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Home My WebLink About13-2541 f � Supreme Court of Pennsylvania Cou ' Com. 'n Pleas For Prothonotary Use Only: " It �, eet ...,.' ~r.. C t , BRC,A D COU lnty Docket No: The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: S ® Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking E Lead Plaintiffs Name: U.S. Bank National Association as Trustee Lead Defendant's Name: JOHN R. THOMPSON C for RASC 2007KS1 T Are money damages requested ?: ❑ Yes ® No Dollar Amount Requested: within arbitration limits I (Check one) ' X outside arbitration limits O N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJ Appeal? [ ® No Name of Plaintiff /Appellant's Attorney: Scott A. Dietterick, Esq. c/o Zucker, Goldberg & Ackerman, LLC A ❑ Check here if you have no attorney (are a Self - Represented [Pro Sel Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other S [I Product Liability (does not include mass tort) ❑ Employment Dispute: E ❑ Slander/Libel/Defamation Discrimination ❑ Other: ❑ Employment Dispute: Other C ❑ Zoning Board T ❑ Other: I MASS TORT ❑ Other: O ❑ Asbestos ❑ Tobacco N ❑ Toxic Tort- DES ❑ Toxic Tort Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑ Other: ❑Ejectment El Common Law /Statutory Arbitration ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment B El Ground Rent El Mandamus ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations ® Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 1/1//2011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE CIVIL DIVISION FOR RASC 2007KS1, ` NO.. Plaintiff, VS. TYPE OF PLEADING JOHN R. THOMPSON; BEVERLY A. THOMPSON CIVIL ACTION - COMPLAINT a /k /a BEVERLY A. NACE THOMPSON; IN MORTGAGE FORECLOSURE Defendants. FILED ON BEHALF OF: U.S. Bank National Association as Trustee for TO: DEFENDANTS RASC 2007KS1 YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE COUNSEL OF RECORD FOR THIS PARTY: ENTERED AGAINST YOU. I HEREBY CERTIFY THAT THE ADDRESS ZUCKER, GOLDBERG & ACKERMAN, LLC OF THE PLAINTIFF IS: 1100 VIRGINIA DRIVE, PO BOX 8300 Scott A Dietterick, Esquire r� FORT WASHINGTON, PA 19034 Pa. I.D. #55650 Z c .....� AND THE DEFENDANT: Kimberly A. Bonner, Esquire ,- Pa. I.D. #89705 =� 7 f •._ 142 Emerson Drive af"- Carlisle, PA 17013 Joel A. Ackerman, Esquire Pa I.D. #202729 Ashleigh Levy Marin, Esquire 2: C:-)'-;� CERTIFICATE OF LOCATION Pa I.D. #306799 Ta CZ cf I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS Ralph M. Salvia, Esquire 142 Emerson Drive, Carlisle PA 17013 Pa I.D. #202946 Municipality: South Middleton Jaime R. Ackerman, Esquire 016 wuk Pa I.D. #311032 ATTORNEY VOI1 PLAINTIFF 200 Sheffield Street, Suite 101 ATTY FILE NO.: XCP 160652 Mountainside, NJ 07092 (908) 233 -8500 (908) 233 -1390 FAX office@zuckergoldberg.com File No.: XCP- 160652/mme C� Q 0 nij IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF, IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF, OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE, THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. Bank National Association as Trustee for RASC CIVIL DIVISION r 2007KS1 NO.: f3 `7 lUI - Plaintiff, r JOHN R. THOMPSON; BEVERLY A. THOMPSON { " a /k /a BEVERLY A. NACE THOMPSON; rS- Defendants. = r' .> NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990 -9108 Phone (800) 990 -9108 (717) 249 -3166 (717) 249 -3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. Bank National Association as Trustee for RASC CIVIL DIVISION 2007KS1 Plaintiff, NO.: VS. JOHN R. THOMPSON; BEVERLY A. THOMPSON a /k /a BEVERLY A. NACE THOMPSON; Defendants. AVISO USTED HA SIDO DEMANDADO /A EN CORTE. Si usted desea defenderse de la demanda establecida en las siguientes paginas, debe tomar accion dentro de los pr6ximos veinte (20) dias despues de la notificaci6n de esta Demanda y Aviso respondiendo personalmente o por medio de un abogado una comparecencia esc rita y radicando en la Corte por escrito sus defensas y objeciones a las demandas establecidas en su contra. Se le advierte de que si usted falla en tomar accion como se describe anteriormente, el caso puede proceder sin usted sin previo aviso y un fallo por cualquier suma de dinero reclamada en la demanda 0 cua Iquier otra reclamaci6n o remedio solicitado por el demandante, puede ser dictado en contra suva por la Corte. Usted puede perder dinero o propiedades u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI LISTED NO TIENE UN ABOGADO 0 NO PUEDE PAGAR LINO, LLAME 0 VAVA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990 -9108 Phone (800) 990 -9108 (717) 249 -3166 (717) 249 -3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. Bank National Association as Trustee for RASC CIVIL DIVISION 2007KS1 Plaintiff, NO.: VS. JOHN R. THOMPSON; BEVERLY A. THOMPSON a /k /a BEVERLY A. NACE THOMPSON; Defendants. CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And now comes U.S. Bank National Association as Trustee for RASC 2007KS1, by its attorneys, Zucker, Goldberg & Ackerman, LLC, and files this Complaint in Mortgage Foreclosure as follows; 1. The Plaintiff is U.S. Bank National Association as Trustee for RASC 2007KS1, (hereinafter "plaintiff') through its servicing agent Ocwen Loan Servicing, LLC, located at 1100 VIRGINIA DRIVE, PO BOX 8300, FORT WASHINGTON, PA 19034. 2. The Defendant, JOHN R. THOMPSON , is an individual whose last known address is 142 Emerson Drive, Carlisle, PA 17013. 3. The Defendant, BEVERLY A. THOMPSON a /k /a BEVERLY A. NACE THOMPSON, is an individual whose last known address is 142 Emerson Drive, Carlisle, PA 17013. 4. U.S. Bank National Association as Trustee for RASC 2007KS1, directly or through an agent, has possession of the Promissory Note. U.S. Bank National Association as Trustee for RASC 2007KS1 is either the original payee of the Promissory Note or the Promissory Note has been duly indorsed. A true and correct copy of said Promissory Note is marked Exhibit A, attached hereto and made a part hereof. 5. On or about October 6, 2006, JOHN R. THOMPSON and BEVERLY A. THOMPSON, his wife made, executed and delivered to Mortgage Electronic Registration Systems, Inc. as nominee for GMAC Mortgage Corp DBA ditech.com a Mortgage in the original principal amount of $133,400.00 on the premises described in the legal description marked Exhibit B, attached hereto and made a part hereof. Said mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on December 6, 2006, in Mortgage Book \Volume 1975, Page 2132. The mortgage is a matter of Zucker, Goldberg & Ackerman, LLC XCP- 160652 public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(8), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 6. Plaintiff is the current Mortgagee. By Assignment of Mortgage recorded May 7, 2012, the mortgage was assigned to U.S. Bank National Association as Trustee for RASC 2007KS1 which assignment is recorded in the Office of the Recorder of Deeds for Cumberland County, Instrument #201213415. The Assignment is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 7. JOHN R. THOMPSON and BEVERLY A.THOMPSON are record and real owners of the aforesaid mortgaged premises. 8. Defendants are in default under the terms of the aforesaid Mortgage for, inter alia, failure to pay the monthly installments of principal and interest due July 1, 2011. 9. As of 04/17/2013 the amount due and owing Plaintiff by Defendant(s) is as follows: Principal $127,870.12 Interest through 04/17/2013 $16,369.14 Late Charges $971.52 Escrow $2,466.72 Prop Inspection $64.25 BPO $303.00 Total $148,044.75 plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania Law, actually and reasonably incurred by Plaintiff, including but not limited to, costs (including escrow advances) and Plaintiff's attorneys' fees and expenses. Plaintiff reserves the right to file a motion in the above - captioned action to add such additional sums authorized under the Mortgage and Pennsylvania Law to the above amount due and owing when incurred. 10. Notice of Intention to Foreclose as set forth, in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and /or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s). Zucker, Goldberg & Ackerman, LLC XCP- 160652 11. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is not seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so in a separate legal action if such right exists. If Defendant(s) have received a discharge of personal liability in a bankruptcy proceeding, this action is in no way an attempt to re- establish such liability. WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of $148,044.75 with interest thereon plus additional costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. ZUCKER, GOLDBERG & ACKERMAN, LLC BY: q Dated: Scott A. ietterick, Es uire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Attorneys for Plaintiff XCP- 160652/mme 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233 -8500; (908) 233 -1390 FAX Email: Office @zuckergoIdberg.com THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Zucker, Goldberg & Ackerman, LLC XCP- 160652 EXHIBIT A Zucker, Goldberg & Ackerman, LLC XCP- 160652 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. Bank National Association as Trustee for RASC CIVIL DIVISION 2007KS1 2 Plaintiff NO" J�p) I V� r 7 JOHN R. THOMPSON; BEVERLY A. THOMPSON f� a /k /a BEVERLY A. NACE THOMPSON; Tj c C3 Defendants. %ms 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. Zucker, Goldberg & Ackerman, LLC XCP- 160652 IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. TIDS PROGRAM IS FREE. ZUCKER, GOLDBERG & ACKERMAN, LLC By: 6 / 0' & vj�— h Dated: May ' 2013 Scott A. Dietterick, Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Attorneys for Plaintiff XCP- 160652/emed 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233 -8500; (908) 233 -1390 FAX Email: Office @zuckergoldberg.com Zucker, Goldberg & Ackerman, LLC XCP- 160652 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: CUSTOM .. Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? CO-BORROWER Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? FINANCIAL •• • First Mortgage Lender: Type of Loan: Loan Number: Date you closed your loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ If yes, provide names, location of court, case number & attorney: Zucker, Goldberg & Ackerman, LLC XCP- 160652 Assets Amount Owed Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1 : Model: Year: Amount owed: Value: Automobile #2 : Model: Year: Amount owed: Value: Monthly Income Name of Employers: 1. 2. 3. Additional Income Description (not wages): 1 • 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 2nd Mortgage Utilities Car Payment(s) Condo /Neigh. Fees Auto Insurance Med. (not covered) Auto fuel /repairs Other prop. payment Install. Loan Payment Cable TV Child Support/Alim. Spending Money Day /Child Care /Tuit. Other Expenses 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: Zucker, Goldberg & Ackerman, LLC XCP- 160652 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 known, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: AUTHORIZATION 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 1 /we am /are under no obligation to use the services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: V Proof of Income V Past 2 bank statements V Proof of any expected income for the last 45 days V Copy of current utility bill V Letter explaining reason for delinquency and any supporting documentation (hardship letter) V Listing agreement (if property is currently on the market) Zucker, Goldberg & Ackerman, LLC XCP- 160652 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. Bank National Association as Trustee for RASC CIVIL DIVISION 2007KS1 Plaintiff, NO.: VS. JOHN R. THOMPSON ; BEVERLY A. THOMPSON a /k /a BEVERLY A. NACE THOMPSON; Defendants. REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated February 28, 2012 governing the Cumberland County 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; 1. Defendant lives in the subject real property, which is defendant's primary residence; 2. 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. § 4904 relating to unworn falsification to authorities. Signature of Defendant's Counsel /Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date Zucker, Goldberg & Ackerman, LLC XCP- 160652 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. Bank National Association as Trustee for RASC CIVIL DIVISION 2007KS1 Plaintiff, NO.: VS. JOHN R. THOMPSON; BEVERLY A. THOMPSON a /k /a BEVERLY A. NACE THOMPSON; Defendants. CASE MANAGEMENT ORDER AND NOW, this day of ,20 ,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 conciliation Conference on at .M. in at the Cumberland County Courthouse, Carlisle, Pennsylvania. 1. 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 may be extended. Upon notice to the Court of the defendant /borrower's failure to serve the completed Form 2 within 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. 2. 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 who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable Zucker, Goldberg & Ackerman, LLC XCP- 160652 resolution, and counsel for 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. 3. 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 a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 4. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, J. Zucker, Goldberg & Ackerman, LLC XCP- 160652 % \z MIN: Loan Number : ADJUSTABLE RATE NOTE (Assumable during Life of Loan) (First LIBOR Index Bus ness Day of Preceding Month Lookback) THIS NOTE CONTAINS PROVISIONS ALLOWING FOR CHANGES IN MY INTEREST RATE AND MY MONTHLY PAYMENT. THIS NOTE LIMITS THE AMOUNT MY INTEREST RATE CAN CHANGE AT ANY ONE TIME AND TILE MAXIMUM RATE I MUST PAY. OCTOBER 6, 2006 COSTA MESA CALIFORNIA [Date] [City] [State] 142 EMERSON DRIVE, CARLISLE, PENNSYLVANIA 17013 (Property Address) 7. BORROWER'S PROMISE TO PAY In return for a loan that I have received, I promise to pay U.S. $13 3 , 4 0 0 . 0 0 called "Principal "), plus interest, to the order of the Lender. The Lender is GMAC MORTGAGE this amount is CORPORATION DBA DITECH.COM, RESIDENTIAL MORTGAGE LENDER I will make all payments under this Note in the form of cash, check or money order. I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note is called the "Note Holder." 2. INTEREST Interest will be charged on unpaid principal until the full amount of Principal has been paid. I will pay interest at a yearly rate of 9 . 6 2 5 %. The interest rate I will pay will change in accordance with Section 4 of this Note. The interest rate required by this Section 2 and Section 4 of this Note is the rate I will pay both before and after any default described in Section 7(B) of this Note. 3. PAYMENTS (A) Time and Place of Payments I will pay principal and interest by making a payment every month. I will make my monthly payment on the 1st day of each month beginning on DECEMBER 1 2006 . I will make these payments every month until I have paid all of the principal and interest and any other charges described below that I may owe under this Note. Each monthly payment will be applied as of its scheduled due date and will be applied to interest before Principal. If, on NOVEMBER 1, 2 03 6 I still owe amounts under this Note, I will pay those amounts in full on that date, which is called the "Maturity Date. " I will make my monthly payments at 3200 PARK CENTER DRIVE, SUITE 150, COSTA MESA, CALIFORNIA 92626 (B) Amount of MI= Initial Monthly Payments or at a different place if required by the Note Molder. Each of my initial monthly payments will be in the amount of U.S. $1, 13 3 . 8 9 amount may change. This MULTISTATE ADJUSTABLE RATE NOTE - 6 -Month LIBOR Index --- (Assumable During Life of Loan) (First Business Day Lookback) "' 800- 649-1362 Single Family -- Freddie Mac MODIFIED INSTRUMENT www.docmagic.com Form 5520 3/04 Page 1 of 5 Us5i2A9.noi. Lem (C) Monthly Payment Changes Changes in my monthly payment will reflect changes in the unpaid principal of my loan and in the interest rate - that I must pay. The Note Holder will determine my new interest rate and the changed amount of my monthly payment in accordance with Section 4 of this Note. 4. INTEREST RATE AND MONTHLY PAYMENT CHANGES (A) Change Dates The interest rate I will pay may change on the 1st day of NOVEMBER, 2009 and may change on that day every sixth month thereafter. Each date on which my interest rate could change is called a "Change Date," (B) The Index Beginning with the first Change Date, my interest rate will be based on an Index. The "Index" is the six month London Interbank Offered Rate ( "LIBOR ") which is the average of interbank offered rates for six -month U.S. dollar- denominated deposits in the London market, as published in The Wall Street Journal. The most recent Index figure available as of the first business day of the month immediately preceding the month in which the Change Date occurs is called the "Current Index." If the Index is no longer available, the Note Holder will choose a new index which is based upon comparable information. The Note Holder will give me notice of this choice. (C) Calculation of Changes Before each Change Date, the Note Holder will calculate my new interest rate by adding SIX AND 220/1000 percentage point(s) ( 6 . 2 2 0 %) to the Current Index. The Note Holder will then round the result of this addition to the nearest one - eighth of one percentage point (0.125 %). Subject to the limits stated in Section 4(D) below, this rounded amount will be my new interest rate until the next Change Date. The Note Holder will then determine the amount of the monthly payment that would be sufficient to repay the unpaid principal that I am expected to owe at the Change Date in full on the Maturity Date at my new interest rate in substantially equal payments. The result of this calculation will be the new amount of my monthly payment. (D) Limits on Interest Rate Changes The interest rate I am required to pay at the first Change Date will not be greater than 12.625% or less than 6 . 62 5 %. Thereafter, my interest rate will never be increased or decreased on any single Change Date by more than ONE AND 0 0 0 / 10 0 0 percentage point(s) ( 1 . 0 0 0 %) from the rate of interest I have been paying for the preceding six months. My interest rate will never be greater than 15.625%. (E) Effective Date of Changes My new interest rate will become effective on each Change Date. I will pay the amount of my new monthly payment beginning on the first monthly payment date after the Change Date until the amount of my monthly payment changes again. (l) Notice of Changes The Note Holder will deliver or mail to me a notice of any changes in my interest rate and the amount of my monthly payment before the effective date of any change. The notice will include information required by law to be given to me and also the title and telephone number of a person who will answer any question I may have regarding the notice. 5. BORROWER'S RIGHT TO PREPAY ** See attached Prepayment Note Addendtmt. I have the right to make payments of Principal at any time before they are due. A payment of Principal only is known as a "Prepayment." When I make a Prepayment, I will tell the Note Holder in writing that I am doing so. I may not designate a payment as a Prepayment if I have not made all the monthly payments due under the Note. MULTISTATE ADJUSTABLE RATE NOTE - 6 -Month LIBOR Index DocA4agtc4ff;'tn 900 -7362 (Assumable During Life of Loan) (First Business Day Lookback) www.dacmagic.com Single Family -- Freddie Mac MODIFIED INSTRUMENT Form 5520 3/04 Page 2 of 5 LM5202.not.2.tem I may make a full Prepayment or partial Prepayments without paying a Prepayment charge, The Note Holder will use my Prepayments to reduce the amount of Principal that I owe under this Note. However, the Note Holder may apply my Prepayment to the accrued and unpaid interest on the Prepayment amount before applying my Prepayment to reduce the Principal amount of the Note. If I make a partial Prepayment, there will be no changes in the due dates of my monthly payment unless the Note Holder agrees in writing to those changes. My partial Prepayment may reduce the amount of my monthly payments after the first Change Date following my partial Prepayment. However, any reduction due to my partial Prepayment may be offset by an interest rate increase. 6. LOAN CHARGES If a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest or other loan charges collected or to be collected in connection with this loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from me which exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing the Principal I owe under this Note or by making a direct payment to me. If a refund reduces Principal, the reduction will be treated as a partial Prepayment. 7. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charges for Overdue Payments If the Note Holder has not received the full amount of any monthly the end of 15 calendar days after the date it is due, I will pay a late charge to he Note Holder. Theamount of the charge will be 5.000 % of my overdue payment of principal and interest. I will pay this late charge promptly but only once on each late payment. (B) Default If I do not pay the full amount of each monthly payment on the date it is due, I will be in default. (C) Notice of Default If I am in default, the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a certain date, the Note Holder may require me to pay immediately the full amount of Principal which has not been paid and all the interest that I owe on that amount. That date must be at least 30 days after the date on which the notice is mailed to me or delivered by other means. (D) No Waiver by Note Holder Even if, at a time when I am in default, the Note Holder does not require me to pay immediately in full as described above, the Note Holder will still have the right to do so if I am in default at a later time. (E) Payment of Note Holder's Costs and Expenses If the Note Holder has required me to pay immediately in full as described above, the Note Holder will have the right to be paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses include, for example, reasonable attorneys' fees. 8. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to me under this Note will be given by delivering it or by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note Holder a notice of my different address. Any notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it by first class mail to the Note Holder at the address stated in Section 3(A) above or at a different address if I am given a notice of that different address. 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, MULTISTATE ADJUSTABLE RATE NOTE - 6 -Month LIBOR Index (Assumable During Life of Loan) (First Business Day Lookback) DoclNayicQ?t-Xtmz 800 - 649 -1362 Single Family -- Freddie Mac MODIFIED INSTRUMENT www.docmagic.com Form 5520 3/04 Page 3 of 5 Us55203.not.3.tem including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. The Note Holder may enforce its rights under this Note against each person individually or against all of us together. This means that any one of us may be required to pay all of the amounts owed under this Note. 10. WAIVERS I and any other person who has obligations under this Note waive the rights of Presentment and Notice of Dishonor. "Presentment" means the right to require the Note Holder to demand payment of amounts due. "Notice of Dishonor" means the right to require the Note Holder to give notice to other persons that amounts due have not been paid. 11. UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to the Note Holder under this Note, a Mortgage, Deed of Trust, or Security Deed (the "Security Instrument "), dated the same date as this Note, protects the Note Holder from possible losses which might result if I do not keep the promises which I make in this Note. That Security Instrument describes how and under what conditions I may be required to make immediate payment in full of all amounts I owe under this Note. Some of those conditions are described as follows: Transfer of the Property or a Beneficial Interest in Borrower. As used in this Section 18, "Interest in the Property" means any legal or beneficial interest in the Property, including, but not limited to, those beneficial interests transferred in a bond for deed, contract for deed, installment sales contract or escrow agreement, the intent of which is the transfer of title by Borrower at a future date to a purchaser. If all or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower is not a natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior written consent, Lender may require immediate payment in full of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law. Lender also shall not exercise this option if: (a) Borrower causes to be submitted to Lender information required by Lender to evaluate the intended transferee as if a new loan were being made to the transferee; and (b) Lender reasonably determines that Lender's security will not be impaired by the loan assumption and that the risk of a breach of any covenant or agreement in this Security Instrument is acceptable to Lender. To the extent permitted by Applicable Law, Lender may charge a reasonable fee as a condition to Lender's consent to the loan assumption. Lender may also require the transferee to sign an assumption agreement that is acceptable to Lender and that obligates the transferee to keep all the promises and agreements made in the Note and in this Security Instrument. Borrower will continue to be obligated under the Note and this Security Instrument unless Lender releases Borrower in writing. If Lender exercises the option to require immediate payment in full, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is given in accordance with Section 15 within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. MULTISTATE ADJUSTABLE RATE NOTE - 6 -Month LIBOR Index DocMa9icd?V--VM0& 800.549 -1352 (Assumable During Life of Loan) (First Business Day Lookback) www.docmagic.com Single Family -- Freddie Mac MODIFIED INSTRUMENT Form 5520 3/04 Page 4 of 5 U05204.=A.[em WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED OHM R . THOMPSON — (Seal) (Seal) - Borrower - Borrower (Seal) (Seal) - Borrower - Borrower i (Seal) (Seal) - Borrower - Borrower ''!l"C R1E zany LLC PAY TO THE. ORDWt OF QV abo aESIDENTIAL FUNDING COMPANY LLB = A ditcch.com Inc, BY . [Sign Original Only] MULTISTATE ADJUSTABLE RATE NOTE - 6 -Month LIBOR Index (Assumable During Life of Loan) (First Business Day Lookback) DoCMagfCebt°xtu magic. om Single Family -- Freddie Mac MODIFIED INSTRUMENT ►�W�docmagic.c Form 5520 3/04 Page 5 of 5 W5205. not. 5. tem EXHIBIT B Zucker, Goldberg & Ackerman, LLC XCP- 160652 • 4 • - 1 • mat Form No. 3300 (5/00) ORDER NO: , Short Form Commitment FILE NO : 0 ASP LENDER Rar 4< The land referred to in this policy is situated in the STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND, TOWNSHIP OF SOUTH MIDDLETON, and described as follows: ALL THAT CERTAIN TRACT OF LAND WITH THE IMPROVEMENTS THEREON ERECTED, SITUATE IN SOUTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED IN ACCORDANCE WITH SUBDIVISION PLAN OF WEST MOORELAND HEIGHTS, SECTION "A ", RECORDED IN THE HEREINAFTER MENTIONED RECORDER'S OFFICE IN PLAN BOOK 25, PAGE 65, AS FOLLOWS: BEGINNING AT A POINT ON THE EASTERN LINE OF THIRTY -SIX (36) FEET WIDE EMERSON DRIVE AT THE NORTHWESTERN CORNER OF LOT NO. 6 AS SHOWN ON SAID PLAN, WHICH POINT AT THE PLACE OF BEGINNING IS THREE HUNDRED FOURTEEN (314) FEET SOUTH OF THE SOUTHERN LINE OF THIRTY -SIX (36) FEET WIDE WEBSTER DRIVE MEASURED ALONG THE EASTERN LINE OF SAID THIRTY -SIX (36) FEET WIDE EMERSON DRIVE; THENCE FROM SAID POINT AT THE PLACE OF BEGINNING ALONG LINE OF LAND NOW OR FORMERLY OF W. FOSTER BISHOP AND WIFE, NORTH 48 DEGREES 30 MINUTES EAST, A DISTANCE OF ONE HUNDRED FORTY (140) FEET TO A POINT AT THE NORTHWESTERN CORNER OF LOT NO. 3 AS SHOWN ON SAID PLAN; THNCE ALONG THE WESTERN LINE OF SAID LOT NO. 3, SOUTH 41 DEGREES 30 MINUTES EAST, A DISTANCE OF ONE HUNDRED THIRTY 130) FEET TO A POINT COMMON TO LOTS NOS. 3 AND 4 AND 6 AND 7 AS SHOWN ON SAID PLAN; THENCE ALONG THE DIVIDING LINE BETWEEN LOTS NOS. 6 AND 7, SOUTH 48 DEGREES 30 MINUTES WEST, A DISTANCE OF ONE HUNDRED FORTY (140) FEET TO A POINT ON THE EASTERN LINE OF THIRTY -SIX (36) FEET WIDE EMERSON DRIVE; THENCE ALONG THE EASTERN LINE OF SAID THIRTY -SIX (36) FEET WIDE EMERSON DRIVE, NORTH 41 DEGREES 30 MINUTES WEST, A DISTANCE OF ONE HUNDRED THIRTY (130) FEET TO A POINT AT THE PLACE OF BEGINNING. CONTAINING ONE HUNDRED THIRTY 130)) FEET IN FRONT ALONG THE EASTERN LINE OF THIRTY -SIX (36) FEET WIDE EMERSON DRIVE AND XTENDING EASTWARDLY THEREFROM AT AN EVEN WIDTH A DISTANCE OF ONE HUNDRED FORTY (140) FEET TO LOT NO. 3 AND BEING ALL OF LOT NO. 6 AS SHOWN ON SAID SUBDIVISION PLAN OF WEST MOORELAND HEIGHTS, SECTION "A ", RECORDED IN THE HEREINAFTER MENTIONED RECORDER'S OFFICE IN PLAN BOOK 25, PAGE 65. 11111IIII111111 Jill 111 THOMPSON 10921737 PA FIRST AMERICAN LENDERS ADVANTAGE APN:40240746031 MORTGAGE 1111 IIll1 {11 it IBII1lt11 {1N1R II11111111111{ tll When recorded mail to: First American Title Insurance Lenders Advantage 1 100 Superior Avenue, Suite 200 Cleveland, Ohio 44114 Attn: NRP'rEAM th is to be recorded .�utiiberland County PA 6K 19 7 5 PG 2 154 Recorder of Deeds VERIFICATION , 0 U'k— "un� SNC r (title), depose and say subject to the penalties of 18 Pa.C.S.A., sec. 4904 relating to unsworn falsification to authorities that the facts set forth in the foregoing pleading are true and correct to the best of my information, knowledge and belief. By: U.S. Bank National Association as Trustee for RASC 2007KS1 Name: Title i zed S %2ne File No: 160652 1 G no o- cr-x P Borrower Name: JOHN R. THOMPSON SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson THE� f,) `i Sheriff tRrarrfa t Jody S Smith L0113ilhY29 pt-1 _ Chief Deputy fir Richard W Stewart CuMBERLAIq`D COUN,I, 1 Solicitor PEN?4SYLVAMA `��! ag�T� ��'�� U.S. Bank National Assoication as Trustee for RASC 2007KS1 Case Number vs. John Rueal Thompson (et al.) 2013-2541 SHERIFF'S RETURN OF SERVICE 05/13/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: John Rueal Thompson, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found" at 142 Emerson Drive, South Middleton, Carlisle, PA 17015. Residence is vacant, the Carlisle Postmaster confirms that the defendant is not known at the address provided. 05/13/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Beverly Thompson, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 142 Emerson Drive, South Middleton, Carlisle, PA 17013. Residence is vacant, the Carlisle Postmaster confirms that the defendant is not known at the address provided. SHERIFF COST: $60.78 SO ANSWERS, x ZX� May 24, 2013 RbNW R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosoft,Inc. e IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. Bank National Association as Trustee for CIVIL DIVISION - RASC 2007KS1 NO.: 13-2541 CIVIL c Plaintiff, . vs. cn r JOHN R.THOMPSON ; BEVERLY A. �_ THOMPSON a/k/a BEVERLY A. NACE THOMPSON• ;> C.3 a? Defendants. C:> - PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please mark the Complaint in Mortgage Foreclosure filed at the above-captioned term and number reinstated. ZUCKER, GOLDBERG &ACKERMAN, LLC By: OR 1v Dated: August 21, 2013 Scott A. Dietterick, Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D.#202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R.Ackerman, Esquire; PA I.D.#311032 Attorneys for Plaintiff XCP-160652/cper 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office @zuckergoldberg.com 2aa4go6 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ;f -( j '�(T, Sheriff f Ci,' C) �xv [�"rr�r#'ic+�f� � 'ti y Body s smut, Chief Deputy 2013 SEP —{ QM It' -1`6 Richard W Stewart ' "" CUMBERLAND COUNTY Solicitor ORME OF Tkl$YERIFr PENNSYLVANIA U.S. Bank National Assoication as Trustee for RASC 2007KS1 Case Number vs. 2013-2541 John Rueal Thompson (et al.) SHERIFF'S RETURN OF SERVICE 08/29/2013 04:15 PM- Deputy Ryan Burgett, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: John Rueal Thompson at 288 Walnut Bottom Road, Carlisle Borough, Carlisle, PA 17013. RYAN BURGETT, DE 08/29/2013 04:15 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be John Thompson, husband,who accepted as"Adult Person in Charge"for Beverly Thompson at 288 Walnut Bottom Road, Carlisle Borough, Carlisle, PA 17013. RYAN BURGETT, DffPUTV SHERIFF COST: $50.78 SO ANSWERS, August 30, 2013 RON R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosoft,Inc. PHELAN HALLINAN, LLP Attorney for Plaintiff John D. Krohn, Esq., Id. No.312244 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 john.krohn@phelanhallinan.com 215-563-7000 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2007KS 1 COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION VS. CUMBERLAND COUNTY JOHN R. THOMPSON BEVERLY A. THOMPSON No. 13-2541 CIVIL A/K/A BEVERLY A. NACE THOMPSON Defendant ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter our appearance as counsel on behalf of the Plaintiff, U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2007KS 1 in the above captioned matter. Phelan Hallinan, LLP Date: 112 y _ By: John D. Kro , Esq., Id. No.3122412- Attorney for Plaintiff --Cl= Phelan Hallinan, LLP x;u cn fv :�►cl PH#936975 PHELAN HALLINAN, LLP Attorney for Plaintiff John D. Krohn, Esq., Id. No.312244 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 john.krohn@phelanhallinan.com 215-563-7000 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2007KS 1 Plaintiff COURT OF COMMON PLEAS VS. CIVIL DIVISION JOHN R. THOMPSON CUMBERLAND COUNTY BEVERLY A. THOMPSON A/K/A BEVERLY A. NACE THOMPSON No. 13-2541 CIVIL Defendant CERTIFICATION OF SERVICE I hereby certify a true and correct copy of the foregoing Entry of Appearance was served by regular mail on Defendant(s) on the date listed below: JOHN R. THOMPSON BEVERLY A. THOMPSON A/K/A BEVERLY A. NACE THOMPSON 288 WALNUT BOTTOM ROAD 288 WALNUT BOTTOM ROAD CARLISLE, PA 17013 CARLISLE, PA 17013 Phelan Hallinan, LLP Date: �Lt b By: QA,-- John D. Kro , Esq., Id. No.312244 Attorney for Plaintiff Phelan Hallinan, LLP PH#936975 PHELAN HALLINAN, LLP _ ., 'r'. : 3 AM t H Attorney for Plaintiff Adam H. Davis, Esq., Id. No.203034 1617 JFK Boulevard, Suite 1400 ` �E) C )UNT One Penn Center Plaza EN NS L`v' 1 A Philadelphia, PA 19103 Adam.Davis@PhelanHallinan.com 215-563-7000 U.S. BANK NATIONAL ASSOCIATION : CUMBERLAND COUNTY AS TRUSTEE FOR RASC 2007KS1 : COURT OF COMMON PLEAS vs. : CIVIL DIVISION JOHN R. THOMPSON BEVERLY A. THOMPSON : No. 13-2541 CIVIL A/K/A BEVERLY A.NACE THOMPSON . PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against JOHN R. THOMPSON and BEVERLY A. THOMPSON A/K/A BEVERLY A.NACE THOMPSON, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $148,044.75 TOTAL $148,044.75 I hereby certify that (1)the Defendants' last known addresses are 288 WALNUT BOTTOM ROAD, CARLISLE, PA 17013 and 142 EMERSON DRIVE, CARLISLE, PA 17015-9185, and (2)that notice has been given in accordance with Rule Pa.R.C.P 237.1. Date 7/z// ' /Ke(4-/L Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: J1VI PH#936975 PROTHONOTARY +756/6.�1 et# /wows Ao&E pea.kel 3d46tt PHELAN HALLINAN,LLP Attorney for Plaintiff Adam H. Davis,Esq.,Id. No.203034 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Adam.Davis@PhelanHallinan.com 215-563-7000 U.S.BANK NATIONAL ASSOCIATION : CUMBERLAND COUNTY AS TRUSTEE FOR RASC 2007KS1 : COURT OF COMMON PLEAS vs. : CIVIL DIVISION JOHN R. THOMPSON : No. 13-2541 CIVIL BEVERLY A. THOMPSON A/K/A BEVERLY A.NACE THOMPSON : AFFIDAVIT OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the defendant(s)JOHN R. THOMPSON and BEVERLY A. THOMPSON A/K/A BEVERLY A. NACE THOMPSON are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act, as amended. (b) that defendant JOHN R. THOMPSON is over 18 years of age and has last known addresses at 288 WALNUT BOTTOM ROAD, CARLISLE, PA 17013 and 142 EMERSON DRIVE, CARLISLE, PA 17015-9185. (c) that defendant BEVERLY A. THOMPSON A/K/A BEVERLY A. NACE THOMPSON is over 18 years of age and has last known addresses at 288 WALNUT BOTTOM ROAD, CARLISLE, PA 17013 and 142 EMERSON DRIVE, CARLISLE, PA 17015-9185. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date l // c • Phelan Hallinan, LLP Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff PHELAN HALLINAN, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza, Philadelphia, PA 19103 215-563-7000 936975 Department of Defense Manpower Data Center Results as of Mar-12-2074 02 26 30 AM SCRA 3.0 ! "'5 ,- ,' Status R ol° ` . Bay Pursuant to Servicemerfabers Civil Relief Act Last Name: THOMPSON First Name: BEVERLY Middle Name: A Active Duty Status As Of: Mar-12-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component Vh, NA NA No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duly Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Catf-Up to.Acute Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her.unit has received early notill atron 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. • }1 & —fotioey).—. Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 Department of Defense Manpower Data Center Results as of Mar-12-2014 02'26 25 AM SCRA 3.0 A f Status Rvott Pursuant to Servicemerabers Civil Relief Act Last Name: THOMPSON First Name: JOHN Middle Name: R Active Duty Status As Of: Mar-12-2014 On Active Duty On Active Duty.Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No - NA This response reflects the individuals'activeduty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date, Active Duty End Date n Status Service Component NA NA I No NA This response reflects where the individual left active duty status withn367 days preceding the Active Duty Status Date € The Member or Hts/HerUhd Was Notified of a FutEure Ca1FUp to Active Duty on Active Duty Status Date ';Order Notitcaton Stmt Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her-unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,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. '411117ilif# yA. a.w Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 - •'_-~~._~~~.- -~~~°~ -�~=° • Department of Defense Manpower Data Center Results~m.w=-1'-2m^o2.3r59^w x�^oo s ---~ Report 7 Pursuant to Servicemembcrs Civil Relief Act Last Name: THOMPSON First Name: BEVERLY Middle Name: A. NACE Active Duty Status As Of: Ma 1 14 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component The Member or His/Her Unit Was Notified of a Future Call-UP to Active Duty ort Active Duty Status Date 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 c�aa��. mmmum includes/nm�a�nonuomvm�emumm»mmo unit receiving nmm�o�mmmmomommmv�fmAm* Duty. ° )4. '.)41CM110 ~_�°��"�~__ Mary M.Snavely-Dixon,Director Department of Defense Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA U.S. Bank National Association as Trustee for RASC : CIVIL DIVISION 2007KS1 Plaintiff, NO.: 13-2541 CIVIL vs. • JOHN R.THOMPSON •• BEVERLY A. THOMPSON a/k/a BEVERLY A. NACE THOMPSON • Defendant. IMPORTANT NOTICE TO: JOHN R.THOMPSON 288 Walnut Bottom Rd Carlisle PA 17013-3739 DATE OF NOTICE: 10/23/2013 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 again you.Unless you act within Ten(10)days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal Help. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone(800)990-9108 Phone(800)990-9108 (717)249-3166 (717)249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. Bank National Association as Trustee for RASC : CIVIL DIVISION 2007KS1 Plaintiff, • NO.: 13-2541 CIVIL vs. JOHN R.THOMPSON • BEVERLY A. THOMPSON a/k/a BEVERLY A. NACE THOMPSON Defendant. • • AVISO IMPORTANTE TO: JOHN R.THOMPSON 288 Walnut Bottom Rd Carlisle PA 17013-3739 FECHA DEL AVISO:10/23/2013 LISTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXEMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO II-'TNIEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO 0 NO PUEDE PAGAR LINO, VAYA 0 LLAME LA OFICINA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TO DEFEND &LAWYER REFERRAL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone(800)990-9108 Phone(800)990-9108 (717)249-3166 (717)249-3166 ZUCKER,GOLDBERG &ACKERMAN BY: SOdt A. D Ielte1-& Scott A. Dietterick,Esquire Attorneys for Plaintiff PA I.D. # 55650 200 Sheffield Street, Suite 301 P.O. Box 1024 Mountainside,NJ 07092-0024 (717) 533-3560 FIRST CLASS U.S. MAIL, POSTAGE PREPAID 160652 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. Bank National Association as Trustee for RASC CIVIL DIVISION 2007KS1 Plaintiff, NO.: 13-2541 CIVIL vs. JOHN R. THOMPSON BEVERLY A. THOMPSON a/k/a BEVERLY A. NACE THOMPSON Defendant. • IMPORTANT NOTICE TO: BEVERLY A. THOMPSON a/k/a BEVERLY A. NACE THOMPSON 288 Walnut Bottom Rd Carlisle PA 17013-3739 DATE OF NOTICE: 10/23/2013 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 again you. Unless you act within Ten (10)days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal Help. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone(800)990-9108 Phone(800)990-9108 (717)249-3166 (717)249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. Bank National Association as Trustee for RASC : CIVIL DIVISION 2007KS1 Plaintiff, NO.: 13-2541 CIVIL vs. • JOHN R.THOMPSON BEVERLY A. THOMPSON a/k/a BEVERLY A. NACE THOMPSON Defendant. • • • AVISO IMPORTANTE TO: BEVERLY A. THOMPSON a/k/a BEVERLY A. NACE THOMPSON 288 Walnut Bottom Rd Carlisle PA 17013-3739 FECHA DEL AVISO:10/23/2013 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DIC;I'AR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INMEDIATAMENTE A SIT ABOGADO. SI USTED NO TIENTE UN ABOGADO 0 NO PUEDE PAGAR UNO, VAYA 0 LLAME LA OFICJNA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TO DEFEND &LAWYERREFERRAL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone(800)990-9108 Phone(800)990-9108 (717)249-3166 (717)249-3166 ZUCKER,GOLDBERG &ACKERMAN BY: Solt A. D Ietterick Scott A. Dietterick,Esquire Attorneys for Plaintiff PA I.D. # 55650 200 Sheffield Street, Suite 301 P.O. Box 1024 Mountainside,NJ 07092-0024 (717) 533-3560 FIRST CLASS U.S. MAIL, POSTAGE PREPAID 160652 (Rule of Civil Procedure No. 236) - Revised U.S.BANK NATIONAL ASSOCIATION : CUMBERLAND COUNTY AS TRUSTEE FOR RASC 2007KS1 : COURT OF COMMON PLEAS vs. JOHN R. THOMPSON : CIVIL DIVISION BEVERLY A. THOMPSON A/K/A BEVERLY A. NACE THOMPSON : No. 13-2541 CIVIL Notice is given that a Judgment in the above captioned matter has been entered 1 against you on 3'1 I11 . .� / 1 ) a a� r By: w.. If you have any questions concerning this matter please contact: Phelan Hallinan, LLP Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 ** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** 936975 t PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 U.S.BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC • COURT OF COMMON PLEAS 2007KS1 • Plaintiff • CIVIL DIVISION • • v. NO.: 13-2541 CIVIL JOHN R.THOMPSON • BEVERLY A.THOMPSON A/K/A BEVERLY A.NACE THOMPSON CUMBERLAND COUNTY Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due $148,044.75 Interest from 03/15/2014 to Date of Sale $4,210.82 ($24.34 per diem) TOTAL $152,255.57 Phelan Hallinan,LLP Adam H.Davis,Esq.,Id.No.203034 Attorney for Plaintiff Note: Please attach description of property. PH#936975 -3 auk a-Atkv3 !SO. so . 8 It L, ^ `_ 1(7 It `I ,S 1t cl . s cx zoo ef CILIA. LrboT) 11 1.- • Sct c LEGAL DESCRIPTION ALL that certain tract of land with the improvements thereon erected, situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with Subdivision Plan of West Mooreland Heights, Section 'A', recorded in the hereinafter mentioned Recorder's Office in Plan Book 25, Page 65, as follows: BEGINNING at a point on the Eastern line of Thirty-Six (36) feet wide Emerson Drive at the Northwestern corner of Lot No. 6 as shown on said Plan, which point at the place of beginning is Three Hundred Fourteen (314)feet South of the Southern line of Thirty-six (36)feet wide Webster Drive measured along the Eastern line of said Thirty-six (36) feet wide Emerson Drive; thence from said point at the place of beginning along line of land now or formerly of W. Foster Bishop and wife, North 48 degrees 30 minutes East, a distance of One Hundred Forty(140)feet to a point at the North-western corner of Lot No. 3 as shown on said Plan; thence along the Western line of said Lot No. 3, South 41 degrees 30 minutes East, a distance of One Hundred Thirty(130) feet to a point common to Lots Nos. 3 and 4 and 6 and 7 as shown on said Plan; thence along the dividing line between Lots Nos. 6 and 7, South 48 degrees 30 minutes West, a distance of One Hundred Forty (140)feet to a point on the Eastern line of Thirty-six (36) feet wide Emerson Drive; thence along the Eastern line of said Thirty-six (36) feet wide Emerson Drive, North 41 degrees 30 minutes West, a distance of One Hundred Thirty (130)feet to a point at the place of BEGINNING. CONTAINING One Hundred Thirty(130) feet in front along the Eastern line of Thirty-six (36) feet wide Emerson Drive and extending Eastwardly therefrom at an even width a distance of One Hundred Forty (140) feet to Lot No. 3 and being all of Lot No.6 as shown on said Subdivision Plan of West Mooreland Heights, Section 'A', recorded in the hereafter mentioned Recorder's Office in Plan Book 25, Page 65. TITLE TO SAID PREMISES VESTED IN John R. Thompson and Beverly A. Thompson, his wife, by Deed from John R. Thompson and Beverly A. Nace Thompson dated 4/1/1977 and recorded 4/1/1977 in Deed Book 27, page 9. PREMISES BEING: 142 EMERSON DRIVE,CARLISLE,PA 17015-9185 PARCEL NO.40-24-0746-031 z 0 a v 0 OQ Ei °x zv °x E o azo Z M at � HQ •0 ¢ E. o N 0H H � E" a Q N C 3 a y W Z a rn a cu z3 - wd3 � O x w> rx b 0 Q w Q OQ nNU CO c,) U W H W W W U z a Z c o W c y z . C N›,w azcA - d w z w p >C a) m H z W o O O o CV 'et � z za � F., A [-� 4x a bn F.2 cgd z :o C . 6 � W=° Oa • Few W 0 0 � a �Uw � � a � Q U xQ xg4 as Z WW 4U > Oxi 0. t�. adQ PHELAN HALLINAN, LLP ; t Attorneys for Plaintiff Adam H. Davis, Esq., Id. No.203034 1617 JFK Boulevard, Suite 1400 '2.k-11'i k i l [ 3 AM I I 1 One Penn Center Plaza as ; Philadelphia, PA 19103 `-'` a3Et-,L,aNll GOES„ 7 Adam.Davis@PhelanHallinan.com 1 �i i E_L`1� I A 215-563-7000 U.S.BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC : COURT OF COMMON PLEAS 2007KS1 Plaintiff : CIVIL DIVISION v. : NO.: 13-2541 CIVIL JOHN R. THOMPSON BEVERLY A. THOMPSON : CUMBERLAND COUNTY A/K/A BEVERLY A.NACE THOMPSON Defendant(s) CERTIFICATION The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: ( ) the mortgage is an FHA Mortgage ( ) the premises is non-owner occupied ( ) the premises is vacant (X) Act 91 procedures have been fulfilled ( ) Act 91 is Not Applicable pursuant to Pa Bulletin, Doc No 11-1197, 41 Pa.B. 3943 This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. By: fi/ �--- Phelan Hallinan,LLP Adam H.Davis,Esq.,Id.No.203034 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE ▪ COURT OF COMMON PLEAS FOR RASC 2007KS1 Plaintiff • CIVIL DIVISION • v. • NO.: 13-2541 CIVIL • • • JOHN R. THOMPSON BEVERLY A. THOMPSON • CUMBERLAND COUNTY A/K/A BEVERLY A.NACE THOMPSON Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 U.S.BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2007KS1,Plaintiff in the above action,by the undersigned attorney,sets forth as of the date the Praecipe for the Writ of Execution was filed,the following information concerning the real property located at 142 EMERSON DRIVE,CARLISLE,PA 17015-9185. 1. Name and address of Owner(s)or reputed Owner(s): Name Address(if address cannot be reasonably ascertained, please so indicate) JOHN R.THOMPSON 288 WALNUT BOTTOM ROAD CARLISLE,PA 17013 BEVERLY A.THOMPSON 288 WALNUT BOTTOM ROAD tTt A/K/A BEVERLY A.NACE THOMPSON CARLISLE,PA 17013 2. Name and address of Defendant(s)in the judgment: Name Address(if address cannot be reasonably ascertained,please so indicate) � n ' JOHN R.THOMPSON 288 WALNUT BOTTOM ROAD -y CARLISLE,PA 17013 cµ BEVERLY A.THOMPSON 288 WALNUT BOTTOM ROAD A/K/A BEVERLY A.NACE THOMPSON CARLISLE,PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address(if address cannot be reasonably ascertained,please indicate) EQUABLE ASCENT FINANCIAL 1120 WEST LAKE COOK ROAD SUITE B BUFFALO GROVE,IL 60089 EQUABLE ASCENT FINANCIAL EDWIN A.ABRAHAMSEN&ASSOCIATES, C/O MICHAEL F.RATCHFORD,ESQUIRE P.C. 120 N KEYSER AVE SCRANTON,PA 18504 CAPITAL ONE BANK,N.A. 15000 CAPITAL ONE DRIVE RICHMOND,VA 23238 CAPITAL ONE BANK,N.A. 4851 COX ROAD GLEN ALLEN,VA 23060 PH#936975 V ` 1 CAPITAL ONE BANK,N.A. HAYT,HAYT&LANDAU,LLC C/O ARTHUR LASHIN,ESQUIRE 123 S BROAD ST STE 1660 PHILADELPHIA,PA 19109 4. Name and address of last recorded holder of every mortgage of record: Name Address(if address cannot be reasonably ascertained,please indicate) FARMERS TRUST COMPANY 1 WEST HIGH STREET P.O.BOX 220 CARLISLE,PA 17013 5. Name and address of every other person who has any record lien on the property: Name Address(if address cannot be reasonably ascertained,please indicate) SOUTH MIDDLETON TOWNSHIP 44 WEST MAIN STREET MUNICIPAL AUTHORITY MECHANICSBURG,PA 17055 C/O KEITH O.BRENNEMAN,ESQUIRE SOUTH MIDDLETON TOWNSHIP 520 PARK DRIVE MUNICIPAL AUTHORITY BOILING SPRINGS,PA 17007 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address(if address cannot be reasonably ascertained,please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address(if address cannot be reasonably ascertained,please indicate) TENANT/OCCUPANT 142 EMERSON DRIVE CARLISLE,PA 17015-9185 DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET CUMBERLAND COUNTY CARLISLE,PA 17013 COMMONWEALTH OF PENNSYLVANIA P.O.BOX 2675 DEPARTMENT OF WELFARE HARRISBURG,PA 17105 INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH,PA 15222 PH#936975 U.S.DEPARTMENT OF JUSTICE 228 WALNUT STREET,SUITE 220 U.S.ATTORNEY FOR THE MIDDLE PO BOX 11754 DISTRICT OF PA HARRISBURG,PA 17108-1754 FEDERAL BUILDING I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Date: jilfZ/4C By: Phelan Hallinan,LLP Adam H.Davis,Esq.,Id.No.203034 Attorney for Plaintiff PHELAN HALLINAN,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza,Philadelphia,PA 19103 215-563-7000 PH#936975 • U.S.BANK NATIONAL ASSOCIATION AS TRUSTEE FOR : COURT OF COMMON PLEAS RASC 2007KS1 : CIVIL DIVISION Plaintiff : : NO.: 13-2541 CIVIL vs. JOHN R. THOMPSON : CUMBERLAND COUNTY BEVERLY A. THOMPSON A/K/A BEVERLY A. NACE THOMPSON Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: JOHN R. THOMPSON =W BEVERLY A. THOMPSON A/K/A BEVERLY A. NACE THOMPSON r 288 WALNUT BOTTOM ROAD cr=}> c a CARLISLE,PA 17013 ` **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORM5NON QBTA[NED WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BZNK�RUP�TC`Y, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT,BUT l)1V,LY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house(real estate)at 142 EMERSON DRIVE,CARLISLE,PA 17015-9185 is scheduled to be sold at the Sheriff's Sale on 09/03/2014 at 10:00 AM in the Cumberland County Courthouse,South Hanover Street, Carlisle,PA 17013 to enforce the court judgment of$148,044.75 obtained by U.S.BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2007KS1 (the mortgagee)against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 (800) 990-9108 SHORT DESCRIPTION By virtue of a Writ of Execution No. 13-2541 CIVIL U.S.BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2007KS1 v. JOHN R. THOMPSON BEVERLY A. THOMPSON A/K/A BEVERLY A. NACE THOMPSON owner(s) of property situate in SOUTH MIDDLETON TOWNSHIP, CUMBERLAND County, Pennsylvania, being 142 EMERSON DRIVE, CARLISLE,PA 17015-9185 Parcel No.40-24-0746-031 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING Judgment Amount: $148,044.75 Attorneys for Plaintiff Phelan Hallinan, LLP LEGAL DESCRIPTION ALL that certain tract of land with the improvements thereon erected, situate in South Middleton Township, Cumberland County, Pennsylvania,bounded and described in accordance with Subdivision Plan of West Mooreland Heights, Section 'A', recorded in the hereinafter mentioned Recorder's Office in Plan Book 25, Page 65, as follows: BEGINNING at a point on the Eastern line of Thirty-Six (36) feet wide Emerson Drive at the Northwestern corner of Lot No. 6 as shown on said Plan, which point at the place of beginning is Three Hundred Fourteen (314)feet South of the Southern line of Thirty-six (36) feet wide Webster Drive measured along the Eastern line of said Thirty-six (36) feet wide Emerson Drive; thence from said point at the place of beginning along line of land now or formerly of W. Foster Bishop and wife, North 48 degrees 30 minutes East, a distance of One Hundred Forty (140)feet to a point at the North-western corner of Lot No. 3 as shown on said Plan; thence along the Western line of said Lot No. 3, South 41 degrees 30 minutes East, a distance of One Hundred Thirty (130) feet to a point common to Lots Nos. 3 and 4 and 6 and 7 as shown on said Plan; thence along the dividing line between Lots Nos. 6 and 7, South 48 degrees 30 minutes West, a distance of One Hundred Forty(140) feet to a point on the Eastern line of Thirty-six (36) feet wide Emerson Drive; thence along the Eastern line of said Thirty-six (36)feet wide Emerson Drive, North 41 degrees 30 minutes West, a distance of One Hundred Thirty (130) feet to a point at the place of BEGINNING. CONTAINING One Hundred Thirty(130) feet in front along the Eastern line of Thirty-six (36) feet wide Emerson Drive and extending Eastwardly therefrom at an even width a distance of One Hundred Forty(140) feet to Lot No. 3 and being all of Lot No.6 as shown on said Subdivision Plan of West Mooreland Heights, Section 'A', recorded in the hereafter mentioned Recorder's Office in Plan Book 25, Page 65. TITLE TO SAID PREMISES VESTED IN John R. Thompson and Beverly A. Thompson, his wife, by Deed from John R. Thompson and Beverly A. Nace Thompson dated 4/1/1977 and recorded 4/1/1977 in Deed Book 27, page 9. PREMISES BEING: 142 EMERSON DRIVE,CARLISLE,PA 17015-9185 PARCEL NO.40-24-0746-031 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-2541 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2007KS1 Plaintiff(s) From JOHN R.THOMPSON,BEVERLY A. THOMPSON A/K/A BEVERLY A.NACE THOMPSON (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: $148,044.75 L.L.: $.50 Interest FROM 3/15/2014 TO DATE OF SALE($24.34 PER DIEM)-$4,210.82 Atty's Comm: Due Prothy: $2.25 Atty Paid: $272.06 Other Costs: Plaintiff Paid: Date:3/13/14 David D.Buell Prothonota (Seal) B - — - Deputy REQUESTING PARTY: Name: ADAM H.DAVIS, ESQUIRE Address: PHELAN HALLINAN,LLP 1617 JFK BLVD.,SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA,PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No.203034 AFFIDAVIT OF SERVICE PLAINTIFF U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2007KS1 DEFENDANT JOHN R. THOMPSON BEVERLY A. THOMPSON A/K/A BEVERLY A. NACE THOMPSON SERVE JOHN R. THOMPSON AT: 288 WALNUT BOTTOM ROAD CARLISLE, PA 17013 SERVED Served and made known to JOHN R. THOMPSON Defendant on the 3o o clock . M., at 28fc Wk rJo7 & TRDM RD. (44w u , Prq, in the Defendant rsonally served_ j Adult family member with whom Defendant(s) reside(s). Relationship is R) 1 F . _ Adult in charge of Defendant's residence who refused to give name or relationship. _ Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. CUMBERLAND COUNTY PH # 936975 SERVICE TEAM/ kb COURT NO.: 13-2541 CIVIL TYPE OF ACTION XX Notice of Sheriff's Sale SALE DATE: September 3, 2014 28ay of AM -1 , 20 14 , at manner described below: Other. Description: Age 5Z's Height D' ' Weight Z2.o Race W Sex Other Ronald Moll a competent adult, hereby verify that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: NAME: PRINTED NAME: Ronald Mull Process Server TITLE: NOT SERVED On the day of,20 , at o'clock _. M., I, state that Defendant NOT FOUND ecause: _ Vacant _ Does Not Exist _ Moved _ Does Not Reside (Not Vacant) No Answer on at at Service Refused Other. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. L V^ -p -.Z... ..crri CZ g- - , a competent adult hereby BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 (215) 563-7000 y.s AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY US. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2007KS1 PH # 936975 DEFENDANT JOHN R. THOMPSON BEVERLY A. THOMPSON A/K/A BEVERLY A. NACE THOMPSON SERVE BEVERLY A. THOMPSON A/K/A BEVERLY A. NACE THOMPSON AT: 288 WALNUT BOTTOM ROAD CARLISLE, PA 17013 SERVICE TEAM/ lxh COURT NO.: 13-2541 CIVIL TYPE OF ACTION XX Notice of Sheriff's Sale SALE DATE: September 3, 2014 SERVED Served and made known to BEVERLY A. THOMPSON A/K/A BEVERLY A. NACE THOMPSON, Defendant on thege day of An 4.1 20.1.4, at 7: 3o o'clock ? M. at $$ INk PuT rrbA4 2D u 0.93/, in the manner described below: Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is . Adult in charge of Defendant's residence who refused to give name or relationship. _ Manager/Clerk of place of lodging in which Defendant(s) reside(s). _ Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other. Description: Age CV Height 5'61. Weight 22..0 Race IN Sex C Other l On -Id lol i a competent adult, hereby verify that I personally handed a true and correct copy of the Notice of en s e m the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. r DATE: NAME: PRINTED NAME: Ronald Moll TITLE: Process Server NOT SERVED On the day of,20 , at o'clock . M., I, , a competent adult hereby state that Defendant NOT FOUND ecause: _ Vacant_ Does Not Exist _ Moved _ Does Not Reside (Not Vacant) No Answer on at at _ Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 (215) 563-7000 PHELAN HALLINAN, LLP Adam H. Davis, Esq., Id. No.203034 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Adam.Davis@PhelanHallinan.com 215-563-7000 �r frrt rrFTHO O1A 2014 AUG 20 A rr1dy totylaintiff CUNBERL NO COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2007KS1 Plaintiff, v. JOHN R. THOMPSON BEVERLY A. THOMPSON A/K/A BEVERLY A. NACE THOMPSON Defendant(s) CUMBERLAND COUNTY . COURT OF COMMON PLEAS CIVIL DIVISION No.: 13-2541 CIVIL AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.2 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, set forth on the Affidavit and as amended if applicable. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached hereto Exhibit "A". Date: fia(7r Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PH # 936975 Name and Address Of Sender Article Number Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadel+hia, PA 19103 Name of Addressee Stree and Post Office Address AZK/CET• Commonwealth of Pennsylvania Department of Welfare P.O. Box 2675 +« Harrisbu : PA 17105 Internal Revenue Service Advisory 1000 Liberty Avenue Room 704 Pittsbur_h PA 15222 U.S. Department of Justice U.S. Attorney for the Middle District of PA Federal Building 228 Walnut Street, Suite 220 PO Box 11754 Harrisbur. PA 17108-1754 /03/2014 SALE OHN:L THOMPSON. CUMBERLAND Form 3877 Facsimile The full declaration of value is form the reconstruction tion ofv value is required nn all domestic and International regstcred mail. The maximum indemnity nonnegotiable documents under Express Mail document reconstruction i 0 pperbk piece subject to o limit of $300,000 per occurrence. The maximum indemnity payobk on Ex The msutirnvro indemnity payable h 525,009 for to _ insurance Is S30,t>nn per R9005913 and 5921 for Ihnitations of coven. �� ova sent with optional Insurance See Domestic 'merchandise 4 SS00. Elomestic Mail Manual Name and Address Of Sender Phelan Hallinan, LLP 10110 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 AZK/CET - 09/03/2014 SALE Line Article Number Name of Addressee, Street, and Post Office Address Postage l U? ,, m z .r.. _a a. ' " x, ti' 1 **** TENANT/OCCUPANT 142 EMERSON DRIVE CARLISLE, PA 17015-9185 $0.47 2 **** CAPITAL ONE BANK, N.A. 15000 CAPITAL ONE DRIVE RICHMOND, VA 23238 $0.47 3 **** CAPITAL ONE BANK, N.A. 4851 COX ROAD GLEN ALLEN, VA 23060 $0.47 4 **** CAPITAL ONE BANK, N.A. C/O ARTHUR LASHIN, ESQUIRE HAYT, HAYT & LANDAU, LLC 123 S BROAD ST STE 1660 PHILADELPHIA, PA 19109 $0.47 5 **** EQUABLE ASCENT FINANCIAL 1120 WEST LAKE COOK ROAD . SUITE B BUFFALO GROVE, IL 60089 $0. tof 6 **** EQUABLE ASCENT FINANCIAL C/O MICHAEL F. RATCHFORLI, ESQUIRE EDWIN A. ABRAHAMSEN & ASSOCIATES, P.C. a 120 N KEYSER AVE SCRANTON, PA 18504 SO. 7 **** FARMERS TRUST COMPANY - 1 WEST HIGH STREET P.O. BOX 220 CARLISLE, PA 17013 $0.47 8 **** SOUTH MIDDLETON TOWNSHIP MUNICIPAL AUTHORITY 520 PARK DRIVE go. BOILING SPRINGS, PA 17007 $0.47 9 **** SOUTH MIDDLETON TOWNSHIP MUNICIPAL AUTHORITY C/O KEITH O. BRENNEMAN, ESQUIRE 44 WEST MAIN STREET • MECHANICSBURG, PA 17055 $0.47 10 **** Domestic Relations of Cumberland County • 13 North Hanover Street Carlisle, PA 17013 $0.47 ItE:'JORNMR 'HON(CUMBERLAND)P.# 9 'r _ $6.11 , Total Number of Pieces Listed by Sender Total Number of Pieces Received at Post Office Postmaster. Per (Name of Receiving Employee) The full declaration of value is required on all domestic and international registered mall. The maximum indemnity payable for the reconstruction of nonnegotiable documents under Eapreas Mail document reconstruction insurance is S50,000 per piece 'object to a limit of $500,0110 pc, occurrence. The maximum indemnity payable on Express Mall merchandise is S500. The maxinotm indemnity payabk is $25.000 for registered ina14 sent with optionat insurance. Sec Dnou is Mail Manual R900 S913 and 5921 for limitations of coverage. Form 3877 Facsimile