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HomeMy WebLinkAbout11-8702SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor sta??''' pl' ?`arzut?rrrih FILED-O ffk"'E THE PROTHCPdOTA R 2012 JAN -6 AM 8: 50 CUMBERLAND COUNTY PENNSYLVANIA Deutsche Bank National Trust Company Case Number vs. Jeannie B. Mohmand (et al.) 2011-8702 SHERIFF'S RETURN OF SERVICE 12/27/2011 05:03 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on December 27, 2011 at 1703 hours, he served a true copy of the within Writ of Revival, upon the within named defendant, to wit: Joshua Kesler, by making known unto Rachel Crider, adult in charge at 245 N. 25th Street, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. A:2--t? LIA-22?:? GERALD WORTH INGTO PUTY 01/03/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Jeannie B. Mohamand, but was unable to locate her in his bailiwick. He therefore returns the within Writ of Revival as not found as to the defendant Jeannie B. Mohmand. Request for service at 4020 Lisburn Road, Mechanicsburg, Pennsylvania 17055 the Defendant was not found. Deputies were advised the current resident has resided at this address for over three years. SHERIFF COST: $74.00 SO ANSWERS, January 03, 2012 RON R ANDERSON, SHERIFF Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE UNDER THE POOLING & SERVICING AGREEMENT SERIES ITF RAST 2006-A3 VS Defendant JEANNIE MOHMAND, ET AL Person to be served: JEANNIE B. MOHMAND 817 MEADOW LANE CAMP HILL PA 17011 Attorney: PARKER McCAY, P.A. 9000 MIDLANTIC DRIVE SUITE 300 MT. LAUREL NJ 08054 Papers Served: WRIT OF REVIVAL IN THE COURT OF COMMON PLEAS OF CUMBERLAND CO., PENNSYLVANIA DOCKET NO. 11-8702 x?eC4k.1 .261 ;L l Am W.4/3 e4evv6ev-L? C Pet.#k yt vac t;& -:=Ikl AFFIDAVIT OF SERVICE (for use by Private Service) Cost of Service pursuant to R4:4-30 Service Data: Served Successfully _X Not Served Date: 04111!12 Time: 05:40PM Attempts: Delivered a copy to himiher personally X Left a copy with a competent household member over 14 years of age residing therein at place of abode. Left a copy with a person authorized to accept service, e.g. managing agent, registered agent, etc. Description of Person Accepting Service: Age: 50 Height: 5'3 Weight: 130 Hair: BLACK Name of Person Served and relationship/title MARIAM MOHMAND MEMBER OF HOUSEHOLD Sex: FEMALE Race: ASIA Unserved: III IIII?l?l?l??l? A?II??I?NI?I?I ( ) Defendant is unknown at the address furnished by the attorney ( ) All reasonable inquiries suggest defendant moved to an undetermined address ( ) No such street in municipality ( ) No response on: Date Time Date Time { ) Other. Comments or Remarks Subscribed and Sworn to me this day of ® 1 Notary Signature IIIIIIIII COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Jwane L. Augustine, Notary Public Silver Spiop Twp, Camberiaad Coaaty M eo®atbld0n ex trs 3 tdDber 11 2019 I, BRENDA FERRELL , was at time of service a competent adult not having a direct interest in the litigation. I declare under penalty of perjury that the foregoing is true and correct. Signature of Process Server Date DGR - THE SOURCE FOR LEGAL SUPPORT WORK ORDER No. 860236 1359 Littleton Road, Moms Plains, NJ 07950-3000 FILE No. 14997-0003 (973) 403-1700 Fax (973) 403-9222 PARKER McCAY P.A. By: Chandra M. Arkema, Esquire Attorney ID# 203437 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054 (856) 810-5815 Attorney for Plaintiff File #:14997-0003 Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series ITF RAST 2006-A3 888 East Walnut Street Pasadena, CA 91101 Plaintiff, V. Jeannie B. Mohmand 817 Meadow Lane Camp Hill, PA 17011 Defendant and Joshua Kesler 245 North 25"' Street Camp Hill, PA 17011 Terre-tenant Property: 245 North 25"' Street Camp Hill, PA 17011 i_? . ;'. ill P L J? :-j _ ( 10: 4i .1 CUMBER ; k;L; GGUN' PENINSYLVANIA : COURT OF COMMON PLEAS : CUMBERLAND COUNTY DOCKET NO. 06-6376/11-8702 CIVIL ACTION MORTGAGE FORECLOSURE PRAECIPE TO ENTER DEFAULT JUDGMENT ON THE WRIT OF REVIVAL TO THE PROTHONOTARY: Kindly enter Judgment by Default on the Writ of Revival in favor of Plaintiff, Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series ITF RAST 2006- A3 and against Defendant, Jeannie B. Mohmand and Terre-tenant, Joshua Kesler for failure to answer or lz.no +cr' otherwise respond to the Writ of Revival in Mortgage Foreclosure. ;It ?7? 7sa ss J?- 'qa. so r??[ ?7 R-*t- Q7` 01 k /4f&c .na` &C Pursuant to Pa.R.C.P. 237.1, I certify that written notice of the intention to file this Praecipe was mailed to the Defendant and Terre-tenant against whom judgment is to be entered more than ten (10) days prior to the date of the filing of this Praecipe and a copy of the notice is attached. PARKER McCAY P.A. Dated: May 24, 2012 BY: Chandra M. Arke , Esquire Attorney ID# 203437 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054 (856) 810-5815 PARKER McCAY P.A. By: Chandra M. Arkema, Esquire Attorney ID# 203437 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054 (856) 810-5815 Attorney for Plaintiff File #:14997-0003 Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series ITF RAST 2006-A3 888 East Walnut Street Pasadena, CA 91101 Plaintiff, V. Jeannie B. Mohmand 817 Meadow Lane Camp Hill, PA 17011 Defendant and Joshua Kesler 245 North 25 h Street Camp Hill, PA 17011 Terre-tenant Property: 245 North 25`x' Street Camp Hill, PA 17011 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 06-6376/11-8702 CIVIL ACTION MORTGAGE FORECLOSURE CERTIFICATION I, Chandra M. Arkema, Esquire, do hereby certify that the Defendant, Jeannie B. Mohmand was served with the Writ of Revival in Mortgage Foreclosure in this action, via DGR Legal Services on April 11, 2012 and that the Terre-tenant, Joshua Kesler, was served with the Writ of Revival by the Cumberland County Sheriff on December 27, 2012. True and correct copies of the Certificates of Service are attached hereto as Exhibit "A". PARKER McCAY P.A. Date: May 24, 2012 By: Chandra M. Arkema, Esquire EXHIBIT "A" Plaintiff DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE UNDER THE POOLING & SERVICING AGREEMENT SERIES ITF RAST 2D08-A3 Va Defendant JEANNIE MOHMAND, ET AL Person to be served: JEANNIE B. MOHMAND 817 MEADOW LANE CAMP HILL PA 17011 .IN THE COURT OF COMMON PLEAS OF CUMBERLAND CO., PENNSYLVANIA DOCKET NO. 114702 Attorney: AFFIDAVIT OF SERVICE PARKER McCAY, P.A (for WW by privets awrbe) 900o MIDLANTIC DRIVE SUITE 300 Cost of Service pursuant to R4-.4-30 MT. LAUREL NJ 08054 Papers Served: WW OFREVIV& Service Data: Served Successfully Not Served Date: Time: S' Attempts: Delivered a co to himfier personally Name of Parson Served and reiatlo-ns1hliMItle Left a copy with a competent household 9 {qR\AM I y ?IIYlIM4lYICA member over 14 years of age residing therein at place of abode. " MEMBERD : g- Left a copy with a person authorized to accept service, e.g. managing agent, registered agent, eta Description of Person Accepting Service: // Age: 50 Height CJ'3)" Weight: 130 Hair lt'?+ Sex _t tn&a Race: - diQt? C ?gta? Unserved: ( ) Defendant Is unknown at the address famished by the attGmey n (I? ( ) All reasonable Inquiries suggest defendant moved to an undetarmined address ( ) No such street in municipality ( } No response on: Date Time Date Time ( ) Other Comments or Remarks I ?j f1Gt{? 1- •'FE'RREA , was at Su2bsc?nbed and Sworn to me thig time of service a competent adult not having a direct i day of b-u Interest in the litigation. i dedare. under penalty of perjury that the foregoing Is true and correct. 101 slonw. Siv du a of Proo-O Serve' Date ????? DOR - THE SOURCE FOR LEGAL SUPPORT 1359 Littleton Road, Morris Plains, NJ 07950-3000 COMMONWHALTHOPPBNNSYLVANIA (973) 403-1700 Fax (973) 403-9222 WORK ORDER No. 860236 FILE No. 14997.0003 i s NOTARIAL SEAT, Joanne I.. Augustine, Notary Public Sliver Springs Twp, Cumberland County ! commUdon tree teatbg 11 2015 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ?titr at ??tir?6rrf Jody S Smith Chief Deputy. ??? ?o?t "` Richard W Stewart Solicitor OFFICE OF THE SHERIFF Deutsche Bank National Trust Company Case Number vs. 2011-8702 Jeannie B. Mohmand (et al.) SHERIFF'S RETURN OF SERVICE 12/27/2011 05:03 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on December 27, 2011 at 1703 hours, he served a true copy of the within Writ of Revival, upon the within named defendant, to wit: Joshua Kesler, by making known unto Rachel Crider, adult in charge at 245 N. 25th Street, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. GERALD WORTHINGTO PUTY 01/03/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Jeannie B. Mohamand, but was unable to locate her in his bailiwick. He therefore returns the within Writ of Revival as not found as to the defendant Jeannie B. Mohmand. Request for service at 4020 Lisburn Road, Mechanicsburg, Pennsylvania 17055 the Defendant was not found. Deputies were advised the current resident has resided at this address for over three years. SHERIFF COST: $74.00 January 03, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF ir. CountySuite Shentf, Teleosofi. 6-C. PARKER McCAY P.A. By: Chandra M. Arkema, Esquire Attorney ID# 203437 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054 (856) 810-5815 Attorney for Plaintiff File #:14997-0003 Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series ITF RAST 2006-A3 888 East Walnut Street Pasadena, CA 91101 Plaintiff, V. Jeannie B. Mohmand 817 Meadow Lane Camp Hill, PA 17011 Defendant and Joshua Kesler 245 North 25th Street Camp Hill, PA 17011 Terre-tenant Property: 245 North 25`" Street Camp Hill, PA 17011 : COURT OF COMMON PLEAS : CUMBERLAND COUNTY DOCKET NO. 06-6376/11-8702 CIVIL ACTION MORTGAGE FORECLOSURE VERIFICATION OF NON-MILITARY SERVICE I, Chandra M. Arkema, Esquire, hereby certify that I represent Plaintiff in the above entitled case; that I am authorized to make this Verification on behalf of Plaintiff, that the above-named Defendant, Jeannie B. Mohmand, is over 18 years of age; that the last known address of the Defendant, Jeannie B. Mohmand, is 817 Meadow Lane, Camp Hill, PA 17011; that the occupation of the Defendant, Jeannie B. Mohmand, is unknown; and that the Defendant, Jeannie B. Mohmand, is not known to be in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments thereto. I further certify that Plaintiff diligently attempted to obtain a full Social Security Number for Terre-tenant, Joshua Kesler, in order to run a search via the Department of Defense Manpower Data Center, but was unable to do so. However, to the best of Plaintiff's knowledge, Terre-tenant, Joshua Kesler, is not known to be in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments thereto. I also certify that the address of the Plaintiff is 888 East Walnut Street, Pasadena, CA 91101. I understand that the statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. PARKER McCAY P.A. BY: Dated: May 24, 2012 han ra M. Arkema, Esquire Attorney ID# 203437 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054 (856) 810-5815 Department of Defense Manpower Data Center Steers Resort Purgumt to Serveemembers Civil Relief Act Last Name: MOHMAND First Name: JEANNIE B Active Duty Status As Of: May-24-2012 Results as of : May-24-2012 07:23:14 SCRA 2.2 Active Duty Start Date Active Duty End Date status Service Component On Active Duty On Acttve Duty Status Date NA NA No NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days c( Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or HWHer Unit Was NotMed of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Data Order Nolltfcation End Date Status SeMce Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAH, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Yhot Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 at seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: hftp://www.defenselink.mil/faq/pis/PC09SLDR.htmi. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Report ID: U2MBFDB4P3 PARKER McCAY P.A. By: Chandra M. Arkema, Esquire Attorney ID# 203437 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054 (856) 810-5815 Attorney for Plaintiff File #:14997-0003 Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series ITF RAST 2006-A3 888 East Walnut Street Pasadena, CA 91101 Plaintiff, V. Jeannie B. Mohmand 817 Meadow Lane Camp Hill, PA 17011 and Defendant Joshua Kesler 245 North 25"' Street Camp Hill, PA 17011 Terre-tenant Property: 245 North 25"' Street Camp Hill, PA 17011 TO: Jeannie B. Mohmand 817 Meadow Lane Camp Hill, PA 17011 : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : DOCKET NO. 06-6376/11-8702 : CIVIL ACTION : MORTGAGE FORECLOSURE NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a JUDGMENT BY DEFAULT ON THE WRIT OF REVIVAL has been entered against you in the above proceeding and that enclosed herewith is a copy of all the (record) documents filed in support of the said judgment. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEY CHANDRA M. ARKEMA, AT TELEPHONE NO. (856) 596-8900 NOTICE REQUIRED BY THE FAIR DEBT COLLECTION PRACTICES ACT: WE ARE ATTEMPTING TO COLLECT A DEBT, AND ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. Prothon ry o umb d County PARKER McCAY P.A. By: Chandra M. Arkema, Esquire Attorney ID# 203437 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054 (856) 810-5815 Attorney for Plaintiff File #:14997-0003 Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series ITF RAST 2006-A3 888 East Walnut Street Pasadena, CA 91101 Plaintiff, V. Jeannie B. Mohmand 817 Meadow Lane Camp Hill, PA 17011 and Defendant Joshua Kesler 245 North 25"' Street Camp Hill, PA 17011 Terre-tenant Property: 245 North 25'h Street Camp Hill, PA 17011 TO: Joshua Kesler 245 North 25'e Street Camp Hill, PA 17011 : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : DOCKET NO. 06-6376/11-8702 : CIVIL ACTION : MORTGAGE FORECLOSURE NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a JUDGMENT BY DEFAULT ON THE WRIT OF REVIVAL has been entered against you in the above proceeding and that enclosed herewith is a copy of all the (record) documents filed in support of the said judgment. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEY CHANDRA M. ARKEMA, AT TELEPHONE NO. (856) 596-8900 NOTICE REQUIRED BY THE FAIR DEBT COLLECTION PRACTICES ACT: WE ARE ATTEMPTING TO COLLECT A DEBT, AND ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. Protho tary o Cumberl d County PARKER McCAY P.A. By: Chandra M. Arkema, Esquire Attorney ID# 203437 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054 (856) 810-5815 Attorney for Plaintiff File #:14997-0003 Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series ITF RAST 2006-A3 888 East Walnut Street Pasadena, CA 91101 Plaintiff, V. Jeannie B. Mohmand 817 Meadow Lane Camp Hill, PA 17011 and Defendant Joshua Kesler 245 North 25`h Street Camp Hill, PA 17011 Terre-tenant Property: 245 North 25 h Street Camp Hill, PA 17011 TO: Craig I. Idler, Esquire Capozzi & Associates, PC 1200 Camp Hill Bypass, Ste. 205 Camp Hill, PA 17011 : COURT OF COMMON PLEAS : CUMBERLAND COUNTY DOCKET NO. 06-6376/11-8702 CIVIL ACTION MORTGAGE FORECLOSURE NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a JUDGMENT BY DEFAULT ON THE WRIT OF REVIVAL has been entered against you in the above proceeding and that enclosed herewith is a copy of all the (record) documents filed in support of the said judgment. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEY CHANDRA M. ARKEMA, AT TELEPHONE NO. (856) 596-8900 NOTICE REQUIRED BY THE FAIR DEBT COLLECTION PRACTICES ACT: WE ARE ATTEMPTING TO COLLECT A DEBT, AND ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. Prothon ry of Cumberland County IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series ITF RAST 2006-A3 888 East Walnut Street Pasadena, CA 91101 Plaintiff, V. Jeannie B. Mohmand, 817 Meadow Lane Camp Hill, PA 17011 Defendant and Joshua Kesler 245 North 25`h Street Camp Hill, PA 17011 Terre-tenant DOCKET NO. 06-6376/11-8702 CIVIL ACTION MORTGAGE FORECLOSURE Property: 245 North 25`h Street Camp Hill, PA 17011 PRAECIPE FOR WRIT OF EXECUTION (MORTGAGE FORECLOSURE) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: a; rv T1 xM C= > ._ v ?y c-D Kindly issue writ of execution in the above matter directed to the Sheriff of Cumberland County. Kindly index this Writ against the Defendant, Jeannie B. Mohmand and Terre-tenant, Joshua Kesler as follows: Real Property involved: 245 North 25`h Street, Camp Hill, PA 17011. Amount due $377,750.55 Interest from 9/3/08 to 09/05/2012 (at the per diem rate of $ 65.74) $ Costs $ Total Date: May 24, 2012 .fig. Sc - CAD CHANDRA M. ARKEMA, ESQUIRE eZ s - Attorney for Plaintiff 99 - ecsq Q Af. 00 t( er 7 rf A9.oo ? ?; sv - ?q?z•?9 .s0 CKod ?S/D3 ?B Wtl- ?2 ?4- d' I/? NO. 06-6376/11-8702 Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series ITF RAST 2006-A3 Plaintiff VS Jeannie B. Mohmand and Defendant Joshua Kesler Terre-tenant PRAECIPE FOR WRIT OF EXECUTION Dated: May 24, 2012 Attorney(s) for Plaintiff(s) PARKER MCCAY P.A. CHANDRA M. ARKEMA, ESQUIRE 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054 (856) 810-5815 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-8702 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT SERIES ITF BAST 2006-A3 Plaintiff (s) From JEANNIE B. MOHMAND AND JOSHUA KESLER (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 $377,750.55 L.L. $.50 Interest FROM 9/3/08 TO 9/5/12 (AT THE PER DIEM RATE OF $65.74) Atty's Comm % Atty Paid $1942.49 Plaintiff Paid Date: 6/1/12 (Seal) Due Prothy $2.25 Other Costs David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name : CHANDRA M. ARKEMA, ESQ. Address: PARKER MCCAY P.A. 9000 MIDLANTIC DRIVE SUITE 300 P.O.BOX 5054 MOUNT LAUREL, NEW JERSEY 08054 Attorney for: PLAINTIFF Telephone: 856-810-5815 Supreme Court ID No. 203437 PARKER McCAY P.A. By: Chandra M. Arkema, Esquire Attorney ID# 203437 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054 (856) 810-5815 Attorney for Plaintiff File #:14997-0003 Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series ITF RAST 2006-A3 888 East Walnut Street Pasadena, CA 91101 Plaintiff, V. Jeannie B. Mohmand. 817 Meadow Lane Camp Hill, PA 17011 Defendant and Joshua Kesler 245 North 25 h Street Camp Hill, PA 17011 Terre-tenant Property: 245 North 25"' Street Camp Hill, PA 17011 : COURT OF COMMON PLEAS : CUMBERLAND COUNTY DOCKET NO. 06-6376/11-8702 : CIVIL ACTION : MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Jeannie B. Mohmand 817 Meadow Lane Camp Hill, PA 17011 The real estate located at 245 North 25"' Street, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on September 5, 2012 at 10:00 a.m., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. (The specific room location will be posted at every entrance to the courthouse; or Deputies posted at each entrance may direct you to the room.) to enforce the in rem court judgment of $377,750.55 plus fees, costs and other charges obtained by Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series ITF RAST 2006-A3, against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 1. This sale will be canceled if you pay the judgment to Chandra M. Arkema, Esquire, 9000 Midlantic Drive, Suite 300, P.O. Box 5054, Mount Laurel, NJ 08054. To find out how much you must pay, you may call (856) 810-5815. 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. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling the Sheriffs Office at (717) 240-6390 or Chandra M. Arkema, Esquire at (856) 810-5815. 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 the Sheriffs Office at (717) 240-6390 or Chandra M. Arkema, Esquire at (856) 810-5815. 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 a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on the 30th day after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days of the preparation of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your house 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, 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. Court Administrator Cumberland County Courthouse 4th Floor Carlisle, PA 17013 (717) 240-6200 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. PARKER McCAY P.A. By: Chandra M. Arkema, Esquire Attorney ID# 203437 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054 (856) 810-5815 Attorney for Plaintiff File #:14997-0003 Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series ITF RAST 2006-A3 888 East Walnut Street Pasadena, CA 91101 Plaintiff, V. Jeannie B. Mohmand, 817 Meadow Lane Camp Hill, PA 17011 Defendant and Joshua Kesler 245 North 25"' Street Camp Hill, PA 17011 Terre-tenant Property: 245 North 25"' Street Camp Hill, PA 17011 2(:,12 JUN - I AP110:4?4 CUMBERLAND GUN PENNSYLVANIA : COURT OF COMMON PLEAS : CUMBERLAND COUNTY DOCKET NO. 06-6376/11-8702 CIVIL ACTION MORTGAGE FORECLOSURE NOTICE OF SALE TO LIENHOLDERS OWNERS: Joshua Kesler PROPERTY: 245 North 25`x' Street, Camp Hill, PA 17011 IMPROVEMENTS: Residential - Detached Dwelling PARCEL ID NO.: 01-21-0271-050 Please be advised that the undersigned office represents, Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series ITF RAST 2006-A3, in a mortgage foreclosure. The above-captioned property is scheduled to be sold by the Sheriff of Cumberland County on September 5. 2012 at 10:00 a.m., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. (The specific room location will be posted at every entrance to the courthouse; or Deputies posted at each entrance may direct you to the room.) Our records indicate that you may hold a mortgage or judgment lien on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty (30) days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the filing of the schedule. CHANDRA M. ARK A, ESQUIRE Attorney for Plaintiff Date: May 24, 2012 9 PARKER McCAY P.A. By: Chandra M. Arkema, Esquire Attorney ID# 203437 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054 (856) 810-5815 Attorney for Plaintiff File #:14997-0003 Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series ITF RAST 2006-A3 888 East Walnut Street Pasadena, CA 91101 Plaintiff, V. Jeannie B. Mohmand, 817 Meadow Lane Camp Hill, PA 17011 Defendant and Joshua Kesler 245 North 25th Street Camp Hill, PA 17011 Terre-tenant Property: 245 North 25`h Street Camp Hill, PA 17011 PD01131Y! VANIA : COURT OF COMMON PLEAS : CUMBERLAND COUNTY DOCKET NO. 06-6376/11-8702 : CIVIL ACTION : MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Jeannie B. Mohmand 817 Meadow Lane Camp Hill, PA 17011 The real estate located at 245 North 250' Street, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on September 5, 2012 at 10:00 a.m., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. (The specific room location will be posted at every entrance to the courthouse; or Deputies posted at each entrance may direct you to the room.) to enforce the in rem court judgment of $377,750.55 plus fees, costs and other charges obtained by Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series ITF RAST 2006-A3, against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 1. This sale will be canceled if you pay the judgment to Chandra M. Arkema, Esquire, 9000 Midlantic Drive, Suite 300, P.O. Box 5054, Mount Laurel, NJ 08054. To find out how much you must pay, you may call (856) 810-5815. 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. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling the Sheriffs Office at (717) 240-6390 or Chandra M. Arkema, Esquire at (856) 810-5815. 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 the Sheriffs Office at (717) 240-6390 or Chandra M. Arkema, Esquire at (856) 810-5815. 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 a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on the 30th day after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days of the preparation of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your house 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, 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. Court Administrator Cumberland County Courthouse 4th Floor Carlisle, PA 17013 (717) 240-6200 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 Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PARKER McCAY P.A. By: Chandra M. Arkema, Esquire Attorney ID# 203437 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054 (856) 810-5815 Attorney for Plaintiff File #:14997-0003 Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series ITF RAST 2006-A3 888 East Walnut Street Pasadena, CA 91101 Plaintiff, V. Jeannie B. Mohmand, 817 Meadow Lane Camp Hill, PA 17011 Defendant and Joshua Kesler 245 North 25`'' Street Camp Hill, PA 17011 Terre-tenant Property: 245 North 25`h Street Camp Hill, PA 17011 cr t si H12 JUNI 11 ','IJMUERLIAHD L 'u I PENNSYL4At -!IA : COURT OF COMMON PLEAS : CUMBERLAND COUNTY DOCKET NO. 06-6376/11-8702 : CIVIL ACTION : MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Joshua Kesler 245 North 25' Street Camp Hill, PA 17011 The real estate located at 245 North 25"' Street, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on September 5, 2012 at 10:00 a.m., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. (The specific room location will be posted at every entrance to the courthouse; or Deputies posted at each entrance may direct you to the room.) to enforce the in rem court judgment of $377,750.55 plus fees, costs and other charges obtained by Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series ITF RAST 2006-A3, against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 1. This sale will be canceled if you pay the judgment to Chandra M. Arkema, Esquire, 9000 Midlantic Drive, Suite 300, P.O. Box 5054, Mount Laurel, NJ 08054. To find out how much you must pay, you may call (856) 810-5815. 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. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling the Sheriffs Office at (717) 240-6390 or Chandra M. Arkema, Esquire at (856) 810-5815. 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 the Sheriffs Office at (717) 240-6390 or Chandra M. Arkema, Esquire at (856) 810-5815. 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 a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on the 30th day after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days of the preparation of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your house 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, 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. Court Administrator Cumberland County Courthouse 4th Floor Carlisle, PA 17013 (717) 240-6200 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 Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PARKER McCAY P.A. By: Chandra M. Arkema, Esquire Attorney ID# 203437 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054 (856) 810-5815 Attorney for Plaintiff File #:14997-0003 Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series I TF RAST 2006-A3 888 East Walnut Street Pasadena, CA 91101 Plaintiff, V. Jeannie B. Mohmand, 817 Meadow Lane Camp Hill, PA 17011 Defendant and Joshua Kesler 245 North 25`h Street Camp Hill, PA 17011 Terre-tenant Property: 245 North 25 h Street Camp Hill, PA 17011 PENNSYLVAili- : COURT OF COMMON PLEAS : CUMBERLAND COUNTY DOCKET NO. 06-6376/11-8702 CIVIL ACTION MORTGAGE FORECLOSURE CERTIFICATION I, CHANDRA M ARKEMA, Esquire, hereby certify that an Act 91 Notice was provided to Defendant-mortgagor, Jeannie B. Mohmand, by letter dated September 5, 2006. This certification is made subject to the penalties of 18 Pa C.S. §4904 relating to unsworn falsification to authorities. CHANDRA M. ARKEMA)4C U Dated: May 24, 2012 PARKER McCAY P.A. By: Chandra M. Arkema, Esquire Attorney ID# 203437 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054 (856) 810-5815 Attorney for Plaintiff File #:14997-0003 Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series ITF RAST 2006-A3 888 East Walnut Street Pasadena, CA 91101 Plaintiff, V. Jeannie B. Mohmand, 817 Meadow Lane Camp Hill, PA 17011 Defendant and Joshua Kesler 245 North 25" Street Camp Hill, PA 17011 Terre-tenant Property: 245 North 25"' Street Camp Hill, PA 17011 L.. N,?, 12AN-I !a Iu !cr ; i hi1 C: L k e LI U I'l i -ENNSYLVAN1 : COURT OF COMMON PLEAS : CUMBERLAND COUNTY DOCKET NO. 06-6376/11-8702 CIVIL ACTION MORTGAGE FORECLOSURE AFFIDAVIT OF LAST KNOWN ADDRESS STATE OF NEW JERSEY COUNTY OF BURLINGTON SS. BEFORE ME, the undersigned authority, a Notary Public in and for the said County and State, personally appeared CHANDRA M. ARKEMA, ESQUIRE, attorney for the Plaintiff, who being duly sworn according to law, deposes and says that to the best of her knowledge, information and belief that the owner of the property located at 245 North 25th Street, Camp Hill, PA 17011, is Joshua Kesler who resides at 245 North 25 b Street, Camp Hill, PA 17011 and that the current address of Jeannie B. Mohmand is 817 Meadow Lane. Camp Hill, PA 17011. f CHANDRA M. ARKEMA, ESQUIRE Sworn to and sub c *bed to before me this 1 day of 2012 NOT Y P IC NOEL OOMINGUEZ A Notary Public of New lerssy My Commission Expires November 20, 2014 PARKER McCAY P.A. By: Chandra M. Arkema, Esquire Attorney ID# 203437 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054 (856) 810-5815 Attorney for Plaintiff File #:14997-0003 Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series ITF RAST 2006-A3 888 East Walnut Street Pasadena, CA 91101 Plaintiff, V. Jeannie B. Mohmand, 817 Meadow Lane Camp Hill, PA 17011 Defendant and Joshua Kesler 245 North 25`h Street Camp Hill, PA 17011 Terre-tenant Property: 245 North 250' Street Camp Hill, PA 17011 ,? I? JUN - I A 10: ? °ENNSYLVAN1A : COURT OF COMMON PLEAS : CUMBERLAND COUNTY DOCKET NO. 06-6376/11-8702 CIVIL ACTION MORTGAGE FORECLOSURE AFFIDAVIT OF NON-MILITARY SERVICE BEFORE ME, the undersigned authority, personally appeared Chandra M. Arkema, Esquire, who, being duly sworn according to law, deposes and says that to the best of her knowledge, information and belief, Defendant, Jeannie B. Mohmand, or Terre-tenant, Joshua Kesler, are not known to be in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 an the amendments there A. r CHANDRA M. ARKEMA, ESQUIRE Attorney for Plaintiff Sworn to and subscribed to TiWiis L4+h day of NOEL DOMINGUEZ 2012 A Notary Public of Now JIM My commission Expires NowMW 20.2014 PARKER McCAY P.A. By: Chandra M. Arkema, Esquire Attorney ID# 203437 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054 (856) 810-5815 Attorney for Plaintiff File #:14997-0003 Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series ITF RAST 2006-A3 888 East Walnut Street Pasadena, CA 91101 Plaintiff, V. Jeannie B. Mohmand, 817 Meadow Lane Camp Hill, PA 17011 Defendant and Joshua Kesler 245 North 25"' Street Camp Hill, PA 17011 Terre-tenant Property: 245 North 25"' Street Camp Hill, PA 17011 PENNSYLVANIA : COURT OF COMMON PLEAS : CUMBERLAND COUNTY DOCKET NO. 06-6376/11-8702 CIVIL ACTION MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series ITF RAST 2006-A3, Plaintiff in the above action, comes by its attorney and sets forth, as of the date the Praecipe for Writ of Execution was filed, the following information concerning the real property located at 245 North 25t" Street, Camp Hill, PA 17011: 1. Name and address of Owner(s) or Reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) Joshua Kesler 245 North 25 Street Cam Hill, PA 17011 2. Name and address of Defendants in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) Jeannie B. Mohmand 817 Meadow Lane, Cam Hill, PA 17011 Joshua Kesler (Terre-tenant) 245 North 25 Street Cam Hill, PA 17101 3. 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 so indicate) Deutsche Bank National Trust Company as Trustee 888 East Walnut Street under the Pooling and Servicing Agreement Series Pasadena, CA 91101 ITF BAST 2006-A3 Deutsche Bank National Trust Company 460 Sierra Madre Villa Avenue, Suite 101 Pasadena, CA 91107 The Harrisburg Academy 10 Erford Road Wormle sbur , PA 17043 Members 1st Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 ACCO York Federal Credit Union 1529 Rodney Road York, PA 17404 PSECU 1 Credit Union Place Harrisburg, PA 17110 The Harrisburg Academy c/o David F. O'Leary, 1 S. Market Sq., P.O. Box 173 Esquire Harrisburg, PA 17108-1146 Members 1st Federal Credit Union c/o Karl M. P.O. Box 173 Ledebohm, Esquire New Cumberland, PA 17070-0173 ACCO York Federal Credit Union c/o Edward A. 2675 Eastern Boulevard Paske , Esquire York, PA 17402-2905 PSECU c/o Melissa L. Van Eck, Esquire 3401 N. Front Street Harrisburg, PA 17110 4. Name and address of the last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please so indicate) Lancaster Mortgage Bankers, A Limited Liability 20 Independence Blvd Company Warren, New Jersey 07059 Deutsche Bank National Trust Company as Trustee 888 East Walnut Street under the Pooling and Servicing Agreement Series Pasadena, CA 91101 ITF RAST 2006-A3 Y Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please so indicate) Dustin J. Malesich 730 South 10 Street Harrisburg, PA 17104 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please so indicate) Janet Miller 1939 Walnut Street (County/Municipal/ School) Cam Hill, PA 17011 Camp Hill Borough 2145 Walnut Street (Sewer) Cam Hill, PA 17011 PA American 800 West Hershey Park Drive (Water) Hershey, PA 17033 Penn Waste P.O Box 3066 York, PA 17402 Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations 13 North Hanover Street, P.O. Box 320 Carlisle, PA 17013 Commonwealth of Pennsylvania 333 Health and Welfare Building Department of Welfare Harrisburg, PA 17105 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 so indicate) Tenant/Occupant 245 North 25 Street Cam Hill, PA 17101 Craig I. Adler, Esquire 2933 N. Front Street Attorney for Joshua Kesler Harrisburg, PA 17110 Paul R. VanFleet, Esquire P.O. Box 5866 Attorney for Joshua Kesler Harrisburg, PA 17110 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. pill M TO (1 C?(OI C RA M. ARKEMA, ESQUIRE Attorney for Plaintiff Date: May 24, 2012 CAPOZZI & ASSOCIATES, P.C. By: Craig I. Adler, Esquire Attorney I.D. No. 52970 1200 Camp Hill Bypass, Ste. 205 Camp Hill, PA 17011 (717) 233-4101 `?tsq?}g?,rs;,?P??},'61?ura K?s?ler IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT SERIES ITF RAST 2006-A3 888 East Walnut Street Pasadena, CA 91101 NO. 06-637 11-8702 Plaintiff vs. CIVIL ACTION MORTGAGE FORECLOSURE JEANNIE B. MOHMAND, 817 Meadow Lane Camp Hill, PA 17011 Defendant and JOSHUA KESLER, 245 North 25th Street Camp Hill, PA 17011 Terre-Tenant ANSWER AND OPPOSITION TO PRAECIPE FOR WRIT OF REVIVAL AND NOW comes Terre-Tenant Joshua Kesler ("Terre-Tenant Kesler") by and through his counsel Capozzi and Associates, P.C., and Craig I. Adler, Esquire, and in opposition to 1 Plaintiff Deutsche Bank National Trust Company as Trustee, under the Pooling and Servicing Agreement Series ITF RAST 2006-A3's Praecipe for Writ of Revival, respectfully requests that this Honorable Court deny Plaintiff s Writ of Revival, and in support thereof represents that: MORTGAGE FORECLOSURE ACTION 1. On November 1, 2006, Plaintiff filed a civil complaint in the Cumberland County Court of Common Pleas against Jeannie Mohmand and, docketed at CV-06-6376, in mortgage foreclosure against the property located at 245 North 25`h Street, Camp Hill, PA ("Property") 2. On December 26, 2006, this Honorable Court entered judgment in favor of Plaintiff and against Defendant Mohmand in the amount of $308,691.96. 3. On October 28, 2011, Plaintiff transferred the judgment to the Cumberland County Court of Common Pleas, docketed as CV-11-8702. WRIT OF REVIVAL 4. On October 28, 2011, Plaintiff filed a Praecipe for Writ of Revival of the judgment claiming that $377,750.55, plus interest from September 3, 2008 was owed, which Writ of Revival indicates that judgment is to be entered against Joshua Kesler, as Terre- Tenant. 5. The Writ of Revival was served on Terre-Tenant Kesler on December 27, 2011. ENTRY OF DEFAULT JUDGMENT 6. On June 1, 2012, Plaintiff filed a Praecipe to Enter Default Judgment on the Writ of Revival ("Praecipe") 2 7. Pennsylvania Rule of Civil Procedure § 237.1 states that "(a) No judgment of non pros for failure to file a complaint or by default for failure to plead shall be entered by the prothonotary unless the praecipe for entry includes a certification that a written notice of intention to file the praecipe was mailed or delivered; in the case of a judgment by default, after the failure to plead to a complaint and at least ten days prior to the date of the filing of the praecipe to the party against whom judgment is to be entered and to the party's attorney of record, if any." Pa.R.C.P. § 237.1(a)(2). 8. Within the Praecipe, Plaintiff certified to the Prothonotary that the required written Notice of Intention to Enter Judgment by Default Judgment ("Notice") was sent to Terre- Tenant Kesler more than 10 days prior to the filing of the Praecipe and that a copy of the Notice was attached. 9. As of the date of the entry of the Default Judgment, neither Terre-Tenant Kesler nor his attorney received a Notice more than 10 days prior to the filing of the Praecipe in violation of Pa.R.C.P. § 237.1. 10. Plaintiff failed to attach a copy of the Notice to the Praecipe in violation of Pa.R.C.P. § 237.1(a)(3). 11. While Terre-Tenant Kesler affirmatively states that no Notice was received, Plaintiff's failure to serve the required Notice or attach a copy of the required Notice, in violation of the requirements of Pa.R.C.P. § 237.1(a)(3), constitutes cause for this Honorable Court to deny the praecipe for default judgment on the writ of revival against Terre-Tenant Kesler. 3 12. Pursuant to Pennsylvania Rule of Civil Procedure §3030, a Writ of Revival " ... shall be the equivalent of a complaint in a civil action. The rules relating to a civil action so far as applicable shall govern further proceedings." Pa.R.C.P. § 3030(a). 13. As such, Terre-Tenant Kesler may present a meritorious defense opposing the entry of judgment against him via the Writ of Revival. 14. Terre-Tenant Kesler has a meritorious defense primarily relating to Plaintiff's inability to prove proper ownership of the Note and Mortgage and irregularities related to the Assignment of Mortgage asserted by Terre-Tenant Kesler by his Application for Rule to Show Cause, which is already part of the record. A true and correct copy of the Application is attached hereto as Exhibit "A". RESPONSE TO PLAINTIFF'S WRIT OF REVIVAL 1. FACTUAL BACKGROUND 15. On October 25, 2005, Jeannie Mohmand ("Defendant Mohmand") executed a Note in favor of Lancaster Mortgage Bankers in the amount of $292,000.00 ("Note"). 16. To secure the Note, Defendant Mohmand executed a Mortgage in favor of Lancaster Mortgage Bankers encumbering such real property located at 245 North 25th Street, Camp Hill, PA 17011 ("Mortgage"). The Mortgage was recorded in the Cumberland County Recorder of Deeds on November 1, 2005. 17. Plaintiff claims that an Assignment of Mortgage was executed between itself and Lancaster Mortgage Bankers assigning the Mortgage to Plaintiff ("Assignment") 18. No such Assignment was ever recorded in the Cumberland County Recorder of Deeds, by Plaintiff's own admission. 4 19. On November 1, 2006, Plaintiff filed a foreclosure complaint against Defendant Mohmand. 20. On. December 27, 2006, Plaintiff obtained an in rem judgment by default against Defendant Mohmand in the amount of $308,691.96. 21. Subsequent to the entry of judgment, Defendant Mohmand conveyed the Property to Terre-Tenant Kesler for a sum of $10,000.00. 22. Subsequent to the conveyance of the Property from Defendant Mohmand to Terre-Tenant Kesler, Plaintiff could not locate the original Assignment and instead filed an Affidavit of Lost Assignment of Mortgage purporting to validly assign the Mortgage to Plaintiff ("Affidavit') 23. On December 20, 2009, Plaintiff filed a Complaint to Quiet Title against Defendant Mohmand, Terre-Tenant Kesler, and Lancaster Mortgage Bankers ("Action to Quiet Title") docketed to Cumberland County Docket No. 09-2991. 24. In that separate Action to Quiet Title, Terre-Tenant Kesler uncovered two separate assignments of mortgage, one of which was an assignment of mortgage which is legally insufficient to constitute an assignment in favor of Plaintiff and a presumably altered version of the aforementioned assignment of mortgage. 25. Plaintiff continues to claim that the altered assignment they produced is a valid copy of the Assignment. 26. Plaintiff now attempts by the referenced Writ of Revival to execute the default judgment commenced against Defendant Mohmand against Terre-Tenant Kesler pursuant to Pa.R.C.P. § 3026.3. 5 II. OPPOSITION TO PLAINTIFF'S WRIT OF REVIVAL 27. Paragraphs 1-26 are hereby incorporated by reference. 28. Terre-Tenant Kesler contends that the assignment of mortgage at issue is invalid, as it appears to be an alteration of a copy of a previous assignment submitted by Plaintiff in the Action to Quiet Title, and such alteration renders the document untrustworthy at a minimum, and fraudulent if altered on purpose, or with intent to deprive Terre-Tenant Kesler of his rights, title or benefits to the property. Further, the alterations made to the assignment are material to the issue at hand regarding whether the document is a valid assignment and whether such assignment should be accepted for filing. A true and correct copy of a forensic investigation of the two documents concluding that the Assignment provided by Plaintiff in the Action to Quiet Title is an alteration of the previous assignment is attached hereto as Exhibit "B." 29. More specifically, Mortgage Electronic Registration Systems, Inc., is not referred to in the Corporation Assignment of Mortgage attached to Action to Quiet Title, but Mortgage Electronic Registration Systems, Inc., was added to the Corporation Assignment of Mortgage attached to the within cause of action, and it is Terre-Tenant Kesler's belief that it was so added fraudulently. Further, there is no handwritten number contained in, or referred to in, the Corporation Assignment of Mortgage in the Action to Quiet Title, but there is a handwritten number that was added to the Corporation Assignment of Mortgage attached to the within cause of action, and it is Terre-Tenant Kesler's belief that it was so added fraudulently. 30. The conveyance of the property from Defendant Mohmand to Terre-Tenant Kesler was for fair consideration, in light of the circumstances surrounding the property, as said 6 property was subject to condemnation by the Cumberland County Redevelopment Authority as a result of being blighted, and was deemed a physical risk to the neighborhood, and the condition of the property was in near tear-down condition. 31. Although a document named "Affidavit of Lost Assignment of Mortgage" is filed of record, the affidavit or the acceptance of the recording thereof' by the Recorder of Deeds Office does not act as a legal assignment of any interest in the mortgage in question to Plaintiff. 32. Plaintiff's title to the mortgage is therefore incomplete, and Plaintiff had no standing to move forward with the Foreclosure Action against Defendant Mohmand. 33. By the same reasoning, Plaintiff has no current standing to bring the default judgment entered against Defendant Mohmand to bear against Terre-Tenant Kesler through the Writ of Revival. 34. Plaintiff and Terre-Tenant Kesler are concurrently litigating these very issues in the Action to Quiet Title. 35. Disposition of the issues created by Plaintiff's issuance of the Writ of Revival is properly reserved for the Action to Quiet Title, and as such, the Court should stay those issues until the Action to Quiet Title is resolved. WHEREFORE, Terre-Tenant Kesler respectfully requests that this Honorable Court deny the Plaintiff's Writ of Revival and prevent any entry of judgment against Terre-Tenant Kesler relating to the Default Judgment entered against Defendant Mohmand, along with any and all othe relief that this Honorable Court finds appropriate. 7 Respectfully submitted, Dater CAPOZZI & ASSOCIATES, P.C. By: 2?? Craig I. Adler, Esquire Attorney ID: 52970 1200 Camp Hill Bypass, Ste. 205 Camp Hill, PA 17011 (717) 233-4101 Attorney for Defendants 8 EXHIBIT "A" DEUTSCHE BANK NATIONAL TRUST : IN THE COURT OF COMMON PLEAS OF COMPANY AS TRUSTEE UNDER THE : CUMBERLAND COUNTY, PENNSYLVANIA POOLING AND SERVICING AGREEMENT SERIES ITF RAST : NO. 06-6376 CIVIL TERM 2006-A3 V. JEAN NILE B M C HMANIJ 1 ) fT 40"+ JOSHUA K] App] FOR RULE TO SHOW CAUSE 1. AeDlicant is Joshua Kesler. 2. On December 27, 2006, Deutsche Bank National Trust Company (hereafter Deutsche Bank) took default judgment in rem in mortgage foreclosure against Jeannie B. Mohmand. 3. On March 28, 2008, for the sum of $10,000.00 Joshua Kesler purchased from Jeannie Mohmand the real estate located at 245 North 25a' Street, Camp Hill, PA 17011 (subject property . 4. It is anticipated in the next few months that Deutsche Bank will list subject property for a i Sheriff s'Sale based upon the in rem judgment in their favor. 5. The mortgage holder of record in this case is Lancaster Mortgage Bankers and not Deutsche i Bank. 6. Deutschei Bank foreclosed on a mortgage which was never assigned out of Lancaster Mortgage Bankers. 7. Attached as Exhibit "A" is a document entitled "Affidavit Of Lost Assignment Of Mortgage" which was filed in the office of the Recorder of Deeds on July 5, 2007. 8. This affidavit indicates that the alleged assignment of mortgage to Deutsche Bank was never record4 was inadvertently not completed and is unavailable. 9. Not only] I was the assignment never recorded, but the assignment was never completed. 10. 21 P.S. 251 TPAt7iTP(? *? _i ,? ...," .?? ..at a.y assignment of a ., which is ,.,,,,, ,.va tgag= . not. 1) ackno..ledgeu, or 2) recorded, shall be void as to any subsequent bona fide purchaser. See Merrill v Hanlev 235 Pa. ?uper. 22, 340 A.2d 546 (1975), Holler v Fairbanks Capital Corporation Servicing Center, j42 B.R. 212 (W.D. Pa. 2006) and In Re Foreclosure Cases 2007 WL 3232430 (N.D. Olio 2007), attached hereto as Exhibit "B". 11. Deutsch Bank lacked the standing to be a Plaintiff in the above captioned mortgage foreclosure action because the relevant mortgage was never assigned to Deutsche Bank. 12. Even though they lacked the legal capacity to bring a mortgage foreclosure action, because i Jeanne B. Mohmand failed to file a response to the complaint, an in rem judgment in mortgage foreclosure was entered against her. 13. The document attached as Exhibit "A" is not an assignment of a mortgage from Lancaster Mortgage Bankers. 14. Pursuantto 21 P.S. §623-1, to be recorded, an assignment must be acknowledged by the assignor. 15. Additionally, the Affidavit attached as Exhibit "A" does not by its own words assign anything., 16. Even if Lancaster Mortgage Bankers were to now execute a valid assignment of its mortgage, the deed into Joshua Kesler would be recorded before said assignment and the i deed into Joshua Kesler would take priority over any assignment of Lancaster Mortgage Bankers. 17. In consideration of Deutsche Bank never having standing to bring their mortgage foreclos>re action, it would be unjust to permit them to execute upon their judgment and gain leg?l and equitable title to subject property to the detriment of Joshua Kesler - the curs eni :;older of legal and equitable title. 18. It would be unjust to permit Deutsche Bank to execute upon their mortgage foreclosure judgmenii because it is clear from the records on file with the Recorder of Deeds Office that Mortgage Bankers is the holder of record of the relevant mortgage and it is Mortgage Bankers which must get "paid off' in order to remove the mortgage lien from subject property. 19. It would be unjust to permit Deutsche Bank to execute upon their mortgage foreclosure I judgments and thereafter receive a whole or partial payoff of the mortgage in question, because the records on file with the Recorder of Deeds Office are clear that regardless of how mu ih money is paid to Deutsche Bank, Lancaster Mortgage Bankers can still demand payment in full of their mortgage or else they could bring their own mortgage foreclosure I action on their unassigned mortgage of record on file with the Recorder of Deeds office. 20. It would! be unjust to permit Deutsche Bank to execute upon their mortgage foreclosure judgment because presumably, the note defining how much money was owed to Lancaster Mortgage Bankers was not assigned to Deutsche Bank, which would mean that in addition to Deutsche Bank not having a security interest in subject property, Deutsche Bank would i not have any legal right to collect any of the underlying debt. W4REFORE, Joshua Kesler requests a rule be issued upon Deutsche Bank National Trust Company to show cause why pursuant to Pa.R.C.P. 3183(b)(2) and 3183(d)(3) the Court should not 6rder that the Execution in this case be permanently stayed and that the Writ of Execution bj permanently set aside. YOFFE & YOFFE, P.C. By ?LEsq. Jeey N. Attorney for Joshua Kesler 214 Senate Avenue, Suite 404 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 &_offe(@verizon net VERIFICATION I hereby state that I am an adult individual who is authorized to make this verification and that the faicts set forth in the foregoing application are true to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 14904 relating to unworn falsification to authorities. Dated: (? p $' 34-- JoslyfC. Kesler 2 I After recordin? return to: Phelan Hallinan & Schmieg, L.L.P. One Penn Center at Suburban Station 1617 John F. *ennedy Boulevard Sig. 1400 Philadelphia A 19103-1814 S Date: 6/1 -ROBERT P. ZIEGLER RECORDER OF DEEi? GL;,Ir _RLAND COUf17 :' W JUL 5 R19 10 48 AFFIDAVIT OF Based upon a diligent search of the property records, it appears the Assignment of Mortgage from Lancaster Mortgage Ba ra, whose sass itmown addr= was in 20 independence Blvd., Warren, NJ 070s9, to Deutsche Bank Nationa Trust Comparry as Trustee tinder the PooBng and Servicing. Agreement Series I TF RAST 2006-A3 (Assi cc) was never recorded and inadvertently not completed and is now unobtainable The aillsat btby aMrms that it has acquired the underlying Note and Mortgage and is the assignee by virtue of this affidavit. Said Mortgage dated 10126105, recorded in the county of Cumberland, state of Pennsylvania is more particularly describes as follows: Original Mort gor (s): Jeannie B Mohmand Original Mort gee. Lancaster Mortgage Bankers Original Princ' of Amount: 292,000,00 Recorded: 11/1/05 Book:1929 Page: 916 Property Ad 245 N 25th Street, Camp Hill, PA 17011 Tax Parcel No: 01-21-0271-050 Legal description attached or refer to Mortgage herein assignee I 4CW By: State of TEXAS I County of: WILLIAMSON ?SS On, Jwe u. XO before me the subscriber, personally appeared Paige Bolen, Vice President personally known to me ( proved to me on the basis of satisfactory evidence) to be the person(s) whose name(s) is/= subscribed to the within instrument and acknowledged to me that Wshelthey executed the same in his/her/their authorized capaI city(ies), and that by his/her/their signature(s) on the inswmcnt the person(s) or the entity u behalf of which the person(s) acted, executed the instrument. i WITNESS my land and official seal (seal) ..+......?........ ?Ap ;5, CYNTHIA CONL L1C The precise address of the 'cit Notary Public within named Alssignee is: I STATE OF TEXAS h ' • - My Commission 3001378206 460 Sierra Madre Villa Ave Expires 03/21120083 Neville Cooper -14 «." ' Pasaden CA 91 1 • ?NiN??Ir?NNN?M?N??N??N?NN? By: (On Dethafro7he assignee) BK0738PG 1 543 EXHIBIT "A" - --?-- _ ? i EXHIBIT "B" 10 DOCUMENT CONSULTANTS 340 WINDSOR AVENUE SOUTHAMPTON, PENNSYLVANIA 18966-3338 EXAMINATION OF ANONYMOUS LETTERS, DEEDS, CHECKS, FORGERIES April 11, 2011 Mr. John Baranski 17 East Market Street York, PA 17401 RE: Comparison of Documents Letter of Opinion Dear Mr. Baranski: TELEPHONE: (215) 357-3083 An examination was conducted to determine whether the document labeled Exhibit 2 is an altered version of the document labeled Exhibit 1. Documents in Ouestion: Exhibit 1: Document titled "Corporation Assignment of Mortgage," date code at bottom - 2/10/05 for 6]. Exhibit 2: Document titled "Corporation Assignment of Mortgage," date code at bottom - 2/10/05 [or 6] (approximately 30% larger than Exhibit 1), with additional notations. The above documents are photocopies. Findiny-s and Discussion: All the words and numbers, and the positions of the words and numbers in the two documents are exactly alike, with the exception of two additions in Exhibit 2, as follows: 1) On the right side, under the double horizontal line of the title, directly above ("Assignee") it reads: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. DOCUMENT CONSULTANTS April 11, 2001 Mr. John Baranski RE: Comparison of Documents Page 2 2) On the left bottom, directly above the double horizontal line, there is a handwritten number that reads: M[or N?] C[?] N#100055401225566688 O inion• Based on the documents submitted, and subject to examination of the originals, it is my considered opinion that Exhibit 2 is an altered version of Exhibit 1. Should you need further information, please contact me, at your convenience. Respectfully submitted, i Carolyn K, Board C' fied Forensic Document Examiner Enclosures: Curriculum Vitae Labeled copied of the two documents Carolyn Kurtz 340 Windsor Avenue Southampton, PA 18966-3338 (215) 357-3083 e-mail: caroiynkk ikomcast.net Professional Training: Board Certified - World Association of Document Examiners, 1997. Registered Professional - World Association of Document Examiners, 1996. Certificate in Forensic Document Examination with Andrew J. Bradley, (Andrew Bradley and Associates, Denver, Colorado), 1.991. Certificate in Advanced Studies: Extended Training in Questioned Document Problems with Andrew J. Bradley, 1996. Private study in Document Examination with Felix Klein (Director, Manhattan Handwriting Consultants, New York City - Consultant to the United Nations) Advanced Course, 1985. Certificate in Forensic Document Examination from Mercer County Community College, Mercer County, New Jersey, 1984-1985. Seminars: Forensic Document Examination Examiners, Inc. - Workshop and Seminar - 15 hours Katherine M. Koppenhaver, CDE - Instructor William A. Koppenhaver - Forensic Document Photographer - Instructor Edgewood, Maryland - September 17 and 18, 2010 Forensic Document Examination Interactive Training Seminar - 15 hours Katherine M. Koppenhaver, CDE - Instructor Edgewood, Maryland - September 18 and 19, 2009 American Academy of Forensic Sciences - Questioned Documents - 12 hours Washington, D.C. - February 21 and 22, 2008 Independent Association of Questioned Document Examiners - 18'/2 hours Arlington, Virginia - August 16-19, 2006. Independent Association of Questioned Document Examiners - 23 hours Itasca, Illinois - August 24-27, 2005 Independent Association of Questioned Document Examiners - 23 hours Charleston, South Carolina- September 15-18, 2004. World Association of Document Examiners, Chicago, Illinois - 30 hours July 23-27, 2002 - Seminar and Resident Training Program World Association of Document Examiners, Oak Brook, Illinois - 27'/4 hours July 19-23, 2001 - Seminar and Resident Training Program. Independent Association of Questioned Document Examiners - 21'/2 hours Dallas, Texas -August 28-31, 2000. World Association of Document Examiners, Chicago, Illinois - 30'/4 hours August 11-14, 1999 - Seminar and Resident Training Program. World Association of Document Examiners, Chicago, Illinois - 30'/4 hours July 28-August 1, 1998 - Seminar and Resident Training Program. 9/10 Carolyn Kurtz Page 2 World Association of Document Examiners, Chicago, Illinois - 32 hours July 16-20, 1997 - Seminar and Resident Training Program. World Association of Document Examiners, Chicago, Illinois July 24-28, 1996 - Seminar and Resident Training Program - 30 hours National Bureau of Document Examiners, New York City - 48 hours 16 Conferences, New York City, 1986-1994. National Association of Document Examiners Seminar, Washington, D.C. - 20 hours - October, 1984. Membership: World Association of Document Examiners -1995-2003 National Association of Document Examiners - 1984 to present National Bureau of Document Examiners -1986-1994. Presentations: "Does the Night Vision Scope Penetrate Obliterations in Forensic Document Work?" "Multiple Generation Copies for Demonstration" World Association of Document Examiners - The Drake Hotel, Chicago, Illinois - July 19, 1997 Check Verification Training Class The Vanguard Group - Great Valley Corporate Center Valley Forge, PA - September 21, 1999 Papers Published: "Can a Demonstration Using Multiple-Generation Copies Emphasize Certain Writing Features?" - World Association of Document Examiners' Exchange - April 1998 "Is the Writing a Forgery or Due to Visual Impairment?" - World Association of Document Examiners' Exchange - February 1998 "The `Comeback Kid' of Writing Instruments: The Fountain Pen" - World Association of Document Examiners' Exchange - January 1998 "Does the Night Vision Scope Penetrate Obliterations in Forensic Document Work?" - World Association of Document Examiners' Exchange - October 1997. "Sworn to Before Me: The Notary Public" - World Association of Document Examiners' Journal - October 1996. "The Left-Handed Writer" - World Association of Document Examiners' Journal - July 1996. "Preventing Illegal Duplication" - National Association of Document Examiners' Journal - February 1985. 9/10 COURT ATTENDANCE Criminal Court - Philadelphia, PA New Brunswick, NJ Centre County (Bellefonte), PA Snyder County (Middleburg), PA Delaware County (Media), PA Lehigh County (Allentown), PA District Court - Bucks County (Penndel), PA Probate Court - West Chester, PA Court of Common Pleas - Civil Div. - Philadelphia, P - Juvenile Div. - Columbia County (Bloomsburg), PA - Orphan's Court Div. - Monroe County (Stroudsburg), PA - Civil Div. - Luzerne County (Wilkes Barre), PA - Civil Div. - Lehigh County (Allentown), PA - Orphan's Court Div. - Bucks County (Doylestown), PA - Orphan's Court Div. - Lackawanna County (Scranton), PA - Civil Div. - Lancaster County, PA - Orphan's Court Div. - Philadelphia County Zoning Board Remand Hearing, Hilltown Township - Bucks County, PA Commonwealth Court of PA - Allegheny County Dept. of Elections, Pittsburgh, PA - Philadelphia Board of Elections, Philadelphia, PA Municipal Court of NJ - Wall Township U.S. Bankruptcy Court - Philadelphia, PA U. S. Bankruptcy Court, Middle District - Chapter 13 Bankruptcy - Harrisburg, PA U.S. Bankruptcy Court, Eastern District - Reading. PA U.S. District Court, Eastern District of Pennsylvania - Philadelphia, PA Register of Wills Hearing - Montgomery County (Norristown), PA - Schuylkill County (Pottsville), PA Superior Court of NJ - Chancery Div. - Camden County (Camden), NJ - Chancery Div. - Morris County (Morristown), NJ - Chancery Div. - Gloucester County (Woodbury), NJ - Chancery Div. - Middlesex County (New Brunswick), NJ - Ocean County (Tom's River), NJ Superior Court - Waterbury, Connecticut Surrogate Court - Bronx County, New York Arbitration - Bucks County (Doylestown), PA Montgomery County (Norristown), PA Philadelphia County, PA (Register of Wills) Depositions - U.S. District Court for the District of Delaware - Wilmington, DE - Court of Common Pleas of Chester County, PA - Radnor, PA - Court of Common Pleas of Montgomery County, PA - Lafayette Hill, PA - Office of Zeichner, Ellman & Krause, New York, NY Custody Hearing - Lebanon, PA Civil Action - Landlord/Tenant - Middlesex County, NJ 10/10 Exhibit 1 i Tw 03? W?tifm l?sel i0eslliert#?; 01??1-0?'1s-os0 i 1,11 1190111 EK.ww ?i mss, ISM167b " O Mow' POII IALUE , *&TIIftWpW r VW. IW salW?rs eo ?If of f4 d{lu tWe ao[ t+inp?n 3a ?oi C"7 , ZOOS ? OCR 24 o And Pap JFJZ 8 1 , A r" 11 i Yy 1O IioiC7lt , Aljj? LWQ.1'tY ..ntlnor awl, niNd r iR drt OIO 7boe b drtJ' 1CrroioO?'ipatd s+ d0 t basiras 11. P. R. V! O1-71-02?l-O?Sp ND Ccow.h Obi604VAP" 7i0M hwik7 Exhibit 2 '11is Inszrutttent Prepared 13y: After Rewfdlq Rawru To. Lax x BANKRRB 20 IIi?13iF?lE?NSSw Nsw . EM t?59 Unifonn :Parml 1&1xider Nwnbcr: 01- 21- 0 2 71- 0 5 0 CAMP X ? P SYL,VAS1JA 1` aTRSBT, Escrow #- Loan #: 150'0096,76 CO ORATION AaSIGNM NT OF MORTGAGE FOR VALUE RECMVE,ia, the imdetsiped hereby gnk ts, aWgns wA traisfera to Mf3RT4Ar =EE1.EG:IRO{Vi?CtREGISfFtAt'll?4i aof its r?fii, aria-and ittteragt in aa8.r4,thc, 7 1,C, Proigem covered by that Cercatn.Moga&i? ctucYi OCTOBER 2 t~ . 2 f} 0`5 . rwovW..in.Boaic Yalttme vA Page minuted by JEANNIE 8 MOMMAND, A MARRMM WOMAN as mortgagor: to LAZE m - ? A I T.ra?atrrrY RA7Y .mort Agee, and recorded as inib? Offidg Rewr& ht the Cottht}r Recondler's of ki: ©f° CUMBElt? Co", Pemaylvania, cicscrbingtheland hereinas: A.P.N. #: 01-21-0271-050 ("Property') VERIFICATION I verify that the statements made herein are true and correct and understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Date: & , Z- CERTIFICATE OF SERVICE I hereby certify that I have, this date, mailed a true and correct copy of the foregoing pleading by United States mail, first-class, postage prepaid, addressed to the following individual(s): Chandra M. Arkema, Esq. Parker McCay, P.A. 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, NJ 08054 Date: Craig L Adler 12 CAPOZZI & ASSOCIATES, P.C. By: Craig 1. Adler, Esquire Attorney I.D. No. 52970 1200 Camp Hill Bypass, Ste. 205 Camp Hill. PA 17011 (717) 233-4101 Attorneys for Joshua Kesler IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST NO. 06-6376/11-8702 COMPANY AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT SERIES ITF RAST 2006-A3 888 East Walnut Street : Pasadena, CA 91101 Plaintiff vs. CIVIL ACTION MORTGAGE FORECLOSURE JEANNIE B. MOHMAND, 817 Meadow Lane Camp Hill, PA 17011 Defendant and JOSHUA KESLER, 245 North 25th Street: Camp Hill, PA 17011 Terre-Tenant ENTRY OF APPEARANCE Please enter my Appearance in the above captioned matter on behalf of Terre-Tenant, Joshua Kesler. 13 Please direct all future correspondence on this matter to the undersigned. Respectfully submitted, CAPOZZI & ASSOCIATES, P.C. Date: By: Craig I. Adler, Esquire Attorney ID: 52970 1200 Camp Hill Bypass, Ste. 205 Camp Hill, PA 17011 (717) 233-4101 Attorney for Defendants 14 CAPOZZI & ASSOCIATES, P.C. By: Craig I. Adler, Esquire Attorney I.D. No. 52970 1200 Camp Hill Bypass, Ste. 205 Camp Hill, PA 17011 (717) 233-4101 Attorneys for Joshua Kesler IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST NO. 06-6-36/11-8702 COMPANY AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT SERIES ITF RAST 2006-A3 888 East Walnut Street Pasadena, CA 91101 Plaintiff VS. CIVIL ACTION MORTGAGE FORECLOSURE JEANNIE B. MOHMAND, 817 Meadow Lane Camp Hill, PA 17011 Defendant and JOSHUA KESLER, 245 North 25th Street Camp Hill, PA 17011 Terre-Tenant RULE TO SHOW CAUSE TO OPEN JUDGMENT AND STAY OF WRIT OF EXECUTION AND NOW, this ?k day ofd:jI , , 2012, in consideration of the within Petition to Open Judgment and on Petition of Craig I. Adler, 7 Esquire, attorney for Defendant Kesler, a Rule is granted on Plaintiff Deutsche Bank t National Trust Company as Trustee, under the Pooling and Servicing Agreement Series ITF RAST 2006-A3, to show cause, if any, why the Petition should not be granted. L Furthermore, in consideration of the within Petition to Open Judgment and Stay Sheriffs Sale, the Writ of Execution filed by Plaintiff Deutsche Bank National Trust Company as Trustee, under the Pooling and Servicing Agreement Series ITF RAST 2006-A3, is hereby STAYED and Plaintiffs Sheriff's Sale related to the real property located at 245 North 25th Street, Camp Hill, PA 17011 is hereby STAYED . RULE RETURNABLE on IJ6 day of JU?IlrG 92012, in Courtroom , Carlisle, PA _ Am. BY J. Thom s A. Placey Distribution List!/Craig I. Adler, Esquire Common Pleas Judge Capozzi and Associates, P.C. 1200 Camp Hill Bypass, Ste. 205 Camp Hill, PA 17011 w ? Chandra M. Arkema, Esq. rn CU Parker McCay, P.A. = 9000 Midlantic Drive, Suite 300 Na P.O. Box 5054 ` n Mount Laurel, NJ 08054 ?- t X5 ma- led 8 %,PARKER McCAY P.A. By: Chandra M. Arkema, Esquire Attorney ID# 203437 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054 (856) 810-5815 Attorney for Plaintiff File #:14997-0003 Y 9 6 ! 1 '? .,+JC?IaEVJ?? . to , i t- a; CQU $T` AU A Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series TTF RAST 2006-A3 888 East Walnut Street Pasadena, CA 91101 Plaintiff, v. Jeannie B. Mohmand 817 Meadow Lane Camp Hill, PA 17011 Defendant and Joshua Kesler 245 North 25" Street Camp Hill, PA 17011 Terre-tenant Property: 245 North 25th Street Camp Hill, PA 17011 : COURT OF COMMON PLEAS : CUMBERLAND COUNTY DOCKET NO.06-6376 11-8702 : CIVIL ACTION : MORTGAGE FORECLOSURE PRAECIPE TO ATTACH TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please add the attached 10 Day Notice Letters, which were inadvertently omitted, to the Praecipe to Enter Default Judgment on the Writ of Revival that was docketed on June 1, 2012. PARKER MCCAY PA (n 114 0 PA Dated: June 18, 2012 By: an a M. Arkema, Esquire Attorney for Plaintiff ATTORNEYS AT LAW P: 856-596-8900 F: 856-596-9631 www.parkermccay.com Foreclosure/Bankruptcy Dept P: 856-810-5815 F: 856-596-3427 May 1, 2012 Ka Certified Mail, R.R.R. & Regular Mail Jeannie B. Mohmand 817 Meadow Lane Camp Hill, PA 17011 Parker McCay P.A. 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054-1539 File No. 14997-0003 Re: Mohmand, Jeannie B. and Kesler, Joshua ads. Deutche Bank National Trust Company, et al Docket No. 11-8702 Dear Sir/Madam: Enclosed herewith please find a Notice of Intention to file Praecipe for Entry of Default Judgment. If you should have any questions, please do not hesitate to contact our office. THIS LETTER IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Very truly yours, Q49. MXA"Xa- CMA/jh Enclosure Mount Laurel, New Jersey I Lawrenceville, New Jersey I Atlantic City, New Jersey PARKER McCAY P.A. By: Chandra M. Arkema, Esquire Attorney ID# 203437 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054 (856) 810-5815 Attorney for Plaintiff File #:14997-0003 Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series ITF RAST 2006-A3 888 East Walnut Street Pasadena, CA 91101 V. Plaintiff, Jeannie B. Mohmand 4020 Lisburn Road Mechanicsburg, PA 17055 Defendant, Joshua Kesler 245 North 25th Street Camp Hill, PA 17011 Terre-tenant, COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 11-8702 : CIVIL ACTION : MORTGAGE FORECLOSURE NOTICE OF INTENTION TO FILE PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT ON THE WRIT OF REVIVAL TO: Jeannie B. Mohmand 817 Meadow Lane Camp Hill, PA 17011 DATE OF NOTICE: May 1, 2012 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTION,' TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (I0') 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. Cumberland County MidPenn Legal Services 401 East Louther Street Carlisle, PA 17013 (800) 822-5288 / (717) 243-9400 NOTICE REQUIRED BY THE FAM I At COLLECTION PRACTICES ACT: WE ARE ATTEMPTING TO COLbEtr A DEBT, AND ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. Respectfully Submitted, PARKER McCAY P.A. BY: .U W W L6k j (i4\Y,4 l l(f ? Chandra M. Arkema, Esquire Attorney for Plaintiff DATE: May 1, 2012 VIA CERTIFIED MAIL, R.R.R. AND FIRST CLASS MAIL .t , f, Parker McCay P.A. 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054-1539 ATTORNEYS AT LAW P: 856-596-8900 F: 856-596-9631 www.parkermccay.com Foreclosure/Bankruptcy Dept P: 856-810-5615 F: 856-596-3427 May 1, 2012 File No. 14997-0003 Via Certified Mail. R.R.R. & Regular Mail Craig I. Idler, Esquire 2933 N. Front Street Harrisburg, PA 17110 Attorney for Joshua Kesler Re: Mohmand, Jeannie B. and Kesler, Joshua ads. Deutche Bank National Trust Company, et al Docket No. 11-8702 Dear Sir/Madam: Enclosed herewith please find a Notice of Intention to file Praecipe for Entry of Default Judgment. If you should have any questions, please do not hesitate to contact our office. THIS LETTER IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Very truly yours, CMA/jh Enclosure Mount Laurel, New Jersey I Lawrenceville, New Jersey I Atlantic City, New Jersey PARKER McCAY P.A. By: Chandra M. Arkema, Esquire Attorney ID# 203437 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054 (856) 810-5815 Attorney for Plaintiff File #:14997-0003 Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series ITF RAST 2006-A3 888 East Walnut Street Pasadena, CA 91101 V. Plaintiff, Jeannie B. Mohmand 4020 Lisburn Road Mechanicsburg, PA 17055 Defendant, Joshua Kesler 245 North 25th Street Camp Hill, PA 17011 Terre-tenant, : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : DOCKET NO.: 11-8702 : CIVIL ACTION : MORTGAGE FORECLOSURE NOTICE OF INTENTION TO FILE PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT ON THE WRIT OF REVIVAL TO: Craig I. Adler, Esquire 2933 N. Front Street Harrisburg, PA 17110 Attorney for Joshua Kesler DATE OF NOTICE: May 1, 2012 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) 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. Cumberland County MidPenh Legal Services 401 East Lowther Street CarAile, I''A 17013 (800) 822-5288 / (717) 243-9400 NOTICE REQUIRED BY THE FAIR DEBT COLLECTION PRACTICES ACT: WE ARE ATTEMPTING TO COLLECT A DEBT, AND ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. Respectfully Submitted, PARKER McCAY P.A. BY: (A Chandra M. Arkema, Esquire Attorney for Plaintiff DATE: May 1, 2012 VIA CERTIFIED MAIL, R.R.R. AND FIRST CLASS MAIL ?.: ?;: Parker McCay P.A. 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054-1539 ATTORNEYS AT LAW P: 856-596-8900 F: 856-596-9631 www.parkermccay.com Foreclosure/Bankruptcy Dept. P: 856-810-5815 F: 856-596-3427 May 1, 2012 File No. 14997-0003 Via Certired Mail, R.R.R. & Regular Mail Joshua Kesler 245 North 25`x' Street Camp Hill, PA 17011 Re: Mohmand, Jeannie B. and Kesler, Joshua ads. Deutche Bank National Trust Company, et al Docket No. 11-8702 Dear Sir/Madam: Enclosed herewith please find a Notice of Intention to file Praecipe for Entry of Default Judgment. If you should have any questions, please do not hesitate to contact our office. THIS LETTER IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Very truly yours, A RKEMA CMA/jh Enclosure Mount Laurel, New Jersey I Lawrenceville, New Jersey I Atlantic City, New Jersey PARKER McCAY P.A. By: Chandra M. Arkema, Esquire Attorney ID# 203437 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054 (856) 810-5815 Attorney for Plaintiff File #:14997-0003 Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series ITF RAST 2006-A3 888 East Walnut Street Pasadena, CA 91101 Plaintiff, V. : COURT OF COMMON PLEAS : CUMBERLAND COUNTY DOCKET NO.: 11-8702 CIVIL ACTION MORTGAGE FORECLOSURE Jeannie B. Mohmand 4020 Lisburn Road Mechanicsburg, PA 17055 Defendant, Joshua Kesler 245 North 25th Street Camp Hill, PA 17011 Terre-tenant, T TO: Joshua Kesler 245 North 25th Street Camp Hill, PA 17011 DATE OF NOTICE: May 1, 2012 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) 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. Cumberland County MidPenn Legal Services 401 East Lo!Aer Street Carlisle; PA 17013 (800) 822-5288 / (717) 243-9400 NOTICE REQUIRED BY THE FAIR DEBT COLLECTION PRACTICES ACT: WE ARE ATTEMPTING TO COLLECT A DEBT, AND ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. Respectfully Submitted, PARKS McCAY P.A. BY: rind Chan a M. Arkema, Esquire Attorney for Plaintiff DATE: May 1, 2012 VIA CERTIFIED MAIL, R.R.R. AND FIRST CLASS MAIL .,, :, Parker McCay P.A. 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054-1539 ATTORNEYS AT LAW May 1, 2012 P: 856-596-8900 F: 856-596-9631 www.parkermccay.com Foreclosure/Bankruptcy Dept. P: 856-810-5815 F: 856-596-3427 File No. 14997-0003 Via Certified Mail, R.R.R. & Regular Mail Jeannie B. Mohmand 817 Meadow Lane Camp Hill, PA 17011 Re: Mohmand, Jeannie B. and Kesler, Joshua ads. Deutche Bank National Trust Company, et al Docket No. 11-8702 Dear Sir/Madam: Enclosed herewith please find a Notice of Intention to file Praecipe for Entry of Default Judgment. If you should have any questions, please do not hesitate to contact our office. THIS LETTER IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Very truly yours, A Enclosure Mount Laurel, New Jersey I Lawrenceville, New Jersey I Atlantic City, New Jersey PARKER McCAY P.A. By: Chandra M. Arkema, Esquire Attorney ID# 203437 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054 (856) 810-5815 Attorney for Plaintiff File #:14997-0003 Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series ITF RAST 2006-A3 888 East Walnut Street Pasadena, CA 91101 Plaintiff, V. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 11-8702 CIVIL ACTION MORTGAGE FORECLOSURE Jeannie B. Mohmand 4020 Lisburn Road Mechanicsburg, PA 17055 Defendant, Joshua Kesler 245 North 25th Street Camp Hill, PA 17011 Terre-tenant, NOTICE OF INTENTION TO FILE PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT ON THE WRIT OF REVIVAL TO: Jeannie B. Mohmand 817 Meadow Lane Camp Hill, PA 17011 DATE OF NOTICE: May 1, 2012 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS' TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) 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. Cumberland County MidPenn Legal Services 401 East Louther Street Carlisle, PA 17013 (800) 822-5288 / (717) 243-9400 NOTICE REQUIRED BY THE FAA lift-i COLLECTION PRACTICES ACT: WE ARE ATTEMPTING TO COLLECT A DEBT, AND ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. Respectfully Submitted, PARKER McCAY P.A. BY:IX W UV (,& AJ L4\Z4 t LV-- ? Chandra M. Arkema, Esquire Attorney for Plaintiff DATE: May 1, 2012 VIA CERTIFIED MAIL, R.R.R. AND FIRST CLASS MAIL ATTORNEYS AT LAW Parker McCay P.A. 9000 Midlantic Drive, Suite 300 P.0. Box 5054 Mount Laurel, New Jersey 08054-1539 P: 856-596-8900 F: 856-596-9631 www.parkermccay.com Foreclosure/Bankruptcy Dept. P: 856-810-5815 F: 856-596-3427 May 1, 2012 Via Certified Mail, R.R.R. & Regular Mail Craig I. Idler, Esquire 2933 N. Front Street Harrisburg, PA 17110 Attorney for Joshua Kesler File No. 14997-0003 Re: Mohmand, Jeannie B. and Kesler, Joshua ads. Deutche Bank National Trust Company, et al Docket No. 11-8702 Dear Sir/Madam: Enclosed herewith please find a Notice of Intention to file Praecipe for Entry of Default Judgment. If you should have any questions, please do not hesitate to contact our office. THIS LETTER IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Very truly yours, (;A CMA/jh Enclosure Mount Laurel, New Jersey I Lawrenceville, New Jersey I Atlantic City, New Jersey PARKER McCAY P.A. By: Chandra M. Arkema, Esquire Attorney ID# 203437 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054 (856) 810-5815 Attorney for Plaintiff File #:14997-0003 Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series ITF RAST 2006-A3 888 East Walnut Street Pasadena, CA 91101 V. Plaintiff, Jeannie B. Mohmand 4020 Lisburn Road Mechanicsburg, PA 17055 Defendant, Joshua Kesler 245 North 25`h Street Camp Hill, PA 17011 Terre-tenant, TO: Craig I. Adler, Esquire 2933 N. Front Street Harrisburg, PA 17110 Attorney for Joshua Kesler DATE OF NOTICE: May 1, 2012 COURT OF COMMON PLEAS CUMBERLAND COUNTY : DOCKET NO.: 11-8702 : CIVIL ACTION : MORTGAGE FORECLOSURE IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) 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. Cumberland County MidP.enb Legal Services 401 East ,Lowther Street CarteWc, ]HA 17013 (800) 822-5288 / (717) 243-9400 NOTICE REQUIRED BY THE FAIR DEBT COLLECTION PRACTICES ACT: WE ARE ATTEMPTING TO COLLECT A DEBT, AND ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. Respectfully Submitted, PARKER McCAY P.A. BY: (4f UZ &Z "ZdZjjZ#1 Chandra M. Arkema, Esquire Attorney for Plaintiff DATE: May 1, 2012 VIA CERTIFIED MAIL, R.R.R. AND FIRST CLASS MAIL; Parker McCay P.A. 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054-1539 ATTORNEYS AT LAW P: 856-596-8900 F: 856-596-9631 www.parkermccay.com Foreclosure/Bankruptcy Dept. P: 856-810-5815 F: 856-596-3427 May 1, 2012 File No. 14997-0003 Via Certified Mail, R.R.R. & Rerular Mail Joshua Kesler 245 North 25`h Street Camp Hill, PA 17011 Re: Mohmand, Jeannie B. and Kesler, Joshua ads. Deutche Bank National Trust Company, et al Docket No. 11-8702 Dear Sir/Madam: Enclosed herewith please find a Notice of Intention to file Praecipe for Entry of Default Judgment. If you should have any questions, please do not hesitate to contact our office. THIS LETTER IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Very truly yours, A RKEMA CMA/jh Enclosure Mount Laurel, New Jersey I Lawrenceville, New Jersey I Atlantic City, New Jersey PARKER McCAY P.A. By: Chandra M. Arkema, Esquire Attorney ID# 203437 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054 (856) 810-5815 Attorney for Plaintiff File #:14997-0003 Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series ITF RAST 2006-A3 888 East Walnut Street Pasadena, CA 91101 Plaintiff, V. Jeannie B. Mohmand 4020 Lisburn Road Mechanicsburg, PA 17055 Defendant, Joshua Kesler 245 North 25th Street Camp Hill, PA 17011 ' Terre-tenant, : COURT OF COMMON PLEAS : CUMBERLAND COUNTY DOCKET NO.: 11-8702 CIVIL ACTION MORTGAGE FORECLOSURE EFAULT TO: Joshua Kesler 245 North 25th Street Camp Hill, PA 17011 DATE OF NOTICE: May 1, 2012 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) 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. Cumberland County MidPenn Legal Services 401 EasttLoither Street Carlisle"PA 17013 (800) 822-5288,/ (717) 243-9400 NOTICE REQUIRED BY THE FAIR DEBT COLLECTION PRACTICES ACT: WE ARE ATTEMPTING TO COLLECT A DEBT, AND ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. Respectfully Submitted, PARKER McCAY P.A. BY:j /f LA-4 V A/ UALAI A=U / Chandra M. 7Aema, Esquire Attorney for Plaintiff DATE: May 1, 2012 VIA CERTIFIED MAIL, R.R.R. AND FIRST CLASS MAIL PARKER McCAY P.A. By: Chandra M. Arkema, Esquire Attorney ID# 203437 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054 (856) 810-5815 Attorney for Plaintiff File #:14997-0003 Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series ITF RAST 2006-A3 888 East Walnut Street Pasadena, CA 91101 Plaintiff, V. Jeannie B. Mohmand 817 Meadow Lane Camp Hill, PA 17011 Defendant and Joshua Kesler 245 North 25 b Street Camp Hill, PA 17011 Terre-tenant Property: 245 North 25`a Street Camp Hill, PA 17011 : COURT OF COMMON PLEAS : CUMBERLAND COUNTY DOCKET NO. 06-6376/11-8702 CIVIL ACTION MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I hereby certify that on this 18'h day of June, 2012, that a copy of the Praecipe to Attach herein described was sent to the following parties, via U.S. First Class Mail, postage prepaid: Jeannie B. Mohmand, 817 Meadow Lane, Camp Hill, PA 17011; Joshua Kesler, 245 North 25'h Street, Camp Hill, PA 17011; Craig I. Idler, Esq., Capozzi & Associates, PC, 1200 Camp Hill Bypass, Ste. 205, Camp Hill, PA 17011. PARKER McC P.A. By: 11 will IVI Chandra M. Arkema, Esquire Attorney for Plaintiff 0(?5- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEUTSCHE BANK NATIONAL TRUST NO. 06-63 6/11-8702 COMPANY AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT SERIES ITF RAST 2006-A3 888 East Walnut Street Pasadena, CA 91101 Plaintiff : vs. CIVIL ACTION . MORTGAGE FORECLOSURE JEANNIE B. MOHMAND, 817 Meadow Lane : Camp Hill, PA 17011 : Defendant C and a JOSHUA KESLER, < Cn 245 North 25th Street m M ss 4 Camp Hill, PA 17011 ?a Terre-Tenant ORDER AND NOW, this [.L day of , 2008, upon consideration of Defendant Kesler's Motion for Continuance of Hearing, the Motion is GRANTED and the hearing scheduled for this matter on June 22, 2012 is cancelled and will be rescheduled, if necessary, for a later time. Date: By: Thomas A. Placey Common Pleas Judge 3 Distribution List Craig I. Adler, Esquire Capozzi and Associates, P.C. 1200 Camp Hill Bypass, Ste. 205 Camp Hill, PA 17011 ? Chandra M. Arkema, Esq. Parker McCay, P.A. 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, NJ 08054 Copes ?-1,? ??a?/ice 4 •SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~ 4~~ti4~ of t+urrfj~~{~h t~ ;:~ ~~. ~F~..~~~ .._ .~~~~~~ ~'~~ ~N~ P~R~~l~~~i T;~R'~' 212 SEP -4 pM 2: 0 f cuM~~~L~x~ c~uMr~ p~~SY1,YANlA Deutsche Bank National Trust Company Case Number vs. Jeannie B. Mohmand (et al.) 2011-8702 SHERIFF'S RETURN OF SERVICE 06/21/2012 04:15 PM -Deputy Ryan Burgett, 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 245 North 25th Street, Camp Hill, PA 17011, Cumberland County. 06/21/2012 04:15 PM -Deputy Ryan Burgett, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be SEAN HOWIE-BABYSITTER, who accepted as "Adult Person in Charge" for Joshua Kesler at 245 North 25th Street, Camp Hill Borough, Camp HIII, PA 17011, Cumberland County. 06/21/2012 05:16 PM -Deputy Ryan Burgett, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be FATIMA MUHMAND-SISTER IN LAW, who accepted as "Adult Person in Charge" for Jeannie B. Mohmand at 817 Meadow Lane, Camp Hill, PA 17011, Cumberland County. 0 812 912 0 1 2 As directed by Chandra Arkema, Attorney for the Plaintiff, Sheriffs Sale Continued to 10/3/2012 08/30/2012 Property sale removed from 10/3/2012 sale. 08/30/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per Order of Court dated June 12, 2012. SHERIFF COST: $780.13 August 30, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF ~-as ~,~.~o- . s ~ t~~- ~~o ~~3 tci CounivSuite Sho~i(t 9~elrosc,ft. Irc. ~. PARKER McCAY P.A. By: Chandra M. Arkema, Esquire Attorney ID# 203437 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054 (856) 810-5815 Attorney for Plaintiff File #:14997-0003 Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series TTF RAST 2006-A3 888 East Walnut Street Pasadena, CA 91101 Plaintiff, v. Jeannie B. Mohmand, 817 Meadow Lane Camp Hill, PA 17011 Defendant and Joshua Kesler 245 North 25~' Street Camp Hill, PA 17011 Terre-tenant Property: 245 North 25`~ Street Camp Hill, PA 17011 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.~~/11-8702 CIVIL ACTION MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series ITF RAST 2006-A3, Plaintiff in the above action, comes by its attorney and sets forth, as of the date the Praecipe for Writ of Execution was filed, the following information concerning the real property located at 245 North 25~' Street, Camp Hill, PA 17011: 1. Name and address of Owner(s) or Reputed Owner(s): Name Joshua Kesler 245 North 25 Street Camp Hill, PA 17011 Address (if address cannot be reasonably ascertained, please so indicate) 2. Name and address of Defendants in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) Jeannie B. Mohmand 817 Meadow Lane, Cam Hill, PA 17011 Joshua Kesler (Terre-tenant) 245 North 25 Street Cam Hill, PA 17101 3. 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 so indicate) Deutsche Bank National Trust Company as Trustee 888 East Walnut Street under the Pooling and Servicing Agreement Series Pasadena, CA 91101 ITF RAST 2006-A3 Deutsche Bank National Trust Company 460 Sierra Madre Villa Avenue, Suite 101 Pasadena, CA 91107 The Harrisburg Academy 10 Erford Road Wormle sbur , PA 17043 Members 1 S` Federal Credit Union 5000 Louise Drive Mechanicsbur , PA 17055 ACCO York Federal Credit Union 1529 Rodney Road York PA 17404 PSECU 1 Credit Union Place Harrisbur , PA 17110 The Harrisburg Academy c/o David F. O'Leary, 1 S. Market Sq., P.O. Box 173 Es uire Harrisbur , PA 17108-1146 Members 1 gc Federal Credit Union c/o Karl M. P.O. Box 173 Ledebohm, Es uire New Cumberland, PA 17070-0173 ACCO York Federal Credit Union c/o Edward A. 2675 Eastern Boulevard Paske , Es uire York, PA 17402-2905 PSECU c/o Melissa L. Van Eck, Esquire 3401 N. Front Street Harrisbur , PA 17110 4. Name and address of the last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please so indicate) Lancaster Mortgage Bankers, A Limited Liability 20 Independence Blvd Com an Warren, New Jerse 07059 Deutsche Bank National Trust Company as Trustee 888 East Walnut Street under the Pooling and Servicing Agreement Series Pasadena, CA 91101 IT'F RAST 2006-A3 Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please so indicate) Dustin J. Malesich 730 South 10 Street Harrisburg, PA 17104 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please so indicate) Janet Miller 1939 Walnut Street Coun /Munici aU School) Cam Hill, PA 17011 Camp Hill Borough 2145 Walnut Street Sewer Cam Hill, PA 17011 PA American 800 West Hershey Park Drive ater Hershe , PA 17033 Penn Waste P.O Box 3066 York, PA 17402 Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations 13 North Hanover Street, P.O. Box 320 Carlisle, PA 17013 Commonwealth of Pennsylvania 333 Health and Welfare Building D artment of Welfare Harrisbur , PA 17105 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 so indicate) Tenant/Occupant 245 North 25 Street Cam Hill, PA 17101 Craig I. Adler, Esquire 2933 N. Front Street Attorne for Joshua Kesler Harrisbur , PA 17110 Paul R. VanFleet, Esquire P.O. Box 5866 Attorne for Joshua Kesler Harrisbur , PA 17110 I verify that the statements made in this affidavit are true and correct to the best of my personal lrnowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. M. ARKEMA, ESQUIltE Attorney for Plaintiff Date: May 24, 2012 PARKER McCAY P.A. _ _ __ By: Chandra M. Arkema, Esquire Attorney ID# 203437 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054 (856) 810-5815 Attorney for Plaintiff File #:14997-0003 Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series ITF RAST 2006-A3 888 East Walnut Street Pasadena, CA 91101 Plaintiff, v. Jeannie B. Mohmand, 817 Meadow Lane Camp Hill, PA 17011 Defendant and Joshua Kesler 245 North 25`~ Street Camp Hill, PA 17011 Terre-tenant Property: 245 North 25~' Street Camp Hill, PA 17011 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 06-6376/11-8702 CIVIL ACTION MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Joshua Kesler 245 North 25~' Street Camp Hill, PA 17011 The real estate located at 245 North 25~' Street, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on September 5, 2012 at 10:00 a.m., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. (The specific room location will be posted at every entrance to the courthouse; or Deputies posted at each entrance may direct you to the room.) to enforce the in rem court judgment of $377,750.55 plus fees, costs and other charges obtained by Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement Series ITF RAST 2006-A3, against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 1. This sale will be canceled if you pay the judgment to Chandra M. Arkema, Esquire, 9000 Midlantic Drive, Suite 300, P.O. Box 5054, Mount Laurel, NJ 08054. To find out how much you must pay, you may call (856) 810-5815. 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. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling the Sheriffs Office at (717) 240-6390 or Chandra M. Arkema, Esquire at (856) 810-5815. 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 fmd out if this has happened, you may call the Sheriffs Office at (717) 240-6390 or Chandra M. Arkema, Esquire at (856) 810-5815. 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 a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on the 30th day after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days of the preparation of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your house 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIIZING 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. Court Administrator Cumberland County Courthouse 4`n Floor Carlisle, PA 17013 (717) 240-6200 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 Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. LEGAL DESCRIPTION ALL THAT CERTAIN lot or parcel of land situate in the Borough of Camp Hill, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point, the intersection of the easterly line of North Twenty-Fifth Street, formerly Locust Avenue, with the southerly line of Lincoln Street; thence north 79 degrees 30 minutes east along the southerly line of Lincoln Street, a distance of one hundred forty (140) feet to a point on St. John's Alley; thence south 10 degrees 30 minutes east along the westerly line of St. John's Alley, a distance of eighty (80) feet to a point; thence south 79 degrees one hundred forty (140) feet to a point on the easterly line of North Twenty-Fifth Street, formerly Locust Avenue; thence north 10 degrees 30 minutes west, along the easterly line of North Twenty-fifth Street, formerly Locust Avenue, a distance of eighty (80) feet to a point, the place of Beginning. HAVING thereon erected atwo-story dwelling known and numbered as 245 North Twenty-Fifth Street, Camp Hill, in the Borough of Camp Hill, Pennsylvania. BEING the same premises which Community Banks granted and conveyed unto Jeannie Mohmand, deed dated October 26, 2005, and recorded in the Cumberland County Recorder of Deeds by instrument number 200541121. PARCEL IDENTIFICATION NO.: O 1-21-0271-050; CONTROL #01001166 TITLE TO SAID PREMISES IS VESTED IN Joshua Kesler, by Deed from Jeannie Mohmand, dated 03/28/2008, recorded 03/31/2008 in Book 271, Page 3558. CUMBERLAND LAW JOURNAL Writ No. 2011-8702 Civil Term TITLE TO SAID PREMISES IS VESTED IN Joshua Kesler, by Deed Deutsche Bank National from Jeannie Mohmand, dated Trust Company 03/28/2008, recorded 03/31/2008 vs in Book 271, Page 3558. Jeannie B. Mohmand Joshua Kesler Atty.: Chandra Arkema ALL THAT CERTAIN lot or pazcel of land situate in the Borough of Camp Hill, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point, the inter- section of the easterly line of North Twenty-Fifth Street, formerly Locust Avenue, with the southerly line of Lincoln Street; thence north 79 degrees 30 minutes east along the southerly line of Lincoln Street, a dis- tance of one hundred forty (140) feet to a point on St. John's Alley; thence south 10 degrees 30 minutes east along the westerly line of St. John's Alley, a distance of eighty (80) feet to a point; thence south ?9 degrees one hundred forty (140) feet to a point on the easterly line of North Twenty- Fifth Street, formerly Locust Avenue; thence north 10 degrees 30 minutes west, along the easterly line of North Twenty-fifth Street, formerly Locust Avenue, a distance of eighty (80) feet to a point, the place of Beginning. HAVING thereon erected atwo- story dwelling known and numbered as 245 North Twenty-Fifth Street, Camp Hill, in the Borough of Camp Hill, Pennsylvania. BEING the same premises which Community Banks granted and conveyed unto Jeannie Mohmand, deed dated October 26, 2005, and recorded in the Cumberland County Recorder of Deeds by instrument number 200541121. PARCEL IDENTIFICATION NO.: 01-21-0271-050; CONTROL #01001166. 71 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (iJnder 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: July 27, August 3, and August 10, 2012 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. L a Marie Coyne, Edi r SWORN TO AND SUBSCRIBED before me this 10 da of Au st 2012 - Notary NOTARIAL SE DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 The Patriot News Co. 2020 Technology Pkwy •Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE c~he ~latriot-dews Now you know CARLISLE PA 17013 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: 07/27/12 08/03/12 08/10/12 COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L. Owens, Notary Public ~ Lawer Paxton Twp„ Oauphln County My Commission fires Nov. 26, 2015 MEMBER, QENN~YINANIA ASSOCSAT[UN OF NOTARIES 2011.8702 Civii Term deutsche Bank National Trust Company Vs Jeannie B. Mohmand Joshua Kesler Arty: Chandra Arkema ALL "[T LT CERTAIN lot or paace! of land situate in the Borough of Camp Hill, Couniv of Cumberland and Stxte «f Pennsylvania, mote particularly hounded and described as follows, to wit: BEC,INNING at a point, the intersectiou of the easterly line of North Twenty-Fifth Street, formerly Locust Avenue. with the southerly ]ine of Una~1n Street. thenc: north 79 degrees 30 minutes cast a(nnti~ the wuthedv line of Lincoln Street, a distaurce of one hundred forty (14(1) feet to a pnmt ~~n 5t. Johns Alley; thence south 10 dep~re~ ~~ ?11 minute, cast along the westerly !ir<e ~ ~l 5t. John`s Alley, a distance of eighty t8(~ ~ feet to a point; thence south 79 degrees ~ ~nr hundredforty (]4O) feet to a p~.im on >>:.~ easterly line of North Twenh~-Firth 5trer'_ formerly Locust Avenue; thcrcc n~~~~tti P. degrees?0 minuteswest, along r',, east~r'~ iinc of North Twenty-fifth Stre< formr.h Locust Avenue, a distance of eight} (SO) teet to a point, the place of Beginning. HAVING thereon erected a two-~tiirv dwel]ing known and numbered as 24? Kurth Twenty-Fifth Street Camp Hill, in the 14arough of Camp Hill, Pennsy9vania- BEINGthe same premises which Community Sanks granted and conveyed unto Jeannie Mohmand, deed dated October ~, 2005, and recorded in the Cumberland County Recorder of Deeds by instrument number 20054ll21. PARCEL IDENTIFICATION NO.: Ol-21~ U271-0~0; CONTROL #01001166 CITLE TO SAID PREMISES IS VE51 Efr } N Joshua Kesler, by Deed from Jeannie '.viohmand, dated 03l28i3008, recorded tt~31 20O~ in B~,~,k'_'1. Pace ?y5`. `..., r 1 '~{ ~' ` ~ i t~ ` PARKER McCAY P.A. Chandra M. Arkema, Esquire ~ i ~ ; '~ F'' 1 ~? t, `1 ~~ c' Attorney I.D. No. 203437 9000 Midlantic Drive, Suite 300 >A; ~ ~ ~ C i~ ~~ j 4~' ~°~ ~ ~:. ~ ~ ~- Mount Laurel, NJ 08054-1539 ~ > ° ~ ~ `~"' ~ ~ ~ ~~~ ~d ~ ~ P: 856-810-5815 F: 856-596-3427 Deutsche Bank National Trust Company as Trustee Under the Pooling and Servicing Agreement Series ITF RAST 2006-A3, Plaintiff, v. Jeannie B. Mohmand and Joshua Kesler, Terre-Tenant, Defendants. Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL DIVISION No. 06-6376/11-8702 /` PRAECIPE TO SATISFY FORECLOSURE JUDGMENT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Kindly mark the in rem foreclosure judgment entered in the above-captioned matter as satisfied. Date: j (l~ ~} J~~ 2- PARKER McCAY, P.A. ,-, Chandra M. Arkema, Esquire Attorney for Plaintiff PMC File No. 14335-0041 PARKER McCAY P.A. Chandra M. Arkema, Esquire Attorney I.D. No. 203437 9000 Midlantic Drive, Suite 300 Mount Laurel, NJ 08054-1539 P:856-810-5815 F: 856-596-3427 Deutsche Bank National Trust Company as Trustee Under the Pooling and Servicing Agreement Series ITF RAST 2006-A3, Plaintiff, v. Jeannie B. Mohmand and Joshua Kesler, Terre-Tenant, Defendants. Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL DIVISION No. 06-6376/11-8702 PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY OF CUMBERLAND COUNTY: • ' ,.. , ,~ .. __, ~,. „---„ r,~ . ,, r._„ .. ..~,~ .'c-i ~ - °w . ~~ °- =- r~i ~:' ~~,~;~ - , Please mark the above-captioned action in mortgage foreclosure as settled, discontinue, and ended, with prejudice. Date: J 1 /J~'~D1~ PARKER McCAY, P.A. ti By Chandra M. Arkema, Esquire Attorney for Plaintiff PMC File No. 14335-0041 • PARKER McCAY P.A. ' Chandra M. Arkema, Esquire Attorney I.D. No. 203437 9000 Midlantic Drive, Suite 300 Mount Laurel, NJ 08054-1539 P: 856-810-5815 F: 856-596-3427 Deutsche Bank National Trust Company as Trustee Under the Pooling and Servicing Agreement Series ITF RAST 2006-A3, Plaintiff, v. Jeannie B. Mohmand and Joshua Kesler, Terre-Tenant, Defendants. Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL DIVISION No. 06-6376/11-8702 CERTIFICATE OF SERVICE I, Chandra M. Arkema, Esquire, hereby certify that I have, this date, caused true and correct copies of the foregoing Praecipe to Satisfy Foreclosure Judgment and Praecipe to Discontinue to be served by U.S. Mail, first class, postage prepaid, addressed as follows: Jeannie B. Mohmand 817 Meadow Lane Camp Hill, PA 17011 Date: ~~ ~ ~ ~ ~ ~ ~- Craig I. Adler, Esquire Capozzi & Associates, P.C. P.O. Box 5866 Harrisburg, PA 17110 Attorney for Joshua Kesler PARKER McCAY, P.A. Bye , ~n~ Chandra M. Arkema, Esquire Attorney for Plaintiff PMC File No. 14335-0041