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UDREN LAW OFFICES, P.C.
BY: MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675
PAIGE M. BELLINO, ESQUIRE - ID#309091
HARRY B. REESE, ESQUIRE - ID#310501
AMY GLASS, ESQUIRE - ID#308367
KASSIA FIALKOFF, ESQUIRE - ID#310530
ELIZABETH L. WASSALL, ESQUIRE - ID#77788
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400 pleadin_2s(c?.udren.com
ATTORNEY FOR PLAINTIFF
Deutsche Bank National Trust Company, as Trustee for GSAMP
Trust 2005-WMC1, Pooling and Servicing Agreement dated as of
September 1, 2005
C/O Ocwen Loan Servicing, LLC
1661 Worthington Road #100
West Palm Beach, FL 33409
Plaintiff
v.
KRISTINA STAMBAUGH A/K/A K nSTINA M. STAMBAUGH
141 EAST MAIN STREET
WALNUT BOTTOM, PA 17266
RICHARD STAMBAUGH A/K/A RICHARD A. STAMBAUGH
141 EAST MAIN STREET
WALNUT BOTTOM, PA 17266
Defendant(s)
COURT OF
COMMON PLEAS
CIVIL DIVISION
CUMBERLAND
County
NO. /o2- JILI3' vd(/Ir
COMPLAINT IN MORTGAGE FORECLOSURE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this Complaint and Notice
are served, by entering a written appearance personally or by attorney and filing in writing with
the Court your defenses or objections to the claims set forth against you. You are warned that if -05
you fail to do so the case may proceed without you and a judgment may be entered against you
4103.15 Po ATr?
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by the Court without further notice for any money claimed in the Complaint or for any other
claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY
BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT
MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR
NO FEE.
LAWYERS REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(800) 990-9108
AVISO
Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas
en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda
y la notificacion. Hace falta aseentar una comparencia escrita o en persona o con un abogado y
entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su
persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la
demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor
del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted
puede perder dinero o sus propiedades u otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE
ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO,
VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA
DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE
PUEDE CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(800) 990-9108
NOTICE
The amount of your debt is as stated in the attached document. The name of the
creditor to whom the debt is owed is as named in the attached document. Unless you notify
us within 30 days after receipt of this Notice and the attached document that the validity of
the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If
you do notify us in writing of a dispute within the 30 day period, we will obtain verification
of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute
the debt, it is not an admission of liability on your part. Also, upon your written request
within the 30 day period, we will provide you with the name and address of the original
creditor if different from the current creditor.
If you notify us in writing within the 30 day period as stated above, we will cease
collection of your debt, or any disputed portion of it, until we obtain the information that
is required and mail it to you. Once we have mailed to you the required information, we
will then continue the collection of your debt.
This law firm is deemed to be a debt collector and this Notice and the attached document
is an attempt to collect a debt, and any information obtained will be used for that purpose.
UDREN LAW OFFICES, P.C.
/s/ Mark J. Udren, Esquire
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill, NJ 08003-3620
(856) 669-5400
1. Plaintiff is the entity designated in the caption on a preceding page. Plaintiff is the
legal holder of the Mortgage that is the subject of this Action. Plaintiff is either the
current mortgagee of record, is the legal holder of the Mortgage by virtue of being
successor in interest to the current mortgagee of record, or is the legal holder of the
Mortgage by virtue of Assignment of Mortgage. If Plaintiff is the legal holder of the
Mortgage by virtue of Assignment of Mortgage, it is by the following Assignments of
Mortgage, all of which have either been recorded or Plaintiff is in the process of
formalizing the actual Assignment of Mortgage in Plaintiff s favor:
Assignor: Mortgage Electronic Registration Systems, Inc.
Assignee: Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing
Agreement Dated as of September 1, 2005, GSAMP Trust 2005-WMC1
Date of Assignment: 07/11/2008
Recorded Date: 08/11/2008
Book/Instrument #: Instrument Number: 200827238
Page:
Assignor: Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing
Agreement Dated as of September 1, 2005, GSAMP Trust 2005-WMCI
Assignee: Deutsche Bank National Trust Company, as Trustee for GSAMP Trust 2005-WMC1,
Pooling and Servicing Agreement dated as of September 1, 2005
Date of Assignment: 01131/2012
Recorded Date:
Book/Instrument #:
Page:
2. Upon information and belief Defendant(s) and/or their predecessor:
Kristina Stambaugh A/k/a Kristina M. Stambaugh & Richard Stambaugh A/k/a
Richard A. Stambaugh
(hereinafter "Defendants"), are the owners of property located at 141 East Main Street,
Walnut Bottom, PA 17266, by virtue of Deed dated 06/30/2005 and recorded
07/06/2005 in Official Records Book 269 at Page 3862 of the Public Records of
Cumberland County, Pennsylvania (hereinafter the "Property").
3. On 06/30/2005 , Defendant(s) and/or their predecessor:
KRISTINA STAMBAUGH A/K/A KRISTINA M. STAMBAUGH
RICHARD STAMBAUGH AMA RICHARD A. STAMBAUGH promised to
pay to the order of WMC Mortgage Corp, the principal sum of $ 106,400.00
payable with interest thereon provided in the Note.
4. By Mortgage dated 06/30/2005, Defendant(s) and/or their predecessor:
KRISTINA STAMBAUGH A/K/A KRISTINA M. STAMBAUGH
RICHARD STAMBAUGH A/K/A RICHARD A. STAMBAUGH
to secure the Note, mortgaged to Mortgage Electronic Registration Systems, Inc.
as nominee for WMC Mortgage Corp, the Property which is the subject of this
action. The Mortgage was recorded on 07/06/2005 in Official Records Book 1913
at Page 3412. Said Mortgage is incorporated herein by referenced in accordance
with Pa.R.C.P 1019(g). A legal description of the mortgage premises is attached
hereto and made a part hereof.
5. Said mortgage is in default in that the payment due 11/01/2010, and all subsequent
payments have not been made, and by its terms, upon breach and failure to cure said
breach after notice, all sums secured by said Mortgage, together with the other charges
authorized by said Mortgage and itemized below, shall be immediately due.
6. After demand, the Defendant(s) continues to fail or refused to comply with the terms of
the Mortgage as follows:
(a) By failing or refusing to pay the installments of principal and interest when due in
the amounts indicated below;
(b) By failing or refusing to pay other charges, if any, indicated below.
The following amounts are due on the said Mortgage or modification agreement as of the
date stated below
Unpaid Principal Balance
Accumulated Interest
Accumulated Late Charges
Escrow Deficit/(Reserve)
Title Report
Attorney Fee
Other Suspense Balance
Prior Servicer Fee
Property Inspection Fee
Property Valuation Fee
Grand Total
The above figures are calculated as of 03/01/2012:
$109,068.19
$10,705.15
$1,543.60
$11,218.35
$300.00
$1,300.00
$-590.53
$829.80
$31.50
$292.00
$134,698.06
The interest rate is subject to adjustment if more fully described as such in the note and
mortgage. The interest rate on the subject note is at 7.00000 %. The per diem interest accruing
on this debt is $20.74 and that sum should be added each day after the above date.
The late charge is subject to adjustment if more fully described as such in the note and
mortgage. The late charge rate on the subject note should be added in accordance to the terms of
the note and mortgage charged monthly at $38.59.
7. Breach letters have been sent to Defendant(s) in accordance with the requirements of
the subject mortgage and/or The Pennsylvania Act 6 of 1974 of the Commonwealth of
Pennsylvania and, if applicable, Act 91 of 1983. Copies of the breach letters are attached
hereto as Exhibit "A".
WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the
sum of $134,698.06 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged
premises.
UDRF,1iLLAW OFFICES,
BY: ) L
PAIGE M. SELLINO, ESQUIR
PA ID 309091
VERIFICATION
The undersigned states that he/she is authorized to make this verification on behalf of the
Plaintiff, and that the facts set forth in the foregoing pleading are true and correct to the best of
the information and belief of the undersigned.
The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S.
Section 4904 relating to unswom falsification to authorities.
Date:
Name: A. Kee*
Cw tdManagement
Title: Coordinator
Company. by its attorney in fact, Ocwen Loan
Servicing, LLC Deutsche Bank National Trust
Company, as Trustee for GSAMP Trust 2005-
WMC1, Pooling and Servicing Agreement dated
as of September 1, 2005
MJU #: 11100710 CASE #: 11100710-1 Transfer
EXMrr A
ALL the following described real estate lying and being situate in the Village of Walnut Bottom, South
Newton Township, Cumberland County, Pennsylvania, more particularly described as follows:
BEGINNING at a set railroad spike in the centerline of PA Traffic Route 174 (Walnut Bottom Road) at
common comer of Lots 1 and 2 on the herein referred to subdivision plan; thence along common boundary
line of Lots 1 and 2, which is also the easterly most boundary of Parcel 1A, South thirty-seven (37) degrees
twenty-four (24) minutes fifty-five (55) seconds East, ninety-six and fifty-seven hundredths (96.57) feet to a
set iron pin-, thence continuing by same, South forty-five (45) degrees forty-nine (49) minutes twenty-five (25)
seconds East, one hundred eighteen and thirty hundredths (118.30) feet to a set iron pin in line of land now or
formerly of Ronald A. Baker; thence along line of land now or formerly of Ronald A. Baker, South forty-nine
(49) degrees zero (00) minutes zero (00) seconds West, thirty-nine and thirty-two hundredths (39.32) feet to a
point; thence continuing by the same, South forty-nine (49) degrees zero (00) minutes zero (00) seconds West,
fifty and zero hundredths (50.00) feet to a point at corner of land now or formerly of Randy K. Boyer; thence
along line of land now or formerly of Randy K. Boyer, North forty-three (43) degrees fifteen (15) minutes two
(02) seconds West, two hundred thirteen and thirty-seven hundredths (213.37) feet to a point in the centerline
of Walnut Bottom Road; thence along the centerline of Walnut Bottom Road, North forty-six (46) degrees
fifty-seven (57) minutes thirty-one (31) seconds East, fifty and zero hundredths (50.00) feet to a point; thence
continuing by same, North forty-nine (49) degrees fifty-seven (57) minutes zero (00) seconds East, forty-three
and eighty-three hundredths (43.83) feet to the set railroad spike, the point and place of BEGINNING.
CONTAINING a total area of 18,793 square feet (0.0431 acres).
BEING known and designated as Lot No. 1 on a subdivision plan entitled "Survey for Mary O. Bowers"
prepared by Steven P. Wolfe, Professional Land Surveyor, dated 4/11/90, which subdivision plan has been
approved by the appropriate municipal authorities as and for a subdivision plan and is recorded in the office of
the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 69, Page 36.
BEING the same premises which Bonnie Swartz and Harold Bowers, Sr., co-Executors of the Last Will and
Testament of Mary O. Bowers, by their deed dated May 10, 1995, and recorded in Cumberland County,
Pennsylvania Deed Book 122, Page 408, granted and conveyed unto Randy V. Singleton, a single man,
Grantor herein.
1 Cert.i ry this to be recorded
i11 ci_itr lbb ,--land County PA
f ?. ;
of Deects
1913PG3421
UT REN LAW OFFICES P. C.
OODCREST CORPORATE CE TER
MARK J. UOREA; ESQUIRE III WOODCREST ROAD
NJ MANAGING ATTORNEY SUITE 200
C ERRY HILL, NEW JERSEY 08T3-3620
1 856. 669. 5400
TINA MARIE RICH FAX. 856. 669. 5399
OFFICE ADULVISTRATOR
FREDDIE MAC
PENNSYLVANIA
DESIGNATED COUNSEL
January 27, 2012
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
ARTICLE 4 7011 1570 0001 9751 1101
Richard Stambaugh
141 East Main Street
Walnut Bottom, PA 17266
RE: Mortgage Loan dated June 30, 2005
NOTICE OF INTENTION TO FORECLOSE
Dear Mortgagor:
The Mortgage serviced by Ocwen Loan Servicing and held by Deutsche
Bank National Trust Company as Trustee under the Pooling and
Servicing Agreement dated as of September 1, 2005, GSAMP Trust
2005-WMC1 (hereinafter we, us or ours) on your property located at
141 East Main Street, Walnut Bottom, PA 17266 IS IN SERIOUS DEFAULT
because you have not made the monthly payments of $1,043.66 for the
months of November 1, 2010 through January 1, 2012.
The last assessed late charge on this account was $38.59 at a late
charge rate of 551. for each delinquent payment (s) . As of today,
late charges have accrued to the total amount of $1,543.60. Other
charges including Property Inspection Fees and Property Valuation
Fees/BPO have accrued at the total amount of $313.00. A Suspense
Balance of $590.53 has been credited to your account. The total
amount now required to cure this default, or in other words, get
caught up in your payments, as of the date of this letter is
$16,920.97.
You may cure this default within THIRTY (30) DAYS of the date of
this letter, by paying to us the above amount of $16,920.97, plus
any additional monthly payments and late charges which may fall due
during this period. Such payment must be made either by cash,
WHITA
cashier's check, certified check or money order, and made to
UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NEW JERSEY 06003-3620
If you do not cure the default within THIRTY (30) DAYS, we intend
to exercise the lender's right to accelerate the mortgage payments.
This means that whatever is owing on the original amount borrowed
will be considered due immediately and you may lose the chance to
pay off the original mortgage in monthly installments.
If full payment of the amount of default is not made within THIRTY
(30) DAYS, the lender also intends to instruct our firm to start a
lawsuit to foreclose your mortgaged property. If the mortgage is
foreclosed your mortgaged property will be sold by the Sheriff or
other similar official to pay off the mortgage debt. If you cure
the default before we begin legal proceedings against you, you will
still have to pay the reasonable attorney's fees actually incurred,
up to $50.00. However, if legal proceedings are started against
you, you will have to pay the reasonable attorney's fees even if
they are over $50.00. Any attorney's fees will be added to
whatever you owe the lender, which may also include our reasonable
costs. If you cure the default within the THIRTY (30) DAY period
you will not be required to pay attorney's fees.
The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage.
If you have not cured the default within the THIRTY (30) DAY period
and foreclosure proceedings have begun, you still have the right to
cure the default and prevent the sale at any time up to one. hour
before the Sheriff's or other similar official foreclosure sale.
You may do so by paying the total amount of the unpaid monthly
payments plus any late or other charges then due, as well as the
reasonable attorney's fees and costs connected with the foreclosure
sale and perform any other requirements under the mortgage. It is
estimated that the earliest date that such a Sheriff's or other
similar official's sale could be held would be approximately six
months from the date of this letter. A notice of the date of the
Sheriff's or similar official sale will be sent to you before the
sale. Of, course, the amount needed to cure the default will
increase the longer you wait. You may find out at any time exactly
what the required payment will be by calling us at the following
number: (856) 669-5400. This payment must be cash, cashier's
check, certified check or money order and made payable to us at the
address stated above.
You should realize that a Sheriff's or other similar official sale
will end your ownership of the mortgaged property and your right to
remain in it. If you continue to live in the property after the
Sheriff's or other similar official sale, a lawsuit could be
started to evict you.
You shall have the right to assert in the foreclosure proceedings,
the non-existence of a default or any other defense that you may
have to acceleration or foreclosure.
You have additional rights to help protect your interest in the
property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY
TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER
LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT
TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER
OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL
THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE
PAID PRIOR. TO OR AT THE SALE, AND THAT THE OTHER REQUIREMENTS UNDER
THE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINE UNDER WHAT
CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE
THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
If you cure the default, the mortgage will be restored to the same
position as if no default had occurred. However, you are not
entitled to this right to cure your default more than three times
in any calendar year.
UDREN LAW OFFICES, P.C.
CC: First: Class Mail
NOTICE
The amount of your debt is as stated in the attached document. The name of the creditor to
whom the debt is owed is as named in the attached document. Unless you notify us within 30
days after receipt of this Notice and the attached document that the validity of the stated debt,
or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in
writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy
of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an
admission of liability on your part. Also, upon your written request within the 30 day period,
we will provide you with the name and address of the original creditor if different from the
current creditor.
If you notify us in writing within the 30 day period as stated above, we will cease collection
of your debt, or any disputed portion of it, until we obtain the information that is required
and mail it to you. Once we have mailed to you the required information, we will then
continue the collection of your debt.
This law firm is deemed to be a debt collector and this Notice and the attached document is
an attempt to collect a debt, and any information obtained will be used for that purpose.
UDREN LAW OFFICES, P.C.
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
WOODCREST CORPORATE CENTER
Ill WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
(856) 664-5400
II REN LAW OFFICES P. C.
OODCREST CORPORATE CE ER
MARK J. UDREN, ESQUIRE III WOODCREST ROAD
N.I MANAGING ATTORNEY SUITE 200
C ERRY HILL, NEW JERSEY 08 3-3620
956. 66Y. 5400
TINA MARIE RICE/ FAX: 856 669. 5399
OFFICE ADMINISTRATOR
FREDDIE MAC
PENNSYLVANIA
DESIGNATED COUNSEL
January 27, 2012
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
ARTICLE # 7011 1570 0001 9751 1095
Kristina Stambaugh
141 East Main Street
Walnut Bottom, PA 17266
RE: Mortgage Loan dated June 30, 2005
NOTICE OF INTENTION TO FORECLOSE
Dear Mortgagor:
The Mortgage serviced by Ocwen Loan Servicing and held by Deutsche
Bank National Trust Company as Trustee under the Pooling and
Servicing Agreement dated as of September 1, 2005, GSAMP Trust
2005-WMC1 (hereinafter we, us or ours) on your property located at
141 East Main Street, Walnut Bottom, PA 17266 IS IN SERIOUS DEFAULT
because you have not made the monthly payments of $1,043.66 for the
months of November 1, 2010 through January 1, 2012.
The last assessed late charge on this account was $38.59 at a late
charge rate of 5% for each delinquent payment(s). As of today,
late charges have accrued to the total amount of $1,543.60. Other
charges including Property Inspection Fees and Property Valuation
Fees/BPO have accrued at the total amount of $313.00. A Suspense
Balance of $590.53 has been credited to your account. The total
amount now required to cure this default, or in other words, get
caught up in your payments, as of the date of this letter is
$16,920.97.
You may cure this default within THIRTY (30) DAYS of the date of
this letter, by paying to us the above amount of $16,920.97, plus
any additional monthly payments and late charges which may fall due
during this period. Such payment must be made either by cash,
cashier's check, certified check or money order, and made to
UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NEW JERSEY 08003-3620
If you do not cure the default within THIRTY (30) DAYS, we intend
to exercise the lender's right to accelerate the mortgage payments.
This means that whatever is owing on the original amount borrowed
will be considered due immediately and you may lose the chance to
pay off the original mortgage in monthly installments.
If full payment of the amount of default is not made within THIRTY
(30) DAYS, the lender also intends to instruct our firm to start a
lawsuit to foreclose your mortgaged property. If the mortgage is
foreclosed your mortgaged property will be sold by the Sheriff or
other similar official to pay off the mortgage debt. If you cure
the default before we begin legal proceedings against you, you will
still have to pay the reasonable attorney's fees actually incurred,
up to $50.00. However, if legal proceedings are started against
you, you will have to pay the reasonable attorney's fees even if
they are over $50.00. Any attorney's fees will be added to
whatever you owe the lender, which may also include our reasonable
costs. If you cure the default within the THIRTY (30) DAY period
you.will not be required to pay attorney's fees.
The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage. `
If you have not cured the default within the THIRTY (30) DAY period
and foreclosure proceedings have begun, you still have the right to
cure the default and prevent the sale at any time up to one hour
before the Sheriff's or other similar official foreclosure sale.
You may do so by paying the total amount of the unpaid monthly
payments plus any late or other charges then due, as well as the
reasonable attorney's fees and costs connected with the foreclosure
sale and perform any other requirements under the mortgage. It is
estimated that the earliest date that such a Sheriff's or other
similar official's sale could be held would be approximately six
months from the date of this letter. A notice of the date of the
Sheriff's or similar official sale will be sent to you before the
sale. Of course, the amount needed to cure the default will
increase the longer you wait. You may find out at any time exactly
what the required payment will be by calling us at the following
number: (856) 669-5400. This payment must be cash, cashier's
check, certified check or money order and made payable to us at the
address stated above.
You should realize that a Sheriff's or other similar official sale
will end your ownership of the mortgaged property and your right to
remain in it. If you continue to live in the property after the
Sheriff's or other similar official sale, a lawsuit could be
started to evict you.
You shall have the right to assert in the foreclosure proceedings,
the non-existence of a default or any other defense that you may
have to acceleration or foreclosure.
You have additional rights to help protect your interest in the
property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY
TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER
LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT
TO SELL OR. TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER
OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL
THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE
PAID PRIOR. TO OR AT THE SALE, AND THAT THE OTHER REQUIREMENTS UNDER
THE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINE UNDER WHAT
CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE
THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
if you cure the default, the mortgage will be restored to the same
position as if no default had occurred. However, you are not
entitled to this right to cure your default more than three times
in any calendar year.
UDREN LAW OFFICES, P.C.
CC: First Class Mail
NOTICE
The amount of your debt is as stated in the attached document. The name of the creditor to
whom the debt is owed is as named in the attached document. Unless you notify us within 30
days after receipt of this Notice and the attached document that the validity of the stated debt,
or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in
writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy
of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an
admission of liability on your part. Also, upon your written request within the 30 day period,
we will provide you with the name and address of the original creditor if different from the
current creditor.
If you notify us in writing within the 30 day period as stated above, we will cease collection
of your debt, or any disputed portion of it, until we obtain the information that is required
and mail it to you. Once we have mailed to you the required information, we will then
continue the collection of your debt.
This law firm is deemed to be a debt collector and this Notice and the attached document is
an attempt to collect a debt, and any information obtained will be used for that purpose.
UDREN LAW OFFICES, P.C.
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
(856) 669-5400
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FORM 1
101-a<gs- Gimwlh
f?C P IN THE COURT OF COMMON PLEAS OF .
CUMBERLAND COUNTY. PENNSl'LVAN
m (y Q?
am A(s) fQj( 7, C/ sync/ Wit'
yvs.
Defendant(s) Civil r_.
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action, you may
be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your
lender.
If you do not have a lawyer, you must take the following steps to be eligible for a conciliation
conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal
Services at (717) 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a
legal representative at no charge to you. Once you have been appointed a legal representative, You must
promptly meet with that legal representative within twenty (20) days of the appointment date. During that
meeting, you must provide the legal representative with all requested financial information so that a loan
resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial
worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation
Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of
the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an
opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements
with your lender before the mortgage foreclosure suit proceeds forward.
If you are represented by a lawyer, you and your lawyer must take the following steps to be
eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the
appointment of a legal representative. However, you must provide your lawyer with all requested financial
information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete
a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation
Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of
the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an
opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements
with your lender before the mortgage foreclosure suit proceeds forward.
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE
STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Date
Res ect Ilv submitted:
[Signature of C?ouns6l for Plaintiff]
PAIGE M. BELLINO, ESQUiRL
FA 10 309091
FORM 2
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Pleas Docket #
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance, your lender must consider your
circumstances to determine possible options while working with your
Please provide the following information to the best of your knowledge:
Borrower name(s):
Property .Address:
City:
Is the property for sale?
Realtor Name:
Borrower Occupied?
Mailing Address (if different)
City:
Phone Numbers
Email:
# of people in household:
Mailing Address:
City:
Phone Numbers:
Office:
Other:
Email:
of people in household: How, long?
First Mortgage Lender:
Type of Loan:
Loan Number: Date You Closed Your Loan:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mort gage Payments Amount: $ Included Taxes & Insurance:
Date of Last Payment:
Prim Reason for Default:
State: Zip:
Yes ? No E] Listing date: Price: $_
Realtor Phone:_
Yes ? No ?
Home:
Cell:
State: Zip:
Office:
Other:
How long?
State: Zip:
Home:
Cell:
Is the loan in Bankruptcy? Yes ? No ?
If yes, provide names, location of court case number & attorney:
Assets Amount Owed: Value:
Home: $ $
Other Real Estate: $ $
Retirement Funds: $ $
Investments: $ $_
Checking: $ $_
Savings: $ $
Other: $ $
Automobile #1: Model: Year:
Amount owed: Value:
Automobile 92: Model: Year:
Amount owed: Value:
Other transportation (automobiles boats, motorcycles): Model:
Year: Amount owed-.Value
Monthly Income
Name of Employers:
1.
Additional Income Description (not wages):
I , monthly amount:
2 monthly amount:
Borrower Pay Days: _ Co-Borrower Pay Days:
Monthly Expenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mortgage Food
2" Mortgage Utilities
Car Payment(s) Cundo/Nei h. Fees
Auto Insurance Med. (not covered)
Auto ftiel/re airs Other prop. payment
Install. Loan Payment Cable TV
Child Su ort'Alim. Spending Money
Da /Child Care/Tuit. Other Expenses I
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes ? No ?
If yes, please provide the following information:
Counseling Agency:
Counselor:
Phone (Office): Fax:_
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program
(HEMAP) assistance?
Yes ? No ?
If yes, please indicate the status of the application:
Have you had any prior negotiations with Your lender or lender's loan servicing company
to resolve your delinquency?
Yes ? No ?
If yes. please indicate the status of those negotiations:
Please provide the following information, if know, regarding your lender or lender's loan
servicing company:
Lender's Contact (Name):
Servicing Company (Name):
Contact:
Phone:
Phone:
I/We authorize the above
named _ to use/refer this information to my lender/servicer for the sole
purpose of evaluating my financial situation for possible mortgage options. I,'We
understand that I/we am/are under no obligation to use the services provided by the above
named
Borrower Signature
Co-Borrower Signature
Date
Date
Please forward this document along with the following information to lender and
lender's counsel:
Proof of income
V(( Past 2 bank statements
V Proof of any expected income for the last 45 days
V Copy of a current utility bill
Letter explaining reason for delinquency and any supporting documentation
t (hardship letter)
V Listing agreement (if property is currently on the market)
FORM 3
D c rS Cke B4n Lr7
I/V'O?'r? r ?yi q t TAu?f
( c/41 f a/J
Plaintiff(s)
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COLTNTY.. PENNSYLVANIA
vs.
R JA ?Lk4r'1 ??4Is'164U.?'h _. ?-e t a f
Defendant(s)
Civil"
REQUEST FOR CONCILIATION CONFERENCE
Pursuant to the Administrative Order dated C6 , 2012 governing the Cumberland
Countv Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies
as follows:
1. Defendant is the owner of the real property which is the subject of this mortgage
foreclosure action;
Defendant lives in the subject real property, which is defendant's primary
residence;
3. Defendant has been served with a `'Notice of Residential Mortgage Foreclosure
Diversion Program" and has taken all of the steps required in that Notice to be
eligible to participate in a court-supervised conciliation conference.
The undersigned verifies that the statements made herein are true and correct. I
understand that false statements are made subject to the penalties of 18 Pa. C.S, X4904 relating to
unsworn falsification to authorities.
Signature of Defendant's Counsel/Appointed
Legal Representative
Signature of Defendant
Date
Date
Signature of Defendant Date
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
BY: MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675
PAIGE M. BELLING, ESQUIRE - ID#309091
HARRY B. REESE, ESQUIRE - ID#310501
AMY GLASS, ESQUIRE - ID#308367
KASSIA FIALKOFF, ESQUIRE - ID#310530
ELIZABETH L. WASSALL, ESQUIRE - ID#77788
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400 leadins(amdren.com
•^?_.
n
C. x'
Deutsche Bank National Trust Company, as Trustee for COURT OF COMMON
GSAMP Trust 2005-WMC1, Pooling and Servicing PLEAS
Agreement dated as of September 1, 2005 CIVIL DIVISION
1661 Worthington Road #100, West Palm Beach, FL 33409 CUMBERLAND County
Plaintiff
v.
KRISTINA STAMBAUGH A/K/A KRISTINA M. STAMBAUGH NO. /oZ - oV 45 01V;1TV_*fi1
141 EAST MAIN STREET
WALNUT BOTTOM, PA 17266
RICHARD STAMBAUGH A/K/A RICHARD A. STAMBAUGH
141 EAST MAIN STREET
WALNUT BOTTOM, PA 17266
Defendant(s)
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter the appearance of the following counsel: Mark J. Udren, Esquire;
Stuart Winneg, Esquire; Lorraine Doyle, Esquire; Alan M. Minato, Esquire, Sherri J.
Braunstein, Esquire; Paige M. Bellino, Esquire; Harry B. Reese, Esquire; Amy Glass,
Esquire; Kassia Fialkoff, Esquire; Elizabeth L. Wassall, Esquire; on behalf of the
Plaintiff, in the above-captioned matter.
UDR AW OFFICES, P.C.
BY: (k,(0`, ij1
M. BELLINO, ESQUIRE
PA TO 309091
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson F- Sheriff , D
- r_
Jody S Smith 4E PPOTHONOTAt"' '% '
Chief Deputy 12 APR 20 AN 8: 44
Richard W Stewart
Solicitor CUM NLAND COUN i"
I'+ SYLVANIA
Deutsche Bank National Trust Company
vs. Case Number
Kristina M. Stambaugh (et al.) 2012-2145
SHERIFF'S RETURN OF SERVICE
04/13/2012 05:19 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on April
13, 2012 at 1719 hours, he served a true copy of the within Complaint and Mortgage Foreclosure, upon
the within named defendant, to wit: Krisitina M. Stambaugh, by making known unto herself personally, at
141 E. Main Street, Walnut Bottom, Cumberland County, Pennsylvania 17266 its contents and at the
same time handing to her personally the said true and correct copy of the me.
-n
A TSHALL, PUTY
04/16/2012 05:21 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on April 16,
2012 at 1721 hours, he served a true copy of the within Complaint and Mortgage Foreclosure, upon the
within named defendant, to wit: Richard A. Stambaugh, by making known unto himself personally, at 141
E. Main Street, Walnut Bottom, Cumberland County, Pennsylvania 17266 its contents and at the same
time handing to him personally the said true and correct copy of the same.
RYAN BURGETT, DE Y
SHERIFF COST: $58.00
April 18, 2012
SO ANSWERS,
'22
RON R ANDERSON, SHERIFF
UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
111 WOODCRESTT' ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadi @udren.com
Deutsche Bank National Trust Company, as Trustee for
GSAMP Trust 2005-WMC1, Pooling and Servicing
Agreement dated as of September 1, 2005
1661 Worthington Road #100
West Palm Beach; FL 33409
Plaintiff
V.
KRISTINA STAMBAUGH A/K/A KRISTINA M.
STAMBAUGH
141 EAST MAIN' STREET
WALNUT BOTTOM, PA 17266
RICHARD STAMBAUGH A/K/A RICHARD A.
STAMBAUGH
141 EAST MAIN' STREET
WALNUT BOTTOM, PA 17266
Defendant(s)
ATTORNEY FOR PLAINTIFF
. .. ?p? . I i + C_
10:
COURT OF COMM6j4, ?
CIVIL DIVISION ,i
Cumberland County
MORTGAGE FORECLOSURE
NO. 12-2145-Civil
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against the Defendant(s), KRISTINA STAMBAUGH A/K/A
KRISTINA M. STAMBAUGH; RICHARD STAMBAUGH A/K/A RICHARD A. STAMBAUGH; for failure to file
an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged
premises, and assessPlaintiffs damages as follows:
Unpaid Principal Balance
Interest Per Complaint
Additional Interest
Late Charges Per Complaint
Additional Late Charges
Escrow Per Complaint
Title Report
Attorney Fee
Other Suspense Balance
Prior Servicer Fee
Property Inspection Fee
Property Valuation Fee
Grand Total
FROM TO
$109,068.19
$10,705.15
03/02/2012 05/25/2012 $1,762.90
$1,543.60
03/02/2012 05/25/2012 $115.77
$11,218.35
$300.00
$1,300.00
$-590.53
$829.80
$31.50
$292.00
$136,576.73
0"k*16.SOP4 '11?
O?1W as -)ss
'P,H a-7s9/-?
I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been
given in accordance with Rule 237.1, a copy of which is attached hereto.
UD LAW OFFICES, P. q.
B
Atto ey or a' tiff
rri I Braunstein, Esquire
INP?
DAMAGES ARE HEREBY ASSESSED AS INDICATED 9
DATE: PRO
MJU#: 11100710 CAiSE#: 11100710-1 Transfer
COPY
UDREN' LAW OFFICES, P.C.
BY; MARIA J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINiE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
SHERRI XF,BRAUNSTEIN, ESQUIRE - ID #90675
PAIGE M. BELLINO, ESQUIRE - 11)#309091
HARRY B. REESE, ESQUIRE - ID#310501
AMY GLASS, ESQUIRE - ID#308367
KASSIA FIALKOFF, ESQUIRE - ID#310530
ELIZABETH L. WASSALL, ESQUIRE - ID#77788
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 0800-1-3620
ATTORNEY FOR PLAINTIFF
- :to '
..
?
_. ? y -
Grr
Deutsche Bank National Trust Company, as Trustee for GSAMP
Trust 2005-WMCI, Pooling and Servicing Agreement dated as of
September 1, 2005
CIO OcVven Loan Servicing, LLC
1661 Worthington Road #100
West Palm Beach, FL 33409
Plaintiff
KRISTINA STAMBAUGH A/K/A I.'I.t1STINA M. STAMBAUGH
141 EAST MAIN STREET
WALNUT BOTTOM, PA 17266
RICHARD STAMBAUGH A/KJA RICHARD A. STAMBAUGH
141 EAST MAIN STREET
WALNUT BOTTOM, PA 17266
Defendant(s)
COURT OF
COMMON PLEAS
CIVIL DIVISION
CUMBERLAND
County
NO. /o`?- 021 ?{5J v i V t
COMPLAINT INMORTGAGE FORECLOSURE
YOU HAVE BEEN SUED IN COURT. within you wish t'defendaga thhe claims set fart Notice
following pages, you must take action within twenty (_0) y'
are served, by entering a written appearance personally or by attorney and filing in writing with
the Count your defenses or objections to the claims set forth against you. You are warned. that if
you fail to do so the case may proceed without you and. a judgment may be entered against you
'rV
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff??xyttr at. L;c,t?lirrt?lD
Jody S Smith
'z
Chief Deputy
Richard W Stewart
Solicitor ksl'F C OF SHE EPiFF
Deutsche Bank National Trust Company Case Number
vs. 2012-2145
Kristina M. Stambaugh (et al.)
SHERIFF'S RETURN OF SERVICE
04/1312012 05:19 PM' - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on April
13, 2012 at 1719 hours, he served a true copy of the within Complaint and Mortgage Foreclosure, upon
the within] named defendant, to wit: Krisitina M. Stambaugh, by making known unto herself personally, at
141 E. Main Street, Walnut Bottom, Cumberland County, Pennsylvania 17266 its contents and at the
same time handing to her personally the said true and correct copy of the me.
14 -40
A TSHALL, PUTY
04/16/2012 05:21 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on April 16,
2012 at 11721 hours, he served a true copy of the within Complaint and Mortgage Foreclosure, upon the
within named defendant, to wit: Richard A. Stambaugh, by making known unto himself personally, at 141
E. Main Street, Walnut Bottom, Cumberland County, Pennsylvania 17266 its contents and at the same
time handing to him personally the said true and correct copy of the same.
RYAN BURGETT, DE Y
SHERIFF COST: $58.00 SO ANSWERS,
April 18, 2012 RON R ANDERSON, SHERIFF
,C) cumtySuite Snen't.. Ieiposrit. mr.
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCRIk ST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400____.____
.--
Deutsche Bank National Trust Company, COURT OF COMMON PLEAS
as Trustee for IGSAMP Trust 2005-WMC1, CIVIL DIVISION
Pooling and Servicing Agreement dated as Cumberland County
of September 1, 2005
Plaintiff MORTGAGE FORECLOSURE
V.
KRISTINA STAMBAUGH A/K/A NO. 12-2145-Civil
KRISTINA M. STAMBAUGH, RICHARD
STAMBAUG A/K/A RICHARD A.
STAMBAUGH
Defemdant(s)
TO: EMSTIfNA STAMBAUGH A/KA KRISTINA M. STAMBAUGH
141 EAST MAIN STREET
WALNUT BOTTOM, PA 17266
Date of Notice: May 8, 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 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.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(800) 990-9108
NOTIFICACION IMPORTANTE
LISTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION
REQUIRIDA',DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO
DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN
NECESIDAI3' DE COMPARARECER LISTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA,
DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS
DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO
IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE
PARA TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA
DIRECCION SE, ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE
CONSEGUIR AgSISTENCIA LEGAL.
SERVICIO DE REFERENCIA LEGAL
Cumberland County Bar Association
2 Libertv Avenue
Carlisle, PA 17013
(800) 990-9108
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW
FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
U N LAW O FICES, PC.
BY
Attorney forPlaintiff
Sherri 1. Braunstein, Esquire
PA ID 90675
Wooderest Corporate Center
111 Wooderest Road, Suite 200
Cherry Hill, New Jersey 08003-3620
MJU#: 1110071 10 CASE#: 11100710-1 Transfer
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST (CORPORATE CENTER
111 WOODCOST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
Deutsche Bank National Trust Company, COURT OF COMMON PLEAS
as Trustee for IGSAMP Trust 2005-WMC1, % CIVIL DIVISION
Pooling and SOrvicing Agreement dated as Cumberland County
of September 1, 2005
Plaintiff MORTGAGE FORECLOSURE
KRISTINA STAMBAUGH A/K/A NO. 12-2145-Civil
IMSTINA M} STAMBAUGH, RICHARD
STAMBAUGH AWA RICHARD A.
STAMBAUGH
Defendant(s)
TO: RICHARD STAMBAUGH A/K/A RICHARD A. STAMBAUGH
141 EAST MAIN STREET
WALNUT BOTTOM, PA 17266
Date of Notice: May 8, 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 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.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(800) 990-9108
NOTIFICACION IMPORTANTE
USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION
REQUIRIDA OE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO
DE UN TERMIINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN
NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA,
DICTAR SENTINCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS
DERECHOS, IIv)PORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO
IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE
PARA TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA
DIRECCION SE' ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE
CONSEGUIR ASSISTENCIA LEGAL.
SERVICIO DE REFERENCIA LEGAL
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(800) 990-9108
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW
FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
ZZ;L .
B Y:
Attorney for Plaintiff
Sherri I Braunstein, Esquire
PA ID 90675
Wooderest Corporate Center
I I I Woodcrest Road, Suite 200
Cherry Hill, New Jersey 08003-3620
MJU#: 11.100710 CASE#: 11100710-1 Transfer
UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings a@uOren.com
Deutsche B nk National Trust Company, as
Trustee for GSAMP Trust 2005-WMC1,
Pooling and lServicing Agreement dated as of
September 1, 2005
Plaintiff
V.
Kristina Stambaugh A/k/a Kristina M.
Stambaugh
Richard Stambaugh A/k/a Richard A.
Stambaugh
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
NO. 12-2145-Civil
i
AFFIDAVIT OF NON-MILITARY SERVICE
UNDER Pa.R.C.P 76
THEUNDERSIGNED states based upon a search of the Department of Defense Manpower Data
Center for the Defendant(s), that the Defendant(s), KRISTINA STAMBAUGH A/K/A KRISTINA M.
STAMBAUGH9 RICHARD STAMBAUGH A/K/A RICHARD A. STAMBAUGH, who/each of
whom is over 18 years of age is/are not in active military service as defined in the Servicemembers' Civil
Relief Act. 'the Military Status Report(s) is/are attached hereto as Exhibit "A".
The Affiant lacks sufficient information to be able to determine whether any other Defendants in
this action are in active military service because Plaintiff cannot provide date(s) of birth and/or Social
Security number(s) for said Defendant(s) to enable a search.
This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn
falsification to authorities.
Attorney for Pl 'ntiff
Sherri J. Braunstein, Esquire
PA ID 90675
MJU#: 11100710 CASE#: 11100710-1 Transfer
Results as of : May-29-2012 12:28:09
Department of Defense Manpower Data Center SCRA2.2
Sjta s Report
nirsuant to Service-members Civil. Relief Act
Last Name: STAMBAUGH First Name: KRISTINA
Active Duty Status As Of: May-29-2012
Active Duty End Date I Status I Service Component
Acura Duty Start at@
j on Active Duty on Active Duty Status Date
NA No NA
NA
This response reflects the individuals' active duty status based on the Active Duty Status Date
Left Active Duty Within 367 Days of Active Duty Status Date
Active Duty End Date Status Service Component
Active Duty Start ate
NA No NA
NA
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or HWKer Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date
Order Notification End Data Status Service Component
Order Notificaton Start l Date
NA No NA
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, NOAA, 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.
Y)Iia
Mary M. Snavely-DixonF 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 et 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: http://www.defenselink.mil/faq/pis/PC09SLDR.html. 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 leftActive
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" Prior to 2010 only some of the active duty periods less
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Y
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 (IRPAs). 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: GM43LDA09
Results as of : May-29-2012 12:28:49
Department of Defense Manpower Data Center SCRA 2.2
S?atus Report
want to Semicemembers Civil Relief Act
Last Name: STAM!BAUGH First Name: RICHARD
Active Duty Status As Of: May-29-2012
Active Duty End Date Status Service Component
Active Duty Start ate
On Active Duty On Active Duty Status Date
NA No NA
NA
This response reflects the individuals' active duty status based on the Active Duty Status Date
Left Active Duty Within 367 Days of Active Duty Status Date
Status Service Component
Active Duty StartDate Active Duty End Date
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 Flis/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date
Status Service Component
order Notification Slarl Date order Notification End Date
NA No NA
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, NOAA, 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.
0
rte, FRI.
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22850
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 et 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 (kPAS). 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 on erroneous certificate to be provided.
Report ID: C36N2EPB35
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 12-2145 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR GSAMP TRUST 2005-WMCI, POOLING AND SERVICING AGREEMENT
DATED AS OF SEPTEMBER 1, 2005. Plaintiff (s)
From KRISTINA STAMBAUGH A/K/A KRISTINA M_STAMBAUGH, RICHARD
STAMBAUGH A/K/A RICHARD A. STAMBAUGH
(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: $136,576.73 L.L.: $.50
Interest FROM 5/26/2012 TO DATE OF SALE- SEPT. 5, 2012 - ONGOING PER DIEM OF $20.74
TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD A LATER DATE - $2,136.22
Atty's Comm: '% Due Prothy: $2.25
Atty Paid: $209.25
Other Costs:
Plaintiff Paid:
Date: 5/30/12
David D. Buell, Prothonotary
(Seal) --?.QP? ??a1L
Deputy
REQUESTING PARTY:
Name: SHERRI J. BRAUNSTEIN, ESQUIRE
Address: UDREN LAW OFFICES, P.C.
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
Attorney for: PLAINTIFF
Telephone: 856-669-5400
UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings(a),udren.com
Deutsche Bank National Trust Company,
as Trustee for GSAMP Trust 2005-WMC1,
Pooling and Servicing Agreement dated as
of September 1, 2005
Plaintiff
V.
Kristina Stambaugh A/k/a Kristina M.
Stambaugh
Richard Stambaugh A/k/a Richard A.
Stambaugh
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE '
r
x,
NO. 12-2145-Civil
c~}
-
7,
S
PRAECIPE TO ISSUE WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount due $ 136,576.73
Interest From 5/26/2012 $ 2,136.22
to Date of Sale September 5, 2012
Ongoing Per Diem of $20.74
to actual date of sale including if sale is
held at a later date
(Costs to be added) $
Cl'
d2.--?s ?l I I
Spu,u?,
t?
UDRE LAW OFFICES, P.C.
1 Y :-
BY:
Attorney or Plainti
Sherri J. Braunstein, Esquire
PA ID 90675
MJU#: 11100710 CASE#: 11100710-1 Transfer
? X915
J?? ? 4 ?? 75-s',r-l
UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
?leadi?s udren.com_ _
Deutsche Bank National Trust Company,
as Trustee for GSAMP Trust 2005-WMC1,
Pooling and Servicing Agreement dated as
of September 1, 2005
Plaintiff
V.
Kristina Stambaugh A/k/a
Kristina M. Stambaugh
Richard Stambaugh A/k/a
Richard A. Stambaugh
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
NO. 12-2145-Civil
CERTIFICATE OF ACT 91
r, .
I hereby state that as the attorney for the Plaintiff in the above-captioned matter:
n Act 91 procedures have been fulfilled
F1 Premises is not subject to the provisions of Act 91
This statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to
unsworn falsification to authorities.
UDRE LAW OFFICES, P.C.
BY-
Attorney for Plaintiff
Sherri J. Braunstein, EsquirE
PA ID 90675
UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings(a-udren.com
Deutsche Bank National Trust Company,
as Trustee for GSAMP Trust 2005-WMC1,
Pooling and Servicing Agreement dated as
of September 1, 2005
Plaintiff
V.
Kristina Stambaugh A/k/a
Kristina M. Stambaugh
Richard Stambaugh A/k/a
Richard A. Stambaugh
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
j CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
NO. 12-2145-Civil
AFFIDAVIT PURSUANT TO RULE 3129.1
AND RULE 76
r-;
Deutsche Bank National Trust Company, as Trustee for GSAMP Trust 2005-WMC1, Pooling and
Servicing Agreement dated as of September 1, 2005, Plaintiff in the above action, by its undersigned
attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the
Writ of Execution was filed, the following information concerning the real property located at:
141 East Main Street, Walnut Bottom, PA 17266
1. Name and address of Owner(s) or reputed Owner(s):
Kristina Stambaugh A/k/a Kristina M. Stambaugh
141 East Main Street
Walnut Bottom, PA 17266
Richard Stambaugh A/k/a Richard A. Stambaugh
141 East Main Street
Walnut Bottom, PA 17266
2. Name and address of Defendant(s) in the judgment:
Kristina Stambaugh A/k/a Kristina M. Stambaugh
141 East Main Street
Walnut Bottom, PA 17266
Richard Stambaugh A/k/a Richard A. Stambaugh
141 East Main Street
Walnut Bottom, PA 17266
3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold:
Jr Lien Holders - None
4. Name and address of the last recorded holder of every mortgage of record:
Deutsche Bank National Trust Company, as Trustee for GSAMP Trust 2005-WMC1, Pooling and
Servicing Agreement dated as of September 1, 2005
1661 Worthington Road #100
West Palm Beach, FL 33409
Sr Mortgage Holders - None
MERS, Inc. as nominee for WMC Mortgage Corp., a Corporation
PO Box 2026
Flint, MI 48501-2026
5. Name and address of every other person who has any record lien on the property:
Sr lien Holders - None
6. Name and address of every other person who has any record interest in the property and whose interest may
be affected by the sale:
Cumberland County Domestic Relations Section
13 North Hanover Street
Carlisle, PA 17013
Cumberland County Real Estate Tax Department
1 Courthouse Square
Carlisle, PA 17013
Commonwealth of PA, Department of Revenue
Bureau of Compliance
PO Box 281230
Harrisburg, PA 17128-1230
Tenants/Occupants
141 East Main Street
Walnut Bottom, PA 17266
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:
Federal Tax Lien Holders - None
Condo/Homeowners Association - None
I verify that the statements made in this affidavit are true and correct to the best of my information and
belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904
relating to unsworn falsification to authorities.
DATED
UDR LAW OFFICES, P.C.
BY -
Attorney for Plain i
Sherri 1. Braunstein, Esquire
MJU#: 11100710 CASE#: 11100710-1 Transfer PA ID 90675
i
R`{~? raTTORNEY FOR PLAINTIFF
UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTI? ?pf,., E
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620 `" E j; t f %' U CHI'! 856-669-5400 rm it S Y (.v `i 1 A
PleadinsisAudren.com
Deutsche Bank National Trust Company, COURT OF COMMON PLEAS
as Trustee for GSAMP Trust 2005-WMC1, CIVIL DIVISION
Pooling and Servicing Agreement dated as Cumberland County
of September 1, 2005
Plaintiff MORTGAGE FORECLOSURE
V.
KRISTINA STAMBAUGH AWA NO. 12-2145-Civil
KRISTINA M. STAMBAUGH, RICHARD
STAMBAUGH A/K/A RICHARD A.
STAMBAUGH
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Kristina Stambaugh A/k/a Kristina M. Stambaugh
141 East Main Street
Walnut Bottom, PA 17266
Your house (real estate) at 141 East Main Street, Walnut Bottom, PA 17266 is scheduled to be
sold at the Sheriffs Sale on September 5, 2012 at 10:00am at the Cumberland County
Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the
court judgment of $136.576.73, obtained by Plaintiff above (the mortgagee) against you. If the
sale is postponed, the property will be relisted for the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable
attorney's fees. To find out how much you must pay, you may call: (856) 669-5400.
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.
You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you will
have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid by calling 856-669-5400.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call 856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule
will state who will be receiving that money. The money will be paid out in accordance with this schedule unless
exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after
Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(800) 990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(800) 990-9108
Deutsche Bank National Trust Company : IN THE COURT OF COMMON PLEAS
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
V.
Kristina Stambaugh and : Docket No. 2012-2145
Richard Stambaugh,
Defendants : CIVIL ACTION- MORTGAGE FORECLOSURE
PRAECIPE FOR ENTRY OF APPEARANCE rrr
^:
TO THE PROTHONOTARY:
- C7 ED _} .
Please enter the appearance of MidPenn Legal Services on behalf of the Defendants,
Kristina Stambaugh and Richard Stambaugh, in the above matter, representing the Defendants in
the Cumberland County Residential Mortgage Foreclosure Diversion Program.
Respectfully Submitted,
MIDPENN LEGAL SERVICES
DATE: June 6, 2012
Amy is, Esquire
Atto e for Defendant
Supr e Ct. ID # 310094
401 E. Louther Street, Ste 103
Carlisle, PA 17013
(717)243-9400
4
Deutsche Bank National Trust Company
Plaintiff,
V.
Kristina Stambaugh and
Richard Stambaugh,
Defendants
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: Docket No. 2012-2145
: CIVIL ACTION- MORTGAGE FORECLOSURE
CASE MANAGEMENT ORDER
AND NOW, this //4day of ?_r4. , 2012, the defendant/borrower in the above-
captioned residential mortgage foreclosure action having filed a Request for Conciliation
Conference verifying that the defendant/borrower has complied with the Administrative Rule
requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND
DECREED that:
1. The parties and their counsel are directed to participate in a court-supervised
Q. rye
conciliation Conference on ?a7 901a at //. in
at the Cumberland County Courthouse, Carlisle,
Pennsylvania.
2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the
defendant/borrower must serve upon the Plaintiff/lender and its counsel a copy of the
"Cumberland County Residential Mortgage Foreclosure Diversion Program Financial
Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon
agreement of the parties in writing or at the discretion of the Court, the Conciliation
Conference ordered may be rescheduled to a later date and/or the date upon which
service of the completed Form 2 is to be made and may be extended. Upon notice to
the Court of the defendant/borrower's failure to serve the completed Form 2 with the
time frame set forth herein or such other date as agreed upon by the parties in writing
or ordered by the Court, the case shall be removed from the Conciliation Conference
schedule and the temporary stay of proceedings shall be terminated.
3. The defendant/borrower and counsel for the parties must attend the Conciliation
Conference in person and an authorized representative of the plaintiff/lender must
either attend the Conciliation Conference in person or be available by telephone
during the course of the Conciliation Conference. The representative of the
plaintiff/lender must discuss resolution proposals with the authorized representative
in advance of the Conciliation Conference. If the duly authorized representative of the
plaintiff/lender is not available by telephone during the Conciliation Conference, the
court will schedule another Conciliation Conference and require the personal
attendance of the authorized representative of the plaintiff/lender at the rescheduled
Conciliation Conference.
4. At the Conciliation Conference, the parties and their counsel shall be prepared to
discuss and explore all available resolution options which shall include: bringing the
mortgage current through a reinstatement; paying off the mortgage; proposing a
forbearance agreement or repayment plan to bring the account current over time;
agreeing to tender a monetary payment and to vacate in the near future in exchange
for not contesting the matter; offering the lender a deed in lieu of foreclosure;
entering into a loan modification or reverse mortgage; paying the mortgage default
over sixty months; and the institution of bankruptcy proceedings.
5. All proceedings in this matter are stayed pending the completion of the scheduled
conciliation conference.
BY THE COURT,
S
? Amy Hirakis, Esquire
MidPenn Legal Services
401 E. Louther Street, Ste 103
Carlisle, PA 17013
Paige M. Bellino, Esquire
Udren Law Offices, P.C.
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill, NJ 08003
i ri
r-y
S' t
UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
Deutsche Bank National Trust Company,
as Trustee for GSAMP Trust 2005-WMC1,
Pooling and Servicing Agreement dated as
of September 1, 2005
Plaintiff
V.
EMSTINA STAMBAUGH A/K/A
EMSTINA M. STAMBAUGH;
RICHARD STAMBAUGH A/K/A
RICHARD A. STAMBAUGH; et al
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 12-2145-Civil
17
r
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Kindly reinstate the Complaint on the above-captioned matter.
DATE: ? 0 t v?- UDREN LAW OFFICES, P.C.
BY:
Atto r laintiff
HARRY B. REESE, ESQUIRE-
PA ID 310501
Grn?0) 5? p
Ck-y ?s ?
ID 11 1?_7
UDREN LAW OFFICES, P.C. i u ?
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200 ,.,, '' e E Q e +'
08003 3620
ATTORNEY FOR PLAINTIFF
CHERRY HILL NJ
856-669-5400 a E D COUNT,`,.
pleadings@udren.com i PEHNS LVAN
Deutsche Bank National Trust Company, as
Trustee for GSAMP Trust 2005-WMC1,
Pooling and Servicing Agreement dated as of
September 1, 2005
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 12-2145-Civil
v.
Kristina Stambaugh A/k/a Kristina M.
Stambaugh
RICHARD STAMBAUGH A/K/A RICHARD
A. STAMBAUGH
Defendant(s)
PRAECIPE TO WITHDRAW JUDGMENT
TO THE PROTHONOTARY:
Kindly withdraw the Judgment entered on 05/30/2012 upon, Kristina Stambaugh A/k/a
Kristina M. Stambaugh and RICHARD STAMBAUGH A/K/A RICHARD A. STAMBAUGH, in
the amount of $ 136,576.73
DATED: I I I ! -)-
MJU#: 11100710 CASE#: 11100710-1 Transfer
C.K-? 3A?Gob
e-11 11
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
t?
71 t"i F a
Deutsche Bank National Trust Company Case Number
vs. 2012-2145
Kristina Stambaugh (et al.)
SHERIFF'S RETURN OF SERVICE
06/15/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed",
per letter of instruction from Attorney.
SHERIFF COST: $95.07 SO ANSWERS,
June 15, 2012 RON R ANDERSON, SHERIFF
7 ??? f
to UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadinL,s(a).udren.com
Deutsche Bank National Trust Company, COURT OF COMMON PLEAS
as Trustee for GSAMP Trust 2005-WMC1, CIVIL DIVISION
Pooling and Servicing Agreement dated as Cumberland County
of September 1, 2005
Plaintiff
v.
Kristina Stambaugh A/k/a
Kristina M. Stambaugh
Richard Stambaugh A/k/a
Richard A. Stambaugh
Defendant(s)
MORTGAGE FORECLOSURE
NO. 12-2145-Civil
AFFIDAVIT PURSUANT TO RULE 3129.1
AND RULE 76
Deutsche Bank National Trust Company, as Trustee for GSAMP Trust 2005-WMC1, Pooling and
Servicing Agreement dated as of September 1, 2005, Plaintiff in the above action, by its undersigned
attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the
Writ of Execution was filed, the following information concerning the real property located at:
141 East Main Street, Walnut Bottom, PA 17266
1. Name and address of Owner(s) or reputed Owner(s):
Kristina Stambaugh A/k/a Kristina M. Stambaugh
141 East Main Street
Walnut Bottom, PA 17266
Richard Stambaugh A/k/a Richard A. Stambaugh
141 East Main Street
Walnut Bottom, PA 17266
2. Name and address of Defendant(s) in the judgment:
Kristina Stambaugh A/k/a Kristina M. Stambaugh
141 East Main Street
Walnut Bottom, PA 17266
Richard Stambaugh A/k/a Richard A. Stambaugh
141 East Main Street
Walnut Bottom, PA 17266
3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold:
Jr Lien Holders - None
0 4. Name and address of the last recorded holder of every mortgage of record:
Deutsche Bank National Trust Company, as Trustee for GSAMP Trust 2005-WMC1, Pooling and
Servicing Agreement dated as of September 1, 2005
1661 Worthington Road #100
West Palm Beach, FL 33409
Sr Mortgage Holders - None
MERS, Inc. as nominee for WMC Mortgage Corp., a Corporation
PO Box 2026
Flint, MI 48501-2026
5. Name and address of every other person who has any record lien on the property:
Sr lien Holders - None
6. Name and address of every other person who has any record interest in the property and whose interest may
be affected by the sale:
Cumberland County Domestic Relations Section
13 North Hanover Street
Carlisle, PA 17013
Cumberland County Real Estate Tax Department
1 Courthouse Square
Carlisle, PA 17013
Commonwealth of PA, Department of Revenue
Bureau of Compliance
PO Box 281230
Harrisburg, PA 17128-1230
Tenants/Occupants
141 East Main Street
Walnut Bottom, PA 17266
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:
Federal Tax Lien Holders - None
Condo/Homeowners Association - None
I
I verify that the statements made in this affidavit are true and correct to the best of my information and
belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904
relating to unsworn falsification to authorities.
DATED:
MJU#: 11100710 CASE#: 11100710-1 Transfer
UDR-V74 LAW OFFICES, P.C.
BY:
Attorney for Plain i
Sherri ). Braunstein, Esquire
PA ID 90675
_ ..-
WRIT OF EXECUTION and/or ATTACHMENT
COMMbNWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 12-2145 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR GSAMP TRUST 2005-WMC1, POOLING AND SERVICING AGREEMENT
DATED AS OF SEPTEMBER 1, 2005. Plaintiff (s)
From KRISTINA STAMBAUGH A/K/A KRISTINA M.STAMBAUGH, RICHARD
STAMBAUGH A/K/A RICHARD A. STAMBAUGH
(I) 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: $136,576.73 L.L.: $.50
Interest FROM 5/26/2012 TO DATE OF SALE- SEPT. 5, 2012 - ONGOING PER DIEM OF 520.74
TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD A LATER DATE - $2,136.22
Atty's Comm: % Due Prothy: $2.25
Atty Paid: $209.25
Other Costs:
Plaintiff Paid:
Date: 5/30/12
David D. Buell, Prothonot
(Seal) B
Deputy REQUESTING PARTY:
Name: SHERRI J. BRAUNSTEIN, ESQUIRE
Address: UDREN LAW OFFICES, P.C.
I I I WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
TRUE COPY FROM RECORD
in Testimony whereof, I here unto set my hand
and the sea of said at Carlisle, Pa.
This _-.YL. day of 20
Attorney for: PLAINTIFF
Telephone: 856-669-5400
On June 11 2012 the Sheriff levied upon the defendant's
interest in the real property situated in South Newton
Township, Cumberland County, PA, known and
numbered 141 East Main Street, Walnut Bottom, PA
17266 more fully described on Exhibit "A" filed with this
writ and by this reference incorporated herein.
Date: June 1, 2012
By:
Claudia Brewbaker, Real Estate Coordinator
1
t
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff??
Jody S Smith
Chief Deputy # tires , ` Egli'.! ( k`i
l
Richard W Stewart
Solicitor OFFICE r??,GSH,,,RIFF ?rl?l?13EiF E -WctvJ ? J•W,r?
P F N S y j?.?f:t, C,5 f
Deutsche Bank National Trust Company Case Number
vs. 2012-2145
Kristina Stambaugh (et al.)
SHERIFF'S RETURN OF SERVICE
06/18/2012 06:24 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on June
18, 2012 at 1824 hours, he served a true copy of the within Complaint in Mortgage Foreclosure and Notice
of Residential Mortgage Foreclosure Diversion Program, upon the within named defendant, to wit: Kristina
Stambaugh, by making known unto herself personally, at 141 E. Main Street, Walnut Bottom, Cumberland
County, Pennsylvania 17266 its contents and at the same time handing to her personally the said true and
correct copy of the same.
ICI EL BARRICK, DEPUTY
06/18/2012 06:24 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on June
18, 2012 at 1824 hours, he served a true copy of the within Complaint in Mortgage Foreclosure and Notice
of Residential Mortgage Foreclosure Diversion Program, upon the within named defendant, to wit: Richard
Stambaugh, by making known unto Kristina Stambaugh, Wife of Defendant at 141 E. Main Street, Walnut
Bottom, Cumberland County, Pennsylvania 17266 its contents and at the same time handing to her
personally the said true and correct copy of the same.
IC AEL BARRICK, DEPUTY
SHERIFF COST: $58.00
June 19, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
(e) GountySuite Sheriff. Teleosoft. Inr,.
Deutsche Bank National Trust Company : IN THE COURT OF COMMON PLEAS
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
v.
Kristina Stambaugh and : Docket No. 2012-2145
Richard Stambaugh,
Defendants : CIVIL ACTION- MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICE
I, Amy Hirakis, Esquire, of MidPenn Legal Services, attorney for the Defendants,
Kristina Stambaugh and Richard Stambaugh, hereby certify that I served a copy of Form 2-
Financial Worksheet on the Plaintiff, Deutsche Bank National Trust Company, through their
attorney, on the following date and in the manner indicated below:
U.S. First Class Mail Postage Pre-Paid C?
Paige M. Bellino, Esquire c P"4
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Udren Law Offices, P.C. C- -,
Woodcrest Corporate Center :41
-
ter"
111 Woodcrest Road, Suite 200 Wr
-<34'. w Qd
Cherry Hill, NJ 08003 r"
DATE: July 2, 2012 -, a
c-n
LEGA f SERVICES
/ Z/y / -,--I '? 16"
Amy H" "is, Esquire
Atto ey or Defendant
Supr m Ct. ID # 310094
401 . Louther Street, Ste 103
Carlisle, PA 17013
(717)243-9400
DEUTSCHE BANK NATIONAL IN THE COURT OF COMMON PLEAS OF
TRUST COMPANY, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
VS.
CIVIL ACTION - LAW
NO. 2012-2145 CIVIL
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KRISTINA STAMBAUGH and
RICHARD STAMBAUGH,
Defendants MORTGAGE FORECLOSURE
IN RE: CONCILIATION CONFERENCE
MEMORANDUM AND ORDER
c?
Present at a conciliation conference held this date were Nathan Wolf, Esquire,) local
counsel for the plaintiff; Nicholas Matash, Esquire, counsel for the defendants; and Richard and
Kristina Stambaugh, defendants.
It has been agreed that the Stambaughs will submit a new HAMP application through
counsel directly to'Paige Bellino, Esquire, counsel for the plaintiff, within fourteen (114) days.
Continued conciliation conference is set by order of even date herewith.
ORDER
AND NOW, this 2 7 day of July, 2012, continued conciliation conference is set in
this matter for Friday, September 14, 2012, at 11:00 a.m. in Chambers of Courtroom Number 4.
? athan Wolf, Esquire
Paige Bellino, Esquire
For the Plaintiff
Nicholas Matash, Esquire
For the Defendants
Cep: es yarx . Jed -7/a7/ /A
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BY THE COURT,
DEUTSCHE BANK NATIONAL IN THE COURT OF COMMON PLEAS OF
TRUST COMPANY, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
CIVIL ACTION - LAW
VS. NO. 2012-2145 CIVIL
KRISTINA STAMBAUGH and
RICHAR6 STAMBAUGH,
Defendants MORTGAGE FORECLOSURE
IN RE: CONCILIATION CONFERENCE
ORDER
AND NOW, this Z? *4 day of August, 2012, continued conciliation conference set in
Septembe 14, 2012, is rescheduled to Wednesday, September 12, 2012, at 11:30 a.m. in
Chambers of Courtroom Number 4.
BY THE COURT,
.// .
Kevin ess, P. J.
Esquire
/Nathan Wblf
,
V Paige Bell?no, Esquire
For the Pl4intiff ?,,r r?
ry
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ra
/Nicholas Matash, Esquire -v -'
For the D4fendants
:rlm Imo. lew? f/,?/
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson a, -._ ..
Sheriff r i-I 0-0)I'i`I
t"xt? t aaaaabr} # _" C ter ,;.
Jody S Smith +. 7w �,TE�OIC�r�r� f
Chief Deputy 1013 JUL 17 PPS : 27
Richard W Stewart
Solicitor OFFICE OF THE 814ERIIFF CUMBERL€Q COUN-
PENNSYLVA141A
Deutsche Bank National Trust Company
vs. Case Number
Kristina Stambaugh (et al.) 2012-2145
SHERIFF'S RETURN OF SERVICE
01/02/2013 01:20 PM-Deputy Amanda Cobaugh, being duly sworn according to law, states service was performed
by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the
above titled action, upon the property located at 141 East Main Street, Walnut Bottom, PA 17266,
Cumberland County.
01/02/2013 01:20 PM -Deputy Amanda Cobaugh, 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 AMBER
BAUGHMAN, DAUGHTER, who accepted as"Adult Person in Charge"for Kristina Stambaugh at 141 E.
Main Street, South Newton Township, Walnut Bottom, PA 17266, Cumberland County.
01/02/2013 01:20 PM-Deputy Amanda Cobaugh, 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 AMBER
BAUGHMAN, DAUGHTER, who accepted as"Adult Person in Charge"for Richard Stambaugh at 141 E.
Main Street, South Newton Township, Walnut Bottom, PA 17266, Cumberland County.
03/07/2013 Ronny R.Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had
been given according to law, he exposed the within described premises at public venue or outcry at the
Cumberland County
Courthouse, 1 Courthouse Square, Carlisle, Cumberlad County, on March 6,2013 at 10:00 a.m. He sold'
the same for the sum of$ 1.00 to Attorney Mark Udren, on behalf of Deutsche Bank National Trust
Company as Trustee for GSAMP Trust 2005-WMC1, being the buyer in this execution, paid to the Sheriff
the sum of$
SHERIFF COST: $1,678.22 SO ANSWERS,
July 17, 2013 RbNW R ANDERSON, SHERIFF
Qs- �rrY
d243 G
(c)C011n1ySUite Sl,oriff,Teleosvfi,Inc.
' UDREN LAW OFFICES;P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER _
111 WOODCREST ROAD; SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
pleadings udren.com
Deutsche Bank National Trust Company, COURT OF COMMON PLEAS
as Trustee for GSAMP Trust 2005-WMC1, CIVIL DIVISION
Pooling and Servicing Agreement dated as Cumberland County
of September 1,2005
Plaintiff MORTGAGE FORECLOSURE
V.
Kristina Stambaugh A/k/a
Kristina M. Stambaugh NO. 12-2145-Civil
Richard Stambaugh A/k/a
Richard A. Stambaugh
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129.1
AND RULE 76
Deutsche Bank National Trust Company, as Trustee for GSAMP Trust 2005-WMC1, Pooling and
Servicing Agreement dated as of September 1, 2005,Plaintiff in the above action,by its undersigned
attorney,upon information and belief,Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the
Writ of Execution was filed, the following information concerning the real property located at:
141 East Main Street,Walnut Bottom, PA 17266
1.Name and address of Owner(s) or reputed Owner(s):
Kristina Stambaugh A/k/a Kristina M. Stambaugh
141 East Main Street
Walnut Bottom, PA 17266
Richard Stambaugh A/k/a Richard A. Stambaugh
141 East Main Street
Walnut Bottom, PA 17266
2. Name and address of Defendant(s) in the judgment:
Kristina Stambaugh A/k/a Kristina M. Stambaugh
141 East Main Street
Walnut Bottom, PA 17266
Richard Stambaugh A/k/a Richard A. Stambaugh
141 East Main Street
Walnut Bottom, PA 17266
3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold:
Jr Lien Holders-None
4. Name and address of the,last.recorded holder of every mortgage of record:.
Deutsche Bank National Trust Company, as Trustee for GSAMP Trust 2005-WMC1, Pooling and
Servicing Agreement dated as of September 1, 2005
1661 Worthington Road, Suite 100
West Palm Beach, FL 33409
Sr Mortgage Holders -None
MERS,Inc. as nominee for WMC Mortgage Corp., a Corporation
PO Box 2026
Flint,MI 48501-2026
5. Name and address of every other person who has any record lien on the property:
Sr lien Holders -None
6. Name and address of every other person who has any record interest in the property and whose interest may
be affected by the sale:
Cumberland County Domestic Relations Section
13 North Hanover Street
Carlisle, PA 17013
Cumberland County Real Estate Tax Department
1 Courthouse Square
Carlisle, PA 17013
-Commonwealth of PA,Department of Revenue
Bureau of Compliance
PO Box 281230
Harrisburg, PA 17128-1230
Tenants/Occupants
141 East Main Street
Walnut Bottom, PA 17266
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:
Federal Tax Lien Holders -None
Condo/Homeowners Association-None
I verify that the statements made in this affidavit are true and correct to the best of my information and
belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904
relating to unsworn falsification to authorities.
DATED: I C` 5-1 Z UDREN L OFFICES, P.C.
B
Attorney for Plaintiff
SALVATORE CAROLLO, MUIKE
MJU#: 11100710 CASE#: 11100710-1 Transfer PA ID 31.30513
UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
pleadings(ti),udren.com
Deutsche Bank National Trust Company, COURT OF COMMON PLEAS
as Trustee for GSAMP Trust 2005-WMCI, CIVIL DIVISION
Pooling and Servicing Agreement dated as Cumberland County
of September 1,2005
Plaintiff MORTGAGE FORECLOSURE
v.
IMSTINA STAMBAUGH A/K/A NO. 12-2145-Civil
KRISTINA M. STAMBAUGH, RICHARD
STAMBAUGH A/K/A RICHARD A.
STAMBAUGH
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Kristina Stambaugh A/k/a Kristina M. Stambaugh
141 East Main Street
Walnut Bottom, PA 17266
Your house(real estate) at 141 East Main Street,Walnut Bottom,PA 17266 is scheduled to be
sold at the Sheriffs Sale on March 6,2012 at 10:00am at the Cumberland County
Courthouse, Commissioners Hearing Room, 2nd Floor,Carlisle, PA 17013, to enforce the
court judgment of$139,468.77, obtained by Plaintiff above(the mortgagee) against you. If the
sale is postponed, the property will be relisted for the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale,you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment,late charges,costs and reasonable
attorney's fees. To fmd out how much you must pay,you may call: (856)669-5400.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,if the
judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The,sooner you contact one,the more chance you will
have of stopping the sale. (See notice on page two on how to obtain an attorney:)
r 4
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find
out the price bid by calling 856-669-5400.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened,you may call 856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the
property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale.This schedule
will state who will be receiving that money. The money will be paid out in accordance with this schedule unless .
exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after
Schedule of Distribution is filed.
7. You may also have other rights and defenses,or ways of getting your home back,if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW,TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle,PA 17413
(800)990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle,PA 17013
(800)990-9108
UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
leadin s udren.com
Deutsche Bank National Trust Company, COURT OF COMMON PLEAS
as Trustee for GSAMP Trust 2005-WMC1, CIVIL DIVISION
Pooling and Servicing Agreement dated as Cumberland County
of September 1,2005
Plaintiff MORTGAGE FORECLOSURE
V.
EMSTINA STAMBAUGH A/K/A NO. 12-2145-Civil
KRISTINA M. STAMBAUGH,RICHARD
STAMBAUGH A/K/A RICHARD A.
STAMBAUGH
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO:' Richard Stambaugh A/k/a Richard A. Stambaugh
141 East Main Street
Walnut Bottom, PA 17266
Your house (real estate) at 141 East Main Street,Walnut Bottom, PA 17266 is scheduled to be
sold at the Sheriff s Sale on March 6,2012 at 10:00am at the Cumberland County
Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle,PA 17013,to enforce the
court judgment of$139,468.77, obtained by Plaintiff above (the mortgagee) against you. If the
sale is postponed, the property will be relisted for the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale,you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment,late charges,costs and reasonable
attorney's fees. To find out how much you must pay,you may call: (856)669-5400.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,if the
judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings..
You may need an attorney to assert your rights. The sooner you contact one,the more chance you will
have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find
out the price bid by calling 856-669-5400.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened,you may call 856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the
property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale.This schedule
will state who will be receiving that money. The money will be paid out in accordance with this schedule unless
exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after
Schedule of Distribution is filed.
7. You may also have other rights and defenses,or ways of getting your home back,if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle,PA 17013
(800)990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle,PA 17013
(800)990-9108
ALL THE F4LLQWING-DESCRIBED REAL ESTATE LYING AND BEING SITUTAE IN THE VILLAGE
OF WALNUT BOTTOM, SOUTH NEWTOWN TOWNSHIP, CUMBERLAND COUNTY,
PENNSYLVANIA,MORE PARTICULARLY DESCRIBED AS FOLLOWS:
BEING AT A SET RAILROAD SPIKE IN THE CENTERLINE OF PA TRAFFIC ROUTE 174(WALNUT
BOTTOM ROAD) AT COMMON CORNER OF LOTS 1 AND 2 ON THE HEREIN REFERRED TO
SUBDIVISION PLAN; THENCE ALONG COMMON BOUNDARY LINE OF LOTS 1 AND 2, WHICH IS
ALSO THE EASTERLY MOST BOUNDARY OF PARCEL 1A, SOUTH THIRTY-SEVEN (37) DEGREES
TWENTY-FOUR(24)MINUTES FIFTY-FIVE (55) SECONDS EAST,NINETY-SIX AND FIFTY-SEVEN
HUNDREDTHS (96.57) FEET TO A SET IRON PIN; THENCE CONTINUING BY SAME, SOUTH
FORTY-FIVE (45) DEGREES FORTY-NINE(49) MINUTES TWENTY-FIVE(25) SECONDS EAST, ONE
HUNDRED EIGHTEEN AND THIRTY HUNDREDTHS (118.30) FEET TO A SET IRON PIN IN LINE OF
LAND NOW OR FORMERLY OF RONALD A. BAKER; THENCE ALONG LINE OF LAND NOW OR
FORMERLY OF RONALD A. BAKER, SOUTH FORTY-NINE (49) DEGREES ZERO (00) MINUTES
ZERO (00) SECONDS WEST,THIRTY-NINE AND THIRTY-TWO HUNDREDTHS (39.32) FEET TO A
POINT; THENCE CONTINUING BY THE SAME, SOUTH FORTY-NINE (49) DEGREES ZERO (00)
MINUTES (00) SECONDS WEST, FIFTY AND ZERO HUNDREDTHS (50.00)FEET TO A POINT AT
CORNER OF LAND NOW OR FORMERLY OF RANDY K. BOYER; THENCE ALONG LINE OF LAND
NOW OR FORMERLY OF RANDY K. BOYER,NORTH FORTY-THREE (43) DEGREES FIFTEEN (15)
MINUTES TWO (02) SECONDS WEST, TWO HUNDRED THIRTEEN AND THIRTY-SEVEN
HUNDREDTHS (213.37) FEET TO A POINT IN THE CENTERLINE OF WALNUT BOTTOM ROAD;
THENCE ALONG THE CENTERLINE OF WALNUT BOTTOM ROAD,NORTH FORTY-SIX (46)
DEGREES FIFTY-SEVEN (57)MINUTES THIRTY-ONE (3 1) SECONDS EAST, FIFTY AND ZERO
HUNDREDTHS (50.00) FEET TO A POINT; THENCE CONTINUING BY SAME,NORTH FORTY-NINE
(49) DEGREES FIFTY-SEVEN(57)MINUTES (00) SECONDS,FORTY-THREE AND EIGHTY-THREE
HUNDREDTHS (43.83) FEET TO THE SET RAILROAD SPIKE, THE POINT AND PLACE OF
BEGINNING.
CONTAINING A TOTAL AREA OF 18,793 SQUARE FEET (0.0431 ACRES)
BEING KNOWN AND DESIGNATED AS LOT NO. 1 ON A SUBDIVISION PLAN ENTITLED"SURVEY
FOR MARY O. BOWERS"PREPARED BY STEVEN P. WOLFE,PROFESSIONAL LAND SURVEYOR,
DATED 4/11/90,WHICH SUBDIVISION PLAN HAS BEEN APPROVED BY THE APPROPRIATE
MUNICIPAL AUTHORITIES AS AND FOR A SUBDIVISION PLAN AND IS RECORDED IN THE
OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA IN
PLAN BOOK 69, PAGE 36.
BEING KNOWN AS: 141 EAST MAIN STREET,WALNUT BOTTOM,PA 17266
PROPERTY ID NO.: 41-31-2230-064
TITLE TO SAID PREMISES IS VESTED IN RICHARD A. STAMBAUGH AND KRISTINA M.
STAMBAUGH,HUSBAND AND WIFE BY DEED FROM RANDY V. SINGLETON DATED 06/30/2005
RECORDED 07/06/2005 IN DEED BOOK 269 PAGE 3862.
WRIT OF EXECUTION and/or ATTACHMENT
COM MONWVALTH OF PENNSYLVANIA) NO. 12-2145 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION–LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR GSAMP TRUST 2005-WMCI,POOLING AND SERVICING AGREEMENT
DATED AS OF SEPTEMBER 1,2005 Plaintiff(s)
From KRISTINA STAMBAUGH A/K/A KRISTINA M. STAMBAUGH,RICHARD
STAMBAUGH A/K/A RICHARD A.STAMBAUGH
(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: $139,468.77 L.L.:
Interest FROM 10/5/2012 TO DATE OF SALE MARCH 6,2013 ONGOING PER DIEM OF$20.74
TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE-$3,173.22
Atty's Comm: % Due Prothy: $2.25
Atty Paid: $426.07 Other Costs:
Plaintiff Paid:
Date: 10/9/12
David D. Buell,Prothonotary
(Seal) By:
Deputy
REQUESTING PARTY:
Name: SALVATORE CAROLLO,ESQUIRE
Address:UDREN LAW OFFICES,P.C.
WOODCREST CORPORATION CENTER, 111 WOODCREST ROAD,SUITE 200
CHERRY HILL,NJ 08003-3620
Attorney for:PLAINTIFF
Telephone: 856-669-5400
Supreme Court ID No.311050 IMUE
I COPY FROM RECORD
In Testimonj whereof,I here unto set my hand
and the seal of said Courfat Carlisle,pa.
ThlS--13—,day of--02-+--- .2019
Prothonotary
On October 26, 2012 the Sheriff levied upon the
defendant's interest in the real property situated in
South Newton Township, Cumberland County, PA,
Known and numbered as, 141 East Main Street,
Walnut Bottom, more fully described on Exhibit
"A" filed with this writ and by this reference
incorporated herein.
Date: October 26, 2012
By:
o-
Real Estate Coordinator
01 130 IIN
All
1
CUMBERLAND LAW JOURNAL
Writ No. 2012-2145 Civil (213.37)feet to a point in the center-
line of Walnut Bottom Road;thence
Deutsche Bank National along the centerline of Walnut Bot-
Trust Company tom Road, North forty-six (46) de-
ws. grees fifty-seven(57)minutes thirty-
Kristina Stambaugh one(3 1) seconds East,fifty and zero
a/k/a Kristina M. Stambaugh, hundredths (50.00) feet to a point;
Richard Stambaugh thence continuing by same, North
a/k/a Richard A. Stambaugh forty-nine(49)degrees fifty-seven(57)
At Mark Udren minutes(00)seconds,forty-three and
Atty.: eighty-three hundredths(43.83)feet
ALL the following described real to the set railroad spike, the point
estate lying and being sitiute in the and place of BEGINNING.
Village of Walnut Bottom,South New- CONTAINING a total area of
town Township,Cumberland County, 18,793 square feet (0.0431 acres).
Pennsylvania, more particularly de- being known and designated as Lot
scribed as follows: No.1 on a subdivision plan entitled
BEING at a set railroad spike in "Survey for Mary O. Bowers" pre-
the centerline of PA Traffic Route 174 pared by Steven P.Wolfe,Profession-
(Walnut Bottom Road) at common al Land Surveyor, dated 4/11190,
corner of Lots 1 and 2 on the herein which subdivision plan has been ap-
referred to subdivision plan; thence proved by the appropriate municipal
along common boundary line of Lots authorities as and for a subdivision
1 and 2, which is also the easterly plan and is recorded in the Office
most boundary of Parcel 1A, South of the Recorder of Deeds in and for
thirty-seven(37)degrees twenty-four Cumberland County, Pennsylvania
(24) minutes fifty-five (55) seconds in plan Book 69,Page 36.
East,ninety-six and fifty-seven hun- BEING KNOWN AS: 141 East
dredths(96.57)feet to a set iron pin; Main Street, Walnut Bottom, PA
thence continuing by same, South 17266.
forty-five(45)degrees forty-nine(49) PROPERTY ID NO.: 41-31-2230-
minutes twenty-five (25) seconds 064.
East, one hundred eighteen and TITLE TO SAID PREMISES is
thirty hundredths (118.30) feet to vested in Richard A. Stambaugh
a set iron pin in line of land now or and Kristina M. Stambaugh, hus-
formerly of Ronald A. Baker;thence band and wife by deed from Randy
along line of land now or formerly of 06 dated Singleton V. Sin 06/30/2005
Ronald A. Baker, South forty-nine g / /
recorded 07/06/2005 in Deed Book
(49) degrees zero (00) minutes zero
(00) seconds West, thirty-nine and 269 Page 3862.
thirty-two hundredths (39.32) feet
to a point;thence continuing by the
same, South forty-nine (49) degrees
zero(00)minutes(00)seconds West,
fifty and zero hundredths(50.00)feet
to a point at corner of land now or
formerly of Randy K. Boyer; thence
along line of land now or formerly
of Randy K.Boyer,North forty-three
(43)degrees fifteen(15)minutes two
(02) seconds West, two hundred
thirteen and thirty-seven hundredths
102
µ
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952,been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
January 25, February 1, and February 8, 2013
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.
/] r
Lisa Marie Coyrik, Editor
SWORN TO AND SUBSCRIBED before me this
da of Februar 2013
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH,CUMBERLAND COUNTY
My Commission Expires Apr 28,2014
The Patriot-News Co.
2020 Technology Pkwy
t al�Suite 3O - tw
1J tw
s
Mechanicsburg, PA 17060 Now you know
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
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
Marianne Miller, 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 clate(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.
]OP-1-7
I � 2012,21"Civil ad ran on the date(s)shown below:
)T U! Do the Bank National rust
Company 01122/13
;)I f VS 01129/13
1!1E Kristina Stambaugh,alfk1a
Kristin M.Stambaugh 02/06/13
Richard Stambaugh,a/k/a
Richard A.Stambaugh
Attr. Mark Udren
ALL THE FOLLOWING DESCRIBED
REAL ESTATE LYING AND BEING
SITTUTEINTHEVILLAGEOFWALNUT Sworn Jo an subscribed before;mthis 14 day of Febr ary, 2013 A.D.
BOTTOM, SOUTH NEWTOWN
TOWNSHIP, CUMBERLAND �iAA
COUNTY, PENNSYLVANIA, MORE
PARTICULARLY DESCRIBED AS It Iqo ta?v ubIIG
FOLLOWS:
BEING AT A SET RAILROAD',
SPIKE IN THE CENTERLINE OF
PA TRAFFIC ROUTE 174 (WALNUT
BoTrom ROAD) AT COMMON
CORNER OF LOTS I AND 2 ON
n-M ympxiN izEFERRIP-D TO
SUBDIVISION PLAN; THENCE COMMONWEALTH OF PENNSYLVANIA
Seat
0
ALONG COMMON BOUNDARY LINE Notarial seat
OF LOTS I AND 2,WHICH IS ALSO Holly Lynn Warfel,Notary Public
TR EASTERLY M 'Y MWaShingwn Twp.,6 Dauphin '
Q$J WDAR Washington Twp.,Dauphin county
YC m
OF PARCEL 1A, SOUTH TIURTY- My cDrnrnlsslon Expires Dec.12,2016
SEVEN (37). DEGREES TWENTY- 4 MEMBER,PENNSYLVANIA
ASSOCIATION OF NOTARIES
FOUR (241 MygijTES FIFTY-FIVE,
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS:
1,Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff s Deed in which Deutsch Bank National Trust Company as Trustee for GSAMP Trust 2005-
WMC1 is the grantee the same having been sold to said grantee on the 6th day of March A.D., 2013,
under and by virtue of a writ Execution issued on the 9th day of October, A.D., 2012, out of the Court of
.Common Pleas of said County as of Civil Term, 2012 Number 2145, at the suit of Deutsche Bank
National Trust Company as Trustee for GSAMP Trust 2005-WMCI against Krishna Stambbaugh a/k/a
j
Kristina M. Stambaugh and Richard Stambaugh a/k/a Richard A. Stambaugh is duly recorded as
Instrument Number 201323550.
IN TESTIMONY WHEREOF,I have hereunto set my hand
and seal of said office this /�z day of
Recorder of Deeds