I-IEREBY NOTIFIED TO PLEAD
TO THE ENCLOSED COMPLAINT
WITHIN TWENTY (20) DAYS FROM
SERVICE HEREOF OR A DEFAULT
JUDGMENT MAY BE ENTERED
AGAINST YOU.
Scott A. Dietterick, Esquire
Kimberly A. Bonner, Esquire
Joel A. Ackerman, Esquire
Ashleigh L. Levy, Esquire
Attorneys for Plaintiff
Zucker, Goldberg & Ackerman, LLC
XCP-138746-EV
138746-EVD 1002C0121201IP2???. p0 Pd Q?
.............................. .
1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
US Bank National Association, as trustee for
the holders of the First Franklin Mortgage Loan
Trust Mortgage Pass-Through Certificates,
Series 2006-FF2
Plaintiff,
vs.
Jenny R. Huber
Defendant
CIVIL DIVISION
NO..
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claim 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 SHOULD
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.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
NOTICE TO DEFEND
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (800) 990-9108
(717) 249-3166
LAWYER REFERRAL
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (800) 990-9108
(717) 249-3166
Zucker, Goldberg & Ackerman, LLC
XCP-138746-EV
138746-EVD1002C01212011P4
i ?
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
US Bank National Association, as trustee for the :
holders of the First Franklin Mortgage Loan CIVIL DIVISION
Trust Mortgage Pass-Through Certificates,
Series 2006-FF2 NO.:
Plaintiff,
vs.
Jenny R.ltuber
Defendant.
AVISO
USTED HA SIDO DEMONDADO/A EN CORTE. Si usted desea defenderse de las demandas
que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro do los
proximos veinte (20) dias despues de la notifacacion de esta Demanda y Aviso radicando
personalmente o por medio de un abogado una comperencencia escrita y redicanco en la Courte
por escnto sus defensas de, y objecciones a, los demandas presentadas aqui en contra suya. Se le
advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede
proceder sin usted y un fallo por cualquier suma de dinero reciamada en la demanda o cualquier
otra reclamacion o remedio solicitado por el demandante puede ser dietado en contra suya por la
Corte sin mas aviso adicional. Usted puede perder dinero 0 propieded u otros derechos
importantes para. usted.
US"TED DEBE LLEVAR ESTE DOCUMENTO A SU ABAGADO IMMEDIATAMENTE. SI
LISTED NO TIENE UN ABOGADO 0 NO PUEDE PAGARLE, A UNO, LLAME A VAYA A
LA SIGUETNTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR
ASISTENCTA LEGAL.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
NOTICE TO DEFEND LAWYER REFERRAL
Cumberland County Bar Association Cumberland County Bar Association
32 S. Bedford Street 32 S. Bedford Street
Carlisle, PA 17013 Carlisle, PA 17013
Phone (800) 990-9108 Phone (800) 990-9108
(7T7) 249-3166 (717) 249-3166
Lucker, Goldberg & Ackerman, LLC
XCP-138746-EV
138746-EVD1002C01212011P5
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
US Bank National Association, as trustee for the :
holders of the First Franklin Mortgage Loan CIVIL DIVISION
Trust Mortgage Pass-Through Certificates,
Series 2006-FF2 NO.:
Plaintiff,
vs.
Jenny R. Huber
Defendant.
CIVIL ACTION - COMPLAINT IN EJECTMENT
AND NOW, comes US Bank National Association, as trustee for the holders of the First
Franklin Mortgage Loan Trust Mortgage Loan Trust Mortgage Pass-Through Certificates, Series
2006-FF2, by its attorneys, Zucker, Goldberg & Ackerman, LLC, and files this Complaint in
Ejectment as follows:
I. The Plaintiff, Bank National Association, as trustee for the holders of the First
Franklin Mortgage Loan Trust Mortgage Loan Trust Mortgage Pass-Through Certificates, Series
2006-FF2, which has its principal place of business at 3815 South Temple Salt Lake City, UT
84115
2. The Defendant, Jenny R. Huber, is an adult individual residing within the
Commonwealth of Pennsylvania at 162 EAST CHAPEL AVENUE, CARLISLE, PA 1701.3.
3. By Sheriff's Deed dated January 3, 2011 and recorded on January 10, 2011 Instr#
201101266, the Sheriff of Cumberland County has conveyed to Plaintiff, all that certain lot of
piece of ground, with improvements erected thereon, and as more fully described in the Deed
and as purchased by Plaintiff at Sheriff Sale on December 8, 2010.
4. During the pendency of the Mortgage Foreclosure Action of US Bank National
Association, as trustee for the holders of the First Franklin Mortgage Loan Trust Mortgage Pass-
Through Certificates, Series 2006-FF2, predecessor in interest to Plaintiff, on the aforesaid
premises docketed at 2010-03538, Defendant was served as owner of the aforesaid premises with
Zucker, Goldberg & Ackerman, LLC
XCP-138746-EV
138746-EVD1002C01212011P6
i .
a true and correct copy of the Complaint in Mortgage Foreclosure by the Sheriff of Cumberland
County.
5. Under the same Term and Number, Defendant was served as owner of the
aforesaid premises with a Notice of Sheriffs Sale scheduling the sale for December 8, 2010 and
Defendant. was served on October 14, 2010, personally by the Sheriff of Cumberland County. A
true and correct copy of Plaintiffs Affidavit of Service is marked Exhibit "A", attached hereto
and made a part hereof.
6. In addition, the aforesaid premises was posted with the Sheriffs Handbill and
Notice of Sale.
7. By letter, dated December 22, 2010, Defendant and all other Current Occupants,
if any, were notified by counsel for the Plaintiff to vacate the premises, via Certified Mail,
Return Receipt Requested and First Class U.S. Mail, postage: pre-paid, with a Certificate of
Mailing. A true and correct copy of the letter, Certified Mail Receipt and Certificate of Mailing
are marked Exhibit "B", attached hereto and made a part hereof.
8. To date, Defendant has failed or refused to vacate the premises, and therefore,
Defendant is occupying, using and enjoying the premises without right and Claim of Title.
9. Defendant has unjustly and unlawfully retained possession of the premises to the
detriment of Plaintiff.
WHER-EFORE, Plaintiff demands judgment against Defendant for possession of the
premises known as 162 EAST CHAPEL AVENUE, CARLISLE, PA 17013, together with such
other relief as this Honorable Court may deem tDiri d appropriate.
ZUCKERER & AC RMAN, LC
BY:
Dated: January 21, 2011 Scott AEsquire; PA T.D. 455650
Kimberly A. Bonner, Esquire; PA I.D. #89705
Joel A. Ackerman, Esquire:; PA I.D. 4202729
Ashleigh L. Levy, Esquire; PA I.D. #306799
Attorneys for Plaintiff
XCP-138746-EV/gg
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
Email: Office ,zuckergolalberg.com
THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
Zucker, Goldberg & Ackerman, LLC
XCP-138746-EV
138746-EVD1o02C01212011P7
LEONARD 6. ZUCKER
MICHAEL S!ACKERMAN
JOEL ACKERMAN'
FRANCES GAMBARDELLA
BRIAN C. NICHOLAS 0
STEVEN D. KROL
CHRISTOPHER G. FORD
DENSE CARLON A
MONIKA S. PUNDALIK
CHRISTINE C POTTER
BRIAN W. BANASIAK
RYAN S. MALC
JENEE K. CICCARELLI A
JAMES R. FREESWICK A
ASHLEIGH L LEVY f
DOUGLAS J.McDONOUGH
TIMOTHYJ. ZIEGLER
STEPHANIE WOLCHOK
HYUN S. OH
ALSO MEMBER OF NY, PA AND CA BAR
0 ALSO MEMBER OF NYAND ME BAR
A ALSO MEMBER OF NYBAR
E ALSO MEMBER OF PA BAR
FCP-138746
Prothonotary of Cumberland County
Cumberland County Courthouse
Carlisle, PA 17013-3387
November 23, 2010
Re: US Bank National Association, as trustee for the holders of the First Franklin
Mortgage Loan Trust Mortgage Pass-Through Certificates, Series 2006-FF2
vs. Jenny R. Huber, single person
Premises: 162 EASTCHAPEL AVENUE AKA 162 EAST CHAPEL ALLEY, CARLISLE PA
17013.
Docket No.: 2010-03538
Sheriff No.:
Sheriff Sale #:
Dear Sir or Madam:
Enclosed for filing please find an original of an Affidavit of Service of Defendant/Owner and Other Parties of
Interest regarding the above referenced matter. Please file the original and return a time-stamped copy of
the extra face page which is enclosed in the self-addressed stamped envelope.
If you have any questions or concerns, please do not hesitate to contact Marie Lindner of our office at
(908) 233-8500 ext. 115.
Very Truly Yours,
ZUCKER, GOLDBERG & ACKERMAN, LLC
BY: /?l?r1e.P1?d
Marie Lindner, Legal Assistant
200 Sheffield Street, Suite 101
Mountainside, W 07092
Email: Office@zuckergoIdberg.com
File No.: FCP-138746
(908) 233-8500; (908) 233-1390 FAX
ml
enclosures
cc: Sheriff of Cumberland Cou.,*v.(w/encl.)
ZUCKER, GOLDBERG & ACKERMAN, LLC FOUNDED IN 1923
ATTORNEYS AT LAW AS ZUCKER & GOLDBERG
MAURICEJ. ZUCKER 1918 1979
200 SHEFFIELD STREET- SUITE 101 LOUIS D. GOLDBERG 1923.1967
P.O. BOX 1024 LEONARD H. GOLDBERG 1929-1979
1
MOUNTAINSIDE, NJ 07092-0024 BENJAMIN WEISS
1949-1981
TELEPHONE: 908-233-8500
FACSIMILE: 908-233-1390 Pennsyivwla Office:
E-MAIL: office@zuckergoldberg.com P.O. Box 650
Hershey, PA 17033
For payoff1m statement figures
Please send your request to. zuckergo/dberg.com/pr OF COUNSEL:
SCOTr A. BERLY A. BONNER, EESCL.
REPLY TO NEW JERSEY ADDRESS KIM
M V
Y MEMBER OF PA BAR ONLY
" EXHIBIT A"
k
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
US BANK NATIONAL ASSOCIATION, AS TRUSTEE
FOR THE HOLDERS OF THE FIRST FRANKLIN
MORTGAGE LOAN TRUST MORTGAGE PASS-
THROUGH CERTIFICATES, SERIES 2D06-FF2,
Plaintiff,
Vs.
CIVIL DIVISION
NO.: 2010-03538
Sheriff Sale #:
TYPE OF PLEADING
Pa. R.C.P. RULE. 3129.2(C) AFFIDAVIT OF SERVICE
OF DEFENDANT/OWNER. AND
OTHER PARTIES OF INTEREST
CODE:
Jenny R. Huber
Defendant.
FILED ON BEHALF OF:
US Bank National Association, as trustee for the
holders of the First Franklin Mortgage Loan Trust
Mortgage Pass-Through Certificates, Series 2006-
FF2
COUNSEL OF RECORD FOR THIS
PARTY:
ZUCKER, GOLDBERG & ACKERMAN, LLC
Scott A. Dietterick, Esquire PA I.D. #55650
Kimberly A. Bonner, Esquire- PA I.D. #89705
Joel A. Ackerman, Esquire- PA I.D. #202729
200 Sheffield. Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500
(908) 233-1390 FAX
officei2zuckere0ldbers.com
File No.: FCP- 138746/ml
Zucker, Goldberg & Ackerman, LLC
FCP-138746
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CIVIL DIVISION
THE HOLDERS OF THE FIRST FRANKLIN MORTGAGE
LOAN TRUST MORTGAGE PASS-THROUGH NO.: 2010-03538
CERTIFICATES, SERIES 2006-FF2,
Plaintiff,
vs.
Jenny R. Huber
Defendant.
Pa R.C.P. RULE 3129(c) AFFIDAVIT OF SERVICE OF
DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST
I, Marie Lindner, a paralegal with the firm of Zucker, Goldberg & Ackerman, LLC, attorneys for
Plaintiff, US Bank National Association, as trustee for the holders of the First Franklin Mortgage Loan
Trust Mortgage Pass-Through Certificates, Series 2006-FF2, being duly sworn according to law depose
and make the following Affidavit regarding the service of Plaintiff's Notice of Sheriff's Sale of Real
Property in this matter on Defendant/Owner and Other Parties of Interest as follows:
1. Defendant, Jenny R. Huber, is the record owner of the real property.
2. On or about 10/14/10, Jenny R. Huber, was served with Plaintiff's Notice of Sheriffs
Sale of Real Property Pursuant to Pa. R.C.P. 3129, personally by the Sheriff of Cumberland County, at
the address of the mortgaged premises, being 162 EAST CHAPEL AVENUE AKA 162 EAST CHAPEL ALLEY,
CARLISLE PA 17013. A true and correct copy of said Notice and Return of Service are marked Exhibit
"A", attached hereto and made a part hereof.
3. On or about 10/20/10, Plaintiff's counsel served all other parties in interest with
Plaintiffs Notice of Sheriff's Sale according to Plaintiffs Affidavit Pursuant to rule 3129.1, via First Class
U.S. Mail, Postage Pre-Paid, with a Certificate of Mailing. True and correct copies of said Notices and
Certificates of Mailing are marked Exhibit "B", attached hereto and made a part hereof.
Zucker, Goldberg & Ackerman, LLC
FCP-138746
Finally, the undersigned deposes and says that the Defendant/Owner and all other Parties of
Interest were served with Plaintiff's Notice of Sheriffs Sale of Real Property in accordance with Pa,R.C.P.
3129.2.
ZUCKER, GOLDBERG & ACKERMAN, LLC
Attorneys for Plaintiff
Dated: November 23, 2010
MARIE IND ER
Paralegal/Legal Assistant
Sworn to and subscribed before
me 23rd day of mberK2010
Notary Public
MY COMMISSION EXPIRES:
KERY A. QUINN
A NOTARY PUBLIC OF NEWVMe
My Commissiori 6xplres 10/23/2012
Zucker, Goldberg & Ackerman, LLC
FCP-138746
Zucker. Goldberg & gckerrnan
l.LC
FCP_138746
Nov, 5. 2010 8:41AM No. 3869 P. 2
SHERIFFS OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chlef beputy
Richard W Stewart
$olicitor
???? ai tGwa6cy??a
'x `-? .rte
0FF1 M OF N9 $hC.MrF
US Bank National Association --
Va. Case Humber
Jenny R. Huber 2010-3598
SHERIFF'S RETURN OF SERVICE
10/1412010 Shawn Gutshell, Deputy Sheriff, who being duty swom aocording to law, states that on 10-14-10 at 1648
hours, he posted a true copy of the within Real Estate Wtit, {Notice, P03ter and Description, in the above
entitled action, upon the property of Jenny R, Huber, located at 162 East Chapel Avenue e/k/s 1$2-Poo
Chapel Alley, Carlisle, Cumberland County, Pennsylvanla according to law.
90/1412010 Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on 10-1440 at 1647
hours, he served a true copy of the within Real Estate Writ, Notice and Desontption, In the above entitled
action, upon the within rYamed defendant, to wit: Jenny R. Huber, by making known unto, Jenny R. Huber,
personally, aat, 162 East Chapel Avenue, Carisle. Cumberland County, Pennsylvania Its contents and at
the some time handing to her personally the said true and correct copy, of the same,
SHERIFF COST: $804.82
November 06. 2010
SO ANSMRS,
M)N ANDERSON, SHERIFF
t?1Cw i?tystwi>iTmwborLIro,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
US Bank National Association, as trustee for the CIVIL DIVISION
holders of the First Franklin Mortgage Loan
Trust Mortgage Pass-Through Certificates, NO.: 2010-03538
Series 2006-FF2,
Plaintiff,
VS.
Jenny R. Huber
Defendant.
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
Jenny R. Huber
162 East Chapel Avenue a/k/a 162 East Chapel Alley
Carlisle, PA 17013
TAKE NOTICE:
That the Sheriffs Sale of Real Property (Real Estate) will be held at the
Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on
12/0812010 at 10;00am prevailing local time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description
consisting of a statement of the measured boundaries of the property, together with a
brief mention of the buildings and any other major improvemetrts erected on the land.
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The LOCATION of your property to be sold is:
162 East Chapel Avenue alk/a 162 East Chapel Alley, Carlisle, PA, 17013
The JUDGMENT under or pursuant to which your property is being sold is
docketed to:
No. 2010-03538
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS
PROPERTY ARE:
Jenny R. Huber
Zucker, Goldberg & Ackerman, LLC
PCP-138746
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities or agencies being entitled to receive part of the
proceeds of the sale received and to be disbursed by the Sheriff (for example to banks
that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff
thirty (30) days after the We, and distribution of the proceeds of sale in accordance with
this schedule will, in fact, be made unless someone objects by filing exceptions to it,
within ten (10) days of the date it is filed. Information about the Schedule of Distribution
may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County,
One Courthouse Square, Carlisle, PA 17013-3387.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY. T
It has been issued because there is a Judgment against you. It may cause your
property to be held, to be sold or taken to pay the Judgment, You may have legal rights
to prevent your property from being taken. A lawyer can advise you more specifically of
these rights. If you wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO
OR TELEPHONE THE OFFICE SET FORTH_ BELOW TO FIND OUT WHERE YOU
CAN GET FREE LEGAL ADVICE.
Lawyer Referral Service of the
Cumberland County Bar Association
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (800) 990-9108
(717) 249-3166
THE LEGAL RIGHTS YOU MAY HAVE ARE,
I. You may file a petition with the Court of Common Pleas of
Cumberland County to open the Judgment if you have a meritorious defense against
the person or company that has entered judgment against you. You may also file a
petition with the same Court if you are aware of a legal defect in the obligation or the
procedure used against you.
2. After the Sheriffs Sale, you may file a petition with the Court of
Common Pleas of Cumberland County to set aside the sale for a grossly inadequate
price or for other proper cause. This petition must be filed before the Sheriff's Deed
is delivered.
Zucker, Goldberg & Ackerman, LLC
FCP-138746
3. A pe #oa or petitions raising the legal issues or rights mentioned
in the preceding paragraphs must be presented to the Court of Common Pleas of
Cumberland County. The petition must be served on the attorney for the creditor or
on the creditor before presentation to the Court and a proposed order or rule must be
attached to the petition. If a specific return date is desired, such date must be
obtained from the Court Administrator's ce, County Courthouse,
One Courthouse Square, Carlisle, PA 70 -33 , e sentation of the
petition to the Court.
ZUCKER L,D E G & X N, LLC
Dated: August 31, 2010 BY:
Scott A. i n squire; PA I.D. #55650
Kimberl . Bonner, Esquire; PAID. #89705
Joel A. Ackerman, Esquire; PA I.D. #202729
200 Sheffield Street, Suite 301
Mountainside, NJ 07092
File No.: FCP-138746
-(908) 233-8500; (908) 233-1390 FAX
E-mail: Office@zuckergoldberg.com
VIA ORDER OF COURT.
Zucker, Goldberg & Ackerman, LLC
FCP-13 8746
Exhibit "A"
LEGAL DESCRIPTION
ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE BOROUGH OF CARLISLE,
CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCHBED AS FOLLOWS, TO
WIT:
BEGINNING AT A POINT, AT LANDS NOW OR FORMERLY OF JOHN PARK AT THE
SOUTHERN RIGHT OF WAY LINE OF EAST CHAPEL AVE., 17,5 FEET, MORE OR LESS TO
LANDS NOW OR FORMERLY OF CHARLES T. RHINESMITH; THENCE ALONG SAID LANDS
OF CHARLES T. RHINESMITH SOUTHWARDLY 103 FEET, MORE OR LESS TO LANDS
FLOWER FORMERLY OF WILLIAM D. RHINESMTTH; THENCE ALONG SAME EASTWARDLY
17.5 FEET, MORE OR LESS, TO LANDS NOW OR FORMERLY OF JOHN PARK; THENCE
ALONG SAID LANDS OF PARK NORTHWARDLY 103 FEET, MORE OR LESS TO THE RIGHT
OF WAY OF EAST CHAPEL AVE., THE PLACE OF BEGINNING.
HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED
AS 162 EAST CHAPEL AVENUE AKA 162 EAST CHAPEL ALLEY, CARLISLE, PA, 17013.
BEING THE SAME PREMISES WHICH MICHAEL C. DIEHL, TRUSTEE FOR COLIN
DIEHL, A MINOR UNDER DECLARATION OF TRUST, BY DEED DATED MAY 14, 2004 AND
RECORDED MAY 14, 2004 IN AND FOR CUMBERLAND COUNTY,, PENNSYLVANIA, IN DEED
BOOK VOLUME 263, PAGE 65, GRANTED AND CONVEYED UNTO JENNY R. HUBER, SINGLE
PERSON.
TAX MAP NO.. 03-21-0320-116.
Zucker. Goldluxgc- Ackcnuan,11C
F(T-1.3 8746
EXHIBIT B
Zucker, Goldberg & Ackerman, !1C
FCP-138746
i UNITED STATES
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Thin ctAirrreme orwim provides evfdanee thst mail has been pmox' d to U PS® fa mf6n& TMa
sod lotereadwal -9.
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c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 301
rMountainside, NJ 07092
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FIRST FRANKLIN, A DIVISION OF NATIONAL CITY
BANK OF INDIANA
2150 NORTH STREET, SUITE 100
SAN JOSE, CA 95131
County of P.Q.: CUMBERLAND
PS Forth 3817, April 2007 PSN 7530-02-000-9065
UNITED STWES.
POSTAL SERM&
This Catitham orMailing provides ovWt a that mail his been prese ded to USPS6 row tatting This K
and into maDOeal mail.
Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 301
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One Courthouse Square
Carlisle, PA 17013 ?"Ian
County of P.Q.: CUMBERLAND
PS Form 3817, April 2007 PSN 7530-02.000-9065
Page 1 of 4
UNITED. STATES
POSTAL SERVICEa
This Catifiate of Mailing Provides tvdaacv that mall his b- laexnld to USPS® for aul I Ing. n
and imNwniorul malt.
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c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 301
Mountainside, NJ 07092
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FCP-138746rdc'TEAM D n
Tv' COMMONWEALTH OF PENNSYLVANIA Postmark,11ore
DEPARTMENT OF WELFARE
P.O. Box 2675
Harrisburg, PA 17105
County of P.Q.: CUMBERLAND
PS Form 3817, April 2007 PSN 7530-02-000-9065
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c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 301
Mountainside, NJ 07092
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S 0004282036 OCT 20 2010
mAILID FROM ZIP CODE 0 70 92
FCP-138746Jjde TEAM D
T" CUMBERLAND COUNTY DOMESTIC RELATIONS Postmark H=
OFFICE
Domestic Relations Section
13 N. Hanover Street
PO Box 320
Carlisle, PA 17013
County of P. Q,: CUMBERLAND
PS Form 3817, April 2007 PSN 7530.02-000-9065
C. C'
Page 2 of 4
UNITEDST?ITES e JE3 P?T4
- POSTAL SERVICE
? t?rv swnes
Tlda Ccalk a of Main prdida evl&r""mal ba bew peaenled ro USM Ar rmfllK. T 0 2 1M $01.100
aid baemc?oanal all. 0004282036 OCT 20 2010
Scott A. Dietterick, Esquire - MAILED FROM ZIP CODE 67092
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 301
Mountainside, NJ 07092
FCP-138746rde TEAM D
T' PA DEPT. OF REVENUE- INHERITANCE TAX DIV:
Dept. 280601
Harrisburg, PA 17I28-0601
vdi c Here
04-1?
County of P.Q.: CUMBERLAND
PS Form 3817, April 2007 PSN 7530.02.000-9065
UNITEUSTATES
7 .naaa+?+ otrmtr sowts
P2POSIALSERVIC& im $ 01.90°
a2
000428203e ocTao 2010
This CvtMfl efMelgag pipw a ldeaee iba mall bo b? prewaed to U.V50 far mmls n;3 foCODE 07092 ...
and iotematleal mil. aE pl,F,ILED FROM
Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 301
Mountainside, NJ 07092
FCP-(38746/jde TEAM D o$'f FJ!zZ11
T- UNKNOWN TENANT OR TENANTS
162 EAST CHAPEL AVENUE AKA 162 EAST CHAPEL r
ALLEY
CARLISLE, PA 17013
County of P.Q. CUMBERLAND
PS Form 3817, April 2007 PSN 7530.02.000-9065
Page 3 of 4
UNITED STATES
POSTAL SERVICEe
This c-ded0*f & I% w-dea wAdatea *k watau b4, pmaged to USPSO %r onw6: Thi
and Iacmatimal maiL
Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 301
Mountainside, NJ 07092
jg?
e,
ara[v Bow?tes
0210 $ Bin !aO
0004282036 CCT20 2010
if'r IVAIMD' n! OMWCaDEJ7092
FCP-13874We TEAM D
UNKNOWN SPOUSE PostmerkI*m
162 East Chapel Avenue a/Va 162 East Chapel Alley
Carlisle, PA 17013
County of P.Q.: CUMBERLAND
PS Forth 3817, April 2007 PW 7530-02-000-9065
TH1b
N;.-.,
Page 4 of 4
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,' PENNSYLVANIA
US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CIVIL DIVISION
THE HOLDERS OF THE FIRST FRANKLIN MORTGAGE
LOAN TRUST MORTGAGE PASS-THROUGH NO.: 2010-33538
CERTIFICATES, SERIES 2006-FF2,
Plaintiff,
vs.
Jenny R. Huber
Defendant.
NOTICE TO UENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129(b)
TO:
CUMBERLAND COUNTY TAX CLAIM BUREAU UNKNOWN SPOUSE
Cumberland County Courthouse 162 East Chapel Avenue a/k/a 162 East Chapel
One Courthouse Square Alley
Carlisle, PA 17013 Carlisle, PA 17013
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF WELFARE
P.O. Box 2675
Harrisburg, PA 17105
PA DEPT. OF REVENUE- INHERITANCE TAX
DIVISION
Dept. 280601
Harrisburg, PA 17128-0601
UNKNOWN TENANT OR TENANTS
162 EAST CHAPEL AVENUE AKA 162 EAST
CHAPEL ALLEY
CARLISLE, PA 17013
FIRST FRANKLIN, A DIVISION OF
NATIONAL CITY BANK OF INDIANA
2150 NORTH STREET, SUITE 100
SAN JOSE, CA 95131
CUMBERLAND COUNTY DOMESTIC RELATIONS
OFFICE
Domestic Relations Section
13 N. Hanover Street
PO Box 320
Carlisle, PA 17013
Zucker, Goldberg & Ackerman, LLC
FCP-138746
138746DIO04CIO202010PI
I
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common
Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will
be exposed to Public Sale in:
the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013
On 12/08/2010 at 10:00am, the following described real estate which Jenny R. Huber, single person are
the owners or reputed owners and on which you may hold a lien or have an interest which could be
affected by the sale of:
162 EAST CHAPEL. AVENUE AKA 162 EAST CHAPEL ALLEY,
CARLISLE, PA 17013
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
Zucker, Goldberg & Ackerman, LLC
FCP-138746
138746D1004C10202010P2
The said Writ of Execution has been issued on a judgment in the action of
US Bank National Association, as trustee for the
holders of the First Franklin Mortgage Loan Trust
Mortgage Pass-Through Certificates, Series 2006-FF2
Plaintiff
vs.
Jenny R. Huber, et al
Defendant(s)
at EX. NO. 2010-03538 in the amount of $61797.69 plus interest and costs.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days
from the sale date.
Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the Office of the
Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of
the Sheriff.
If you have any questions or comments with regard to the Sheriffs Sale or this Notice, you
should contact your attorney as soon as possible.
Dated: October 20, 2010
ZUCICEFtt"rCrrDB!.T& P;CIC.ERI+lIAN LLC
Scott A. Dietterick, Esquire; PA I.D. #55650
Kimberly A. Bonner, Esquire; PA I.D. #89705
Joel A. Ackerman, Esquire; PA T.D. #202729
200 Sheffield Street, Suite 301
Mountainside, NJ 07092
File No.: FCP-138746
(908) 233-8500; (908) 2.33-1390 FAX
E-mail: Office@zuckerf),,oldberg.com
Zucker, Goldberg & Ackerman, LLC
FCP-138746
138746D1004C1O20201OP3
Exhibit "A"
LEGAL DESCRIPTION
ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE BOROUGH OF CARLISLE,
CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCHBED AS
FOLLOWS, TO WIT:
BEGINNING AT A POINT, AT LANDS NOW OR FORMERLY OF JOHN PARK AT THE
SOUTHERN RIGHT OF WAY LINE OF EAST CHAPEL AVE., 17,5 FEET, MORE OR LESS
TO LANDS NOW OR FORMERLY OF CHARLES T. RHINESMITH; THENCE ALONG
SAID LANDS OF CHARLES T. RHINESMIT14 SOUTHWARDLY 103 FEET, MORE OR
LESS TO LANDS FLOWER FORMERLY OF WILLIAM D. RHINESMITH; THENCE
ALONG SAME EASTWARDLY 17.5 FEET, MORE OR LESS, TO LANDS NOW OR
FORMERLY OF JOHN PARK; THENCE ALONG SAID LANDS OF PARK
NORTHWARDLY 103 FEET, MORE OR LESS TO THE RIGHT OF WAY OF EAST
CHAPEL AVE., THE PLACE OF BEGINNING.
HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND
NUMBERED AS 162 EAST CHAPEL AVENUE AKA 162 EAST CHAPEL ALLEY,
CARLISLE, PA, 17013.
BEING THE SAME PREMISES WHICH MICHAEL C. DIEHL, TRUSTEE FOR
COLIN DIEHL, A MINOR UNDER DECLARATION OF TRUST, BY DEED DATED MAY
14, 2004 AND RECORDED MAY 14, 2004 IN AND FOR CUMBERLAND COUNTY,
PENNSYLVANIA, IN DEED BOOK VOLUME 263, PAGE 65, GRANTED AND
CONVEYED UNTO JENNY R. HUBER, SINGLE PERSON.
TAX MAP NO.: 03-2I-0320-116.
Zucker, Goldberg & Ackerman, LLC
Field2»-((Field1»
« Field l »D 1004C02/12/2008P4
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
I COURTHOUSE SQUARE
CARLISLE, PA 17013
717-240-6370
Instrument Number - 201101266
Recorded On 1/10/2011 At 11:29:23 AM * Total Pages - 5
* Instrument Type - DEED-SHERIFF'S
Invoice Number - 80128 User ID - KW
* Grantor - HUBER,, JENNY R
* Grantee - FIRST FRANKLIN MORTGAGE LN TR SERIES 2006-1772
* Customer - 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
Certification Page
DO NOT DETACH
This page is now part
of this legal document.
ROD ARCHIVES FEE $3.00
CARLISLE AREA SCHOOL $0.00
DISTRICT
CARLISLE BOROUGH $0.00
TOTAL PAID $63.00
I Certify this to be recorded
in Cumberland County PA
t.
A
RECORDER O D - Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
OQON2A
i!! I?I?illll 11111!1 ?I I Ifl
• lye
Know all Men by these Presents
???IIYIII?INII
Tax Parcel No. 03-21-0320-116
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 US Bank National Association, as Trustee for the
Holders of the First Franklin Mortgage Loan Trust Mortgage Pass-Through
Certificates, Series 2006-FF2
Writ No. 2010-3538 Civil Term
US Bank National Association, as Trustee for the
Holders of the First Franklin Mortgage Loan Trust Mortgage Pass-Through
Certificates, Series 2006-FF2
Vs
Jenny R. Huber
ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE BOROUGH OF CARLISLE,
CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCHBED AS
FOLLOWS, TO WIT:
BEGINNING AT A POINT, AT LANDS NOW OR FORMERLY OF JOHN PARK AT THE
SOUTHERN RIGHT OF WAY LINE OF EAST CHAPEL AVE., 17,5 FEET, MORE OR LESS
TO LANDS NOW OR FORMERLY OF CHARLES T. RHINESMITH; THENCE ALONG
SAID LANDS OF CHARLES T. R.EINESMITH SOUTHWARDLY 103 FEET, MORE OR
LESS TO LANDS FLOWER FORMERLY OF WILLIAM D. RFIINESMITH; THENCE
ALONG SAME EASTWARDLY 17.5 FEET, MORE OR LESS, TO LANDS NOW OR
FORMERLY OF JOHN PARK; THENCE ALONG SAID LANDS OF PARK
NORTHWARDLY 103 FEET, MORE OR LESS TO THE RIGHT
OF WAY OF EAST CHAPEL AVE., THE PLACE OF BEGINNING.
HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND
NUMBERED AS 162 EAST CHAPEL AVENUE AKA 162 EAST CHAPEL ALLEY,
CARLISLE, PA, 17013. BEING THE SAME PREMISES WHICH MICHAEL C. DIEHL,
'T'RUSTEE FOR COLIN DIEHL, A MINOR UNDER DECLARATION OF TRUST, BY DEED
DATED MAY 14, 2004 AND RECORDED MAY 14, 2004 IN AND FOR CUMBERLAND
COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 263, PAGE 65, GRANTED AND
CONVEYED UNTO JENNY R. HUBER, SINGLE PERSON.
TAX MAP NO.: 03-21-0320-116.
The same having been sold by me to the said grantee on the 8th day of December
Axn7o Domini Two Thousand and Nine (2010) after due advertisement according to law,
under and by Virtue of a Writ of Execution issued on the 9"' of September Anno
Domini 2010. out of the Court of Common Pleas of Cumberland County, Pennsylvania, as
of Civil Term, Two Thousand and Ten (2010) Number 3538 at the suit of
US Rank National Association, as Trustee for the Holders of the First Franklin
Mortgage Loan Trust Mortgage Pass-Through Certificates, Series 2006-FF2 -vs-
Jenny R. Huber
In Witness Whereof, I have hereunto affixed my signature this 3rd
Anno Domini Two Thousand and Eleven (2011)
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 3rd day
Of January Anno Domini Two Thousand and Eleven (2011)
s f/ J
."Onotaty.Cumberla (?urrt? Carlisle. PA
My Commfsaion Exoras a Flrst7rla+daY of Jan 2014
I hereby certify that the residence
And Post Office address of the
Within Grantee is
3815 South Temple
Salt Lake City, UT 84115
Richard W. Stewart
Solicitor
day of January
A. ZUCKER
RCHAEL S.
AC KERMAN
ZUCKER, GOLDBERG & ACKERMAN,
FOUNDED IN 1923
JOELACKERMAN• r LC AS ZUCKER&GOLDBERG
FRANCFS GAMBARDELLA
BRIAN C. MTCHOLAS A L
ATTQRNEYS AT LAW 1918.1979)
MAURICE J. ZUCKER
LOUIS D. GOLDBERG 1923.19671
STEVEN D. KROL
FRIC[R. PPARKER A ORD
200 SHEFFIELD STREET- SUITE 301
LEONARD H. 929-1979))
11,949-1981
BENJA
JANET V. KEYMETIAN m P.O. BOX 1024
DENISF CARLON A
ANNIE CHA A MOUNTAINSIDE, NJ 07092-0024 Pennsylvania Office:
MONIKA S. PUNDALIK
CHRISTINE E. POTTER
TELEPHONE: 908-233-8500 P.O. Box GSO
Hershey, PA 17033
BRIAN W. BANASIAK FACSIMILE: 908-233-1390
RYAN S. MALC
JENFE K. CICCARELLI A E-MAIL: office/?'?zucker oldber com
Li $ g of COUNSEL:
• ALSO MEMBER OF NY, PA AND CA BAR SCOTT A. DIETTERICK, ES Q. V
0 AI-SO MEMBER OF NY AND ME BAR For payoff/reinstatement figures KIMBERLY A. BONNER ES i?
A ALSO MEMBER OF NY BAR Please send your request to. zuckdyoldberg.com/pr ESQ 0 JAIME R. ACKEftMA .
m ALSO MEMBER OF MA AND ND BAR
Y MEMBER OF PA BAR ONLY REPLY TO NEW JERSEY ADDRESS
FCP-138746-EV December 22, 2010
Former Owner Article Certified And/or Tenant, Known or Unknown (s) at
162 E. Chapel Avenue AKA 162 East Chapel Alley 0 3901 9458 5507 9101
Carlisle, PA 17013
SENDERS RECORD
RE: DEMAND FOR POSSESSION OF PROPERTY
Dear Occupant: (s)
On December 8, 2010 the property located at 162 E. Chapel Avenue Carlisle, PA 17013 was sold before
the Courthouse door of Cumberland County, PA during the legal hours of sale. .You are hereby notified that
possession is demanded by US Bank National Association, as trustee for the' holders of the First Franklin
Mortgage Loan Trust Mortgage Pass-Through Certificates, Series 2006-FF2, which was the highest bidder at the
sale, and now owns the property.
If you are the former owner of the property, or the child, spouse, or parent of the former owner, and
you do not immediately relinquish possession, dispossessory proceedings will be initiated in the Court of
Cumberland County, PA to evict you.
If you are a tenant of the former owner of the property, and not the child, spouse, or parent of the
former owner of the property, you may be entitled to additional rights as provided in the Protecting Tenants at
Foreclosure Act of 2009, including the right to remain in the property for 90 days from the date of receipt of this
notice, before dispossessory proceedings are initiated against you. In order for us to determine on behalf, US
Bank National Association, as trustee for the holders of the First Franklin Mortgage Loan Trust Mortgage
Pass-Through Certificates, Series 2006-FF2 what rights you may have under the Protecting Tenants at
Foreclosure Act of 2009, you must immediately forward to us the following:
(a) a copy of your written lease (if an oral lease you must provide us a summary of the terms of your oral
lease, including: the term of the lease, monthly rental amount, and all other relevant lease terms);
(b) proof of your alleged monthly rental amount (proof may be in the form of a copy of your lease
showing the rent amount, or, if an oral lease, copies of cancelled checks or money orders);
(c) proof that all monthly rental payments due under the lease have been paid to date (proof may be in
the form of copies of cancelled checks, money orders, or a signed statement from your landlord
stating that you have paid your rent in full as required by your lease);
(d) the names of all occupants of the Property who are over 18 years of age; and
(e) 'Indicate whether you are a Section 8 tenant.
"EXHIBIT B"
Effective immediately, your rental payments must be made by money order, cashier's check, or certified check
(00 NOT send cash or personal check), and should be made payable to:
US Bank National Association, as trustee for the holders
of the First Franklin Mortgage Loan Trust Mortgage
Pass-Through Certificates, Series, 2006-FF2
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, 301
Mountainside, NJ 07092.
On your Cashier's Check or Money Order, clearly indicate your Name and the Property Address, including
your Apartment Number or Location.
For any questions regarding your rights as a post-foreclosure tenant, contact Appropriate Eviction
Processor at 908-233-8500, Ext. 375 Please note that you may wish to consult an attorney to help you
determine what rights you may have, if any, under the Protecting Tenants at Foreclosure Act of 2009_
If you are an active member of the United States Armed Forces, you may be entitled to rights as provided
in the Servicemembers Civil Relief Act, in such case, you or your attorney should contact this law firm
immediately to determine if you fall under the protection of the Act.
All questions regarding the property should be addressed to the following Agent:
Bob Hoobler at Phone# 717-920-6400
Sincerely,
ZUCKER, GOLDBERG & ACKERMAN, LLC
Gamalielle Geffrard- ext. 375
T5NA1VT QUESTIONNAIRE Our File #: FCP-138746-EV
PROPERTY ADDRESS: 162 E. Chapel Avenue AKA 162 East Chapel Aucy Carlisle, PA 17013
YOUR NAME (Please Print Clearly):
TELEPHONE NUMBER WHERE YOU CAN BE EASILY REACHED: ( )
NUMBER OF PEOPLE LIVING WITH YOU: # ADULTS # CHILDREN
NAME OF OTHER ADULTS LIVING WITH YOU,
1. 2. 5. 7.
3. 4. 6. 8.
YOUR FLOOR/UNIT#
DO YOU HAVE A LEASE?
HOW LONG HAVE YOU LIVED AT THIS PROPERTY?
HOW MUCH DO YOU PAY MONTHLY FOR RENT?
DO YOU PAY FOR ANY UTILITIES? WATER GAS PSE&G
WHO WERE YOU PAYING YOUR RENT TO?
ARE YOU RELATED TO THE FORMER OWNER?
DO YOU HAVE HELP FROM SECTION 8 OR OTHER AGENCY TO PAY YOUR RENT?
NO YES IF YES, PLEASE PROVIDE COPY OF YOUR SECTION 8 CONTRACT
AND NAME/TELEPHONE NUMBER OF YOUR CASE WORKER.
ARE YOU INTERESTED IN RECEIVING INFORMATION ABOUT BUYING THIS HOME FROM THE NEW OWNER? (The
price of the home would be based on fair market value and the current condition of the home).
Yes, I am interested No, I do not want to buy.
DO YOU PLAN TO MOVE OUT WITHIN THE NEXT: (please circle one)
15 days 30 days 60 days 90 days
ARE YOU INTERESTED IN ENTERING INTO A MONTH TO MONTH LEASE AGREEMENT WITH THE NEW OWNER?
-- Yes No
Please check here if you have moved out
I have moved out and removed all of my personal belongings- you may take possession of my unit.
I moved out, but need to get back in to get the rest of my things- please contact me.
Please sign and date this form here: Dated:
g?Pes Pos 4"
•
UNITED STATES ? "V ?rN EY 6pWE5
- 02 1M $01-150
0004282036 DEC 23 2010
POSTAL SERVICEn MAILED FROM ZIP CODE 0 70'92
This ceoificsie or Mailing provides evidence that mail has been prexnied to USPS® for mailing This form mar .... ........... _„.._.._
and imemalional mail.
From: Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, N3 07092
XCP-138746-EV/gg'rEAM D
T° Former Owner And/Or Current Occupant (s), Known or P ostmark Here
Unknown at:
162 East Chapel Avenue &Wa 162 East Chapel Alley
Carlisle, PA 17013
County of P.Q-: CUMBERLAND
PS Form 3817, April 2007 PSN 7530-02-000-9065
i
r. 'f
701
3S G?
LEONARD B. ZUCKER
MICHAEL S. ACKERMAN
JOEL ACKERMAN*
FRAIMCESC,'AABARDELLA
BRIAN C. NICHOLAS 0
STEVEN D. KROL
CHRISTOPHER G. FORD
ERIC R. PARKER A
JANET V, KEYMETIAN n
DENISE CARLON A
ANNIE CHA A
MONIKA S. PUNDALIK
CHRISTINE E. POTTER
BRIAN W. BANASIAK
RYAN S. MALC
JENEE K. CICCARELLI A
* ALSO MEMBER OF NY, PA AND CA BAR
0 ALSO MEMBER OF NY AND ME BAR
A ALSO MEMBER OF NY BAR
oo ALSO MEMBER OF MA AND ND BAR
41 MEMBER OF PA BAR ONLY
XCE-144379-EV
ZUCKER, GOLDBERG & ACKERMAN,
LLC
ATTORNEYS AT LAW
200 SHEFFIELD STREET- SUITE 301
P.O. BOX 1024
MOUNTAINSIDE, N! 07092-0024
TELEPHONE: 908-233-8500
FACSIMILE: 908-233-1390
E-MAIL: office@zuckergoldberg.com
For payoff `/reinstatement figures
Please send your request to: zuckeigoldberg com/pr
REPLY TO NEW JERSEY ADDRESS
October 27, 2010
Former Owner
And/or Tenant, Known or Unknown (s) at:
3343 Huntingdon Street
Philadelphia, PA 19132
RE: DEMAND FOR POSSESSION OF PROPERTY
Dear Occupant: (s)
ESQ. 0
FOUNDED IN 1923
AS ZUCKER & GOLDBERG
MAURICE J. ZUCKER 1918-1979
LOUIS D. GOLDBERG 1923-1967
LEONARD H. GOLDBERG 1929-1979
BENJAMIN WEISS 11949-19811
Pennsylvania Office:
P.O. Box 650
Hershey, PA 17033
OF COUNSEL:
SCOTT A. DIETTERICK, ESQ *
KIMBERLY A. BONNER ESO. *
JAIME R. ACK _ MATT,
? 5i!?7 5141.,
On October 5, 2010 the property located at 3343 Huntingdon Street Philadelphia, PA 19132 was sold
before the Courthouse door of Philadelphia County, PA during the legal hours of sale. You are hereby notified
that possession is demanded by NovaStar Mortgage, Inc., which was the highest bidder at the sale, and now
owns the property.
If you are the former owner of the property, or the child, spouse, or parent of the former owner, and
you do not immediately relinquish possession, dispossessory proceedings will be initiated in the Court of
Philadelphia County, PA to evict you.
If you are a tenant of the former owner of the property, and not the child, spouse, or parent of the
former owner of the property, you may be entitled to additional rights as provided in the Protecting Tenants at
Foreclosure Act of 2009, including the right to remain in the property for 90 days from the date of receipt of this
notice, before dispossessory proceedings are initiated against you. In order for us to determine on behalf,
NovaStar Mortgage, Inc. what rights you may have under the Protecting Tenants at Foreclosure Act of 2009, you
must immediately forward to us the following-
(a) a copy of your written lease (if an oral lease you must provide us a summary of the terms of your oral
lease, including: the term of the lease, monthly rental amount, and all other relevant lease terms);
(b) proof of your alleged monthly rental amount (proof may be in the form of a copy of your lease
showing the rent amount, or, if an oral lease, copies of cancelled checks or money orders);
(c) proof that all monthly rental payments due under the lease have been paid to date (proof may be in
the form of copies of cancelled checks, money orders, or a signed statement from your landlord
stating that you have paid your rent in full as required by your lease);
(d) the names of all occupants of the Property who are over 18 years of age; and
(e) indicate whether you are a Section 8 tenant.
Effective immediately, your rental payments must be made by money order, cashier's check, or certified check
(DO NOT send cash or personal check), and should be made payable to:
. , .
NovaStar Mortgage, Inc.
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, 301
Mountainside, NJ 07092
On your Cashier's Check or Money Order, clearly indicate your Name and the Property Address, including
your Apartment Number or Location.
For any questions regarding your rights as a post-foreclosure tenant, contact Appro iate Eviction
Processor at: 906-233-8500 Ext. 375 . Please note that you may wish to consult an attorney to help you
determine what rights you may have, if any, under the Protecting Tenants at Foreclosure Act of 2009.
If you are an active member of the United States Armed Forces, you may be entitled to rights as provided
in the Servicemembers Civil Relief Act. In such case, you or your attorney should contact this law firm
immediately to determine if you fall under the protection of the Act.
All questions regarding the property should be addressed to the following Agent:
Sincerely,
ZUCKER, GOLDBERG & ACKERMAN, LLC
Gamallelle Geffrard- ext. 375
TENANT QUESTIONNAIRE Our File #. XCE-144458-EV
AROPERTYADDRESS: 3343 Huntingdon Street Philadelphia, PA 19132
YOUR NAME (Please Print Clearly):
TELEPHONE NUMBER WHERE YOU CAN BE EASILY REACHED:
NUMBER OF PEOPLE LIVING WITH YOU: # ADULTS # CHILDREN
NAME OF OTHER ADULTS LIVING WITH YOU:
1. 2. S. 7.
3. 4. 6. 8.
YOUR FLOOR/UNIT#
DO YOU HAVE A LEASE?
HOW LONG HAVE YOU LIVED AT THIS PROPERTY?
HOW MUCH DO YOU PAY MONTHLY FOR RENT?
DO YOU PAY FOR ANY UTILITIES? WATER GAS PSE&G
WHO WERE YOU PAYING YOUR RENT TO?
ARE YOU RELATED TO THE FORMER OWNER?
DO YOU HAVE HELP FROM SECTION 8 OR OTHER AGENCY TO PAY YOUR RENT?
NO YES IF YES, PLEASE PROVIDE COPY OF YOUR SECTION 8 CONTRACT
AND NAME/TELEPHONE NUMBER OF YOUR CASE WORKER.
ARE YOU INTERESTED IN RECEIVING INFORMATION ABOUT BUYING THIS HOME FROM THE NEW OWNER? (The
price of the home would be based on fair market value and the current condition of the home).
Yes, I am interested No, I do not want to buy.
DO YOU PLAN TO MOVE OUT WITHIN THE NEXT: (please circle one)
15 days 30 days 60 days 90 days
ARE YOU INTERESTED IN ENTERING INTO A MONTH TO MONTH LEASE AGREEMENT WITH THE NEW OWNER?
Yes No
Please check here if you have moved out
I have moved out and removed all of my personal belongings- you may take possession of my unit.
I moved out, but need to get back in to get the rest of my things- please contact me.
Please sign and date this form here: Dated:
VERIFICATION
Scott A. Dietterick, esquire hereby states that he is attorney for 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 he is authorized to
Make this verification pursuant to Pa. R. C. P. 1024 (c) and that the statements made in
the foregoing pleading in the Civil Action Complaint In Ejctement are based upon
information supplied by Plaintiff and are true and correct to the best of his knowledge,
information and belief. Furthermore, it is the undersigned'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 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities.
Scott A Dietterick, EsquirePA I.D.. 455650
Kimberly A. Bonner, Esquire- PA l.D.
Joel A. Ackerman- PA I.D. 9202729
Ashleigh L. Levy- PA I.D. #306799
' Dated: 1 I
i
I
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
US Bank National Association, as trustee for the
holders of the First Franklin Mortgage Loan
Trust Mortgage Pass-Through Certificates, Serie:
2006-FF2,
Plaintiff,
vs.
Jenny R. Huber
Defendant.
CIVIL DIVISION
NO.: 2011-01217
U,)r --
LD -4c:)
C)
v c- -v c) o --n
=F
ZG rQ O
PRAECIPE TO SUBSTITUTE VERIFICATION PURSUANT TO PaR.C.P. 1024(c)
To the Prothonotary:
Please substitute the Verification of Co sel attached to iff's Complaint in the
above captioned-matter with the attached Verifi tion P ' t' f.
ZUCKER, B G A RfAAN, LLC
BY:
Dated: February 8, 2011 Scott . Die terick, Esquire; PA I.D. #55650
Kimbe Bonner, Esquire; PA I.D. #89705
Joel A. Ackerman, Esquire; PA I.D. 4202729
Ashleigh L. Levy, Esquire; PA I.D. 4306799
Attorneys for Plaintiff
FCP-138746/gg
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
Email: Office@zuckergoldberg.com
VERIFICATION
Adam Shields, Document Control Officer
I, , (title),
depose and say subject to the penalties of 18 Pa.C.S.A., sec. 4904 relating to unsworn
falsification to authorities that the facts set forth in the foregoing pleading are true and correct to
the best of my information, knowledge and belief.
By: US Bank National Association, as
trustee for the holders of the First
Franklin Mortgage Loan Trust
Mortgage Pass-Thr ugh
c es, S 2 2
Name-
Title:
Our File No:
Loan No.:
Borrower Name:
138746-EV
0011552163
Jenny R. Huber
Zucker, Goldberg & Ackerman, LLC
XCP-138746-EV
138746-EVQ1002C01212011P8
4.
RECORDING REQUESTED BY:
Select Portfolio Servicing, Inc.
Document ControIDepartment
P.O. Box 65250
Salt Jake City, UT 84165-0250
SPACE ABOVE THIS LINE FOR RECORDER'S USE
LIMITED POWER°OF ATTORNEY
U.S. BANK NATIONAL Assoculaox ("U.S. Bank'), a national banking association organized and existing under
the laws of the United States of A.taerica, with an office at 180 East Fifth Street, Corporate Trust, 2nd Floor, St Paul,
MN 55101 hereby constitutes and appoints SELECT Poiiwouo Stttevtpmtc, b;C. ("SPS"), and in its name,
aforesaid Attomcy-litiFact, by and through any officer appointed by the Board of Directors of SPS, to execute and
acknowledge in writing or by facsimile stamp all documents ,cuatomarily and reasonably necessary and appropriate
for the tasks described is the items (1) through (4) beiov, provided, however, that the documents described below
may only be executed and delivered by such Attomeys-In Fact if such documents are required or permitted under
the terms of the Seamtization Servicing Agreement dated as of February 1, 2006, among SPS, successor servieer to
National City Horne Loan Services, Inc., as Servicer, Lehman Brothers Holdings Inc., as Seller, Aurora Loan
Services LLC, as Master Servioer, and U.S. Bank, as Trustee, relating to First Franklin Mortgage Loan Trust
Mortgage Psss-Through Certificates, Series 2006-M and no power is granted hereunder to take any action that
would be adverse to the interests of the Trustee. This Limited Power of Attorney is being issued in connection with
SPS's responsibilities to service certain mortgage loans (the "Loanel held by U.S. Bank in its capacity as Trustee.
These Loans are comprised of Mortgages, Deeds of Trust, Deeds to Secure Debt and other form of Security
instruments (collectively, the "Security Instruments!) and the Notes secured thereby.
Demand, sue for, recover, collect and receive each and every sum of money, debt, account and interest
(which now is, or hereafter shall become due and payable) belonging to or claimed by U.S. Bank, and to
use or tape any lawful means for recovery by legal process or otherwise.
Transact business of any kind regarding the Loans, and obtain an interest therein and/or building thereon,
as U.S. Bank act and deed, to contact for, purchase, receive and take possession and evidence of title in and
to the property and/or to secure payment of a promissory note or performance of any obligation or
agnc=nt
Execute bonds, notes, mortgages, deeds of trust and other contracts, agreements and instruments regarding
the Borrowers and/or the Property, including, but not limited to, the execution of releases, satisfactions,
assignments, sud other insrments pcrtauui ag to mortgages or deeds of trust, and execution of deeds and
associated instruments, if any, conveying the Property, in the interest of U.S. Bank_
4. Endorse on behalf of the undersigned all checks, drafts and/or other negotiable instruments made payable
to the undersigned .
The Trustee shall be entitled to the indemnification provided by the Servicer in the Pooling and Servicing
Agreement as if set forth herein in connection with the actions of the Servicer under this Limited Power of
Attorney.
WITNESS my hand and seal this 17'h day of October 2008.
Witness: D
Witness: Joan CUbb
Attest Paul J. Gobin,
Account Administrator
U.S. Bank tioud soci , as Trustee'
By:
J B Vice Presi
de?-
By:
vid clos, , Vice resident
FOR CORPORATE ACKNOWLEDGMENT
State of Massachusetts
County of Suffolk
On this 172' of October 2008, before me, the undersigned,' a Notary Public in and for said County and State,
personally appeared Jams H. Byrnes and David Duclos, personally known to me (or proved to me on the basis of
satisfactory evidence) to be the persons who executed the within instrument as Vice President and Vice President of
U.S. Bank National Association, and known to me to be thepetson who executed the within instrument on behalf of
the corporation therein named, and acknowledge to me that such corporation executed the within iastnrment
pursuant to its by-laws or a resolution ofits Board of Directors.
offic" 60M. 4
WITNESS my hand and ate`gpA ('U
{otiV tt.$
Signature:
Y uo i - off/
My commission expir /1112014 s
-s,"L? ROftato
1' pll
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CIVIL DIVISION
THE HOLDERS OF THE FIRST FRANKLIN MORTGAGE
LOAN TRUST MORTGAGE PASS-THROUGH NO.: 2011-01217
CERTIFICATES, SERIES 2006-FF2,
Plaintiff,
vs.
Jenny R. Huber
Defendant.
PRAECIPE TO REINSTATE COMPLAINT IN-EJECTMENT
TO THE PROTHONOTARY:
Please mark the Complaint In-Ejectment filed at the above-captioned
term and number reinstated.
G - --t
rn '10
- C
Zr
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TUCKER, GOLDB RG & CKER AN, LLC
BY:
Dated: February 18, 2011 Scott A. Dietteri , Esquire; PA I.D. 455650
Kimberly A. Bonner, Esquire; PA I.D. 489705
Joel A. Ackerman, Esquire; PA I.D. 4202729
Ashleigh L. Levy, Esquire; PA I.D. 4306799
Attorneys for Plaintiff
FCP-l 38746-EV/gg
200 Sheffield Street, Suite 101
Mountainside. NJ 07092
(908) 233-8500; (908) 233-1390 FAX
Email: Office@zuckergoldberg.com
OL.0 il6 06 t'd atkr
55 U
01 ws'
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
??3ttttt, of 41P1r1?iP??/???
4? _ T
Richard W Stewart
Solicitor
US Bank National Association
vs.
Jenny R. Huber
Case Number
2011-1217
SHERIFF'S RETURN OF SERVICE
02/25/2011 02:25 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on February
25, 2011 at 1425 hours, he served a true copy of the within Complaint in Ejectment, upon the within
named defendant, to wit: Jenny R. Huber, by making known unto herself personally, at 162 E. Chapel
Avenue, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to
her personally the said true and correct copy of the same.
SHERIFF COST: $33.40
February 28, 2011
NOAH CLINE, DEPUTY
SO ANSWERS,
RON Y R ANDERSON, SHERIFF
.,.? Cou!ify ?.iite S^e ff. Te eosoft. I %-.
W2
WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF THE FIRST
FRANKLIN MORTGAGE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES,
SERIES 2006-FF
VS. No. 11-1217 Civil Term
JENNY R. HUBER,
Costs
Attorney's $ 173.40
Plaintiff s $
Prothonotary $ 2.00
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND:
To the Sheriff of Cumberland County, Pennsylvania
(1) To satisfy the judgment for possession in the above matter you are directed to deliver
possession of the following described property to: (Plaintiff (s))
US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF THE FIRST
FRANKLIN MORTGAGE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES,
SERIES 2006-FF, 3815 SOUTH TEMPLE, SALT LAKE CITY, UT 84115
being: (Premises as follows):
162 EAST CHAPEL AVENUE, CARLISLE, PA 17013
(2) To satisfy the costs against the defendant (s) you are directed to levy upon any
property of the defendant (s) and sell his/her (or their) interest therein.
David D uell, Protho tary,
Common Pleas Court o Cumberland County, PA
Date April 4, 2011
(Seal)
2of2
No 11-1217 Civil Term
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE HOLDERS OF
THE FIRST FRANKLIN MORTGAGE LOAN TRUST MORTGAGE PASS-
THROUGH CERTIFICATES, SERIES 2006-FF
VS.
JENNY R. HUBER
WRIT OF POSSESSION
P.R.C.P. 3160-3165 ETC.
Costs
Att'y $ 173.40
Plff (s) $
Prothy $ 2.00
Sheriff $
Plaintiff (s) attorney name and address:
SCOTT A. DIETTERICK, ESQUIRE, ZUCKER GOLDBERG &
ACKERMAN, LLC, 200 SHEFFIELD STREET, SUITE 101, MOUNTAINSIDE, NJ 07092
t#9o?-a33-SAC)
Attorney for Plaintiff (s)
Where papers may be served
By virtue of this writ, on the day of . I caused the within
named , to have possession of the premises described with the
appurtenances, and
Sworn and subscribed to before me this
Day of
Prothonotary
So Answers,
Sheriff
By
Deputy
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
US Bank National Association, as trustee for the
j holders of the First Franklin Mortgage Loan Docket No.: 2011-01217
' Trust Mortgage Pass-Through Certificates,
Series 2006-FF t'?i
Execution No.: -
Plaintiff, rn v
1 cn r" ? ?-?
Vs. -<>
.
- r- C)
C Cl.
j r
.
.
Jenny R. Huber
Defendant. '
PRAECIPE FOR WRIT OF POSSESSION
To the Prothonotary of Cumberland County:
Please issue a Writ of Possession in the above-referenced matter for Plaintiff's possession
of the;real property known and numbered as 162 EAST CHAPEL AVENUE, CARLISLE, PA
17013 and more particularly described on Exhibit "A" attached hereto.
ZUCKER GOt'DBE0 & ACKERMAN, LLC
Dated: March 28, 2011
50
tSO 'tu
Vol
u u
pc1 ?t
BY:
Scott A. Dietterick, Esquire; PA I.D. #55650
Kimberly A. Bonner, Esquire; PA.I.D. #89705
Joel A. Ackerman, Esquire; PA I.D. #202729
Ashleigh L. Levy, Esquire; PA I.D. #306799
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
File No.: XCP-1 3 8746-EV
(908) 233-8500; (908) 233-1390 FAX
E-mail: Office@zuckergoldberg.com
Zucker, Goldberg & Ackerman, LLC
XCP-138746-EV
a57
-----------
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
?d?ttl? G? ?tt#Ibp?f???
'F 5 '-E ?i - -»R;?F
FILED-OFFICE
OF THE PPOTHONOTARY
2011 APR 12 AM 9: 13
CUMBERLAND COUNTY
PENNSYLVANIA
US Bank National Association
Case Number
vs.
Jenny R. Huber 2011-1217
SHERIFF'S RETURN OF SERVICE
04/08/2011 02:55 PM - Tim Black, Deputy Sheriff, who being duly sworn according to law, states that on April 8, 2011 a
1455 hours, he served a true copy of the within writ of possession, in the above entitled action, upon the
within named defendant, to wit: Jenny R. Huber, by making known unto Jenny R. (Huber) Richwine,
personally, at 162 E Chapel Avenue, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at
the same time handing to her personally the said true and correct copy of the same.
SHERIFF COST: $36.00 SO ANSWERS,
April 11, 2011 RON R ANDERSON, SHERIFF
T' ack, Deputy
io CountySuite Sheriff, Teleosoft, Inc