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HomeMy WebLinkAbout13-2917 Supreme Co ennsylvania t For Prothonota Use O nly: Coll frCo�*1<n>cuo leas ry y: f Tj C • ' �rV@'Ip et Docket No: STq Cu and" rrr County 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 bylaw or rules of court. Commencement of Action: S n Complaint ® Writ of Summons Petition Transfer from Another Jurisdiction ® Declaration of Taking E Lead Plaintiff's Name: Lead Defendant's Name: C Deutsche Bank national Trust Company Steven A. Ebersole; Tessa A. Giacobbe- Ebersole T Dollar Amount Requested: ® within arbitration limits I Are money damages requested? ® Yes El No (check one) 13 outside arbitration limits O N Is this a Class Action Suit? ® Yes 0 No Is this an MDJAppeal? ® Yes xa No LL1ZABETH L WASSALL, ESQ A Name of Plaintiff /Appellant's Attorney: PA 1D 77788 ® Check here if you have no attorney (are a Self- Represented [Pro Se] 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 n Motor Vehicle © Debt Collection: Other 13 Board of Elections Nuisance [] Dept. of Transportation E] Premises Liability [3 Statutory Appeal: Other S 0 Product Liability (does not include mass tort) 13 Employment Dispute: E Discrimination 0 Slander/Libel/ Defamation ® Employment Dispute: Other ® Zoning Board C ® Other: ® Other: T I 13 Other: O MASS TORT n Asbestos N ® Tobacco ® Toxic Tort - DES Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS ® Toxic Waste © Ejectment [3 Common Law /Statutory Arbitration n Other: ® Eminent Domain/Condemnation n Declaratory Judgment B [3 Ground Rent © Mandamus © Landlord/Tenant Dispute [3 Non - Domestic Relations IM Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY [3 Mortgage Foreclosure: Commercial Quo Warranto 0 Dental ® Partition Replevin ® Legal ® Quiet Title Other: ® Medical Q Other: ® Other Professional: Updated 1 /1/2011 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE GAZZARA DOYLE, ESQUIRE - ID #34576 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 SALVATORE CAROLLO, ESQUIRE - ID #311050 HARRY B. REESE, ESQUIRE - ID #310501 - ELIZABETH L. WASSALL, ESQUIRE - ID#77788 r :' KATHERINE E. KNOWLTON, ESQUIRE - ID #311713, JOHN ERIC KISHBAUGH, ESQUIRE - ID #33078 8 � tv NICOLE B. LABLETTA, ESQUIRE - ID #202194 DAVID NEEREN, ESQUIRE - ID #204252 C JORDAN DAVID, ESQUIRE - ID #311968' WOODCREST CORPORATE CENTER p 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 2006 -FM3, CIVIL DIVISION Mortgage Pass - Through Certificates, CUMBERLAND County Series 2006 -FM3 C/O Ocwen Loan Servicing, LLC l e tut J 1661 Worthington Road NO. Suite 100 West Palm Beach, FL 33409 Plaintiff V. STEVEN A. EBERSOLE 1805 CREEK VIEW CT NEW CUMBERLAND, PA 17070 TESSA A. GIACOBBE - EBERSOLE 1805 CREEK VIEW CT NEW CUMBERLAND, PA 17070 Defendant(s) 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 (2 k- a --qo�7� you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. 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 ascentar 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 provisioner 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 December 1, 2006, GSAMP trust 2006 -FM3 Date of Assignment: 12/13/2010 Recorded Date: 02/10/2011 Book/Instrument #: Instrument Number: 201105047 Page: N/A Assignor: Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement dated as of December 1, 2006, GSAMP trust 2006 -FM3 Assignee: Deutsche Bank National Trust Company as Trustee for GSAMP Trust 2006 -FM3, Mortgage Pass - Through Certificates, Series 2006 -FM3 Date of Assignment: 12/17/2012 Recorded Date: 01/03/2013 Book/Instrument #: Inst# 201300158 Page: N/A 2. Upon information and belief Defendant(s) and/or their predecessor: Steven A. Ebersole & Tessa A. Giacobbe - Ebersole (hereinafter "Defendants "), are the owners of property located at 1805 Creekview Ct, New Cumberland, PA 17070, by virtue of Deed dated 09/08/2006 and recorded 09/12/2006 in Official Records Book 276 at Page 3114 of the Public Records of Cumberland County, Pennsylvania (hereinafter the 'Property "). 3. On 09/08/2006, Defendant(s) and /or their predecessor: STEVEN A. EBERSOLE TESSA GIACOBBE - EBERSOLE promised to pay to the order of Fremont Investment & Loan, the principal sum of $137,600.00 payable with interest thereon provided in the Note. 4. By Mortgage dated 09/08/2006, Defendant(s) and /or their predecessor: STEVEN A. EBERSOLE TESSA GIACOBBE- EBERSOLE to secure the Note, mortgaged to Mortgage Electronic Registration Systems, Inc., as nominee for Fremont Investment & Loan , the Property which is the subject of this action. The Mortgage was recorded on 09/12/2006 in Official Records Book 1965 at Page 3360. Said Mortgage is incorporated herein by referenced in accordance with Pa.R.C.P 1019(8). 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 03/01/2010, 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 $133,436.44 Accumulated Interest $33,875.29 Accumulated Late Charges $1,212.02 Escrow Deficit /(Reserve) $12,226.81 Title Report $300.00 Attorney Fees $1,650.00 Property Valuation Fee - BPO $1,168.00 Property Inspection Fee $94.50 Prior Servicer Fees $1,278.00 Grand Total $185,241.06 The above figures are calculated as of 04/25/2013: 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 8.00000 %. The per diem interest accruing on this debt is $28.5000 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 $60.61. 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 $ 185,241.06 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged premises. UDREN LAW ICES, P.C. BY ' ALL, ESQ PA ID 77788 VERIFICATION Contract Management I, the undersigned, a(n) Coordinator of Ocwen Loan Servicing, LLC ( "Ocwen ") attorney in fact for Deutsche Bank National Trust Company as Trustee for GSAMP Trust 2006 -FM3, Mortgage Pass - Through Certificates, Series 2006 -FM3 ( "Plaintiff'), am authorized to make this verification on behalf of Ocwen and hereby certify that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. Except where otherwise stated and /or based upon public record, this verification is based upon a review of business records regularly created, kept and maintained in the course of Ocweri s mortgage servicing business conducted on Plaintiffs behalf. In making this verification, I understand that it is a crime under 18 PA C.S. Section 4904 to make a written statement to a public servant, or to invite a public servant's reliance upon a written statement or instrument, which I do not believe to be true or which I know to be false Date: Name: ►� ���� Title: Contract Management Coordinator Company: Ocwen Loan Servicing, LLC. as attorney in fact for Deutsche Bank National Trust Company as Trustee for GSAMP Trust 2006 -FM3, Mortgage Pass - Through Certificates, Series 2006 -FM3 Borrower: STEVEN A. EBERSOLE TESSA A. GIACOBBE - EBERSOLE Property Address: 1805 Creekview Ct, New Cumberland, PA 17070 MJU #: 11120774 -1- Transfer Legal description: ALLTHAT CERTAIN tract or parcel of land situate in the Township of Lower Allen, County of Cumberland and Commonwealth of Pennsylvania, more partIcularty bounded and described as follows, to wit: BEGINNING at a point on the southerly line of Creek View Court at the comer of Lot No. 22 of the hereinafter mentioned Plan of trots; thence by the southerly We of Creek View Court by a curve to the left having a radius of 60 feet, an are distance of 24.04 feet to a point at the comer of Lot No. 24 of the hereinafter mentioned Plan of Lots; thence by Lot No. 88 South 22 degrees 43 minutes 27 seconds West, a distance of 25.20 feet to a point at Lot No, 22 of the hereinafter mentioned Plan of Lots; thence by Lot No. 22 North 49 degrees 31 minutes 52 seconds West, a distance of 167.44 feet to a point on the southern lisle of Creek. Mery Court, the place of BEGINNING. BEING Lot No. 23 of ft Final Subdivision Pian for Phase 1, Beacon Hill Village of Creekside, recorded in Cumberland County Plan Book -50, Page 113. BEING the same premises which Gary E. Lenderman and Men, f Lou Lenderman. by their deed dated September 8, 2006 and intended to be recorded herewith, granted and conveyed unto Tessa A, Giscobbe- Ebersole and Steven A. Ebersole, owners/mortgagors :herein. October 25, 2012 AC T 91 NO'T'ICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lewder intends to foreclose Specific information about the nature of the default i pr in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name address and phone number of Consumer Credit Counseling Agen serving your County are fasted at the end of this Notice If you have any questions, you may call the Pennsvlvania Housing Finance Agency toll free at 1- 800 -342 -2397. (Persons with impaired hearing can call 071.7) 780 - 1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUUNTO ES DE SUMA IMPORTANCIA, DUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. Exhibit A HOMEOWNER'S NAME(S): Steven A. Ebersole Tessa A. Giacobbe- Ebersole ._.._-........_..........._... ._.........__......__.._....... ......__...........__ _.....__............_-.........._._......__........ __........._ ............. - - -_.. PROPERTY ADDRESS: 1805 Creekview Ct. New Cumberland, PA 17070 ........ . ..____......... __......___.........___ ..................._ - ....... --_ _ - LOAN ACCT. NO.: 7090832101 _...........__......._._------___..._........__._.._.__.__.... ... _ _ _.. . .__...__.._.....__....._..__..._..._.........--- ....----- ._.....___.....__._.. ORIGINAL LENDER: FREMONT INVESTMENT & LOAN _.._......__.........-_.._.___._.___...____._..__._..---_... __......._.._....._..._......._ ....__._._......____......_--- ........--- ._.....____..___.. CURRENT LENDER: Deutsche Bank National Trust Company as Trustee under the Pooling and Servicing Agreement dated as of December 1., 2006, GS-AMP Trust 2006 -FM3, Mortgage Pass- Through Certificates, Series 2006 - FM3 HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MADE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the. Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face -to- face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF THIS NOTICE IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - -. If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the propert y is located are set forth at the end of this Notice It is only necessary to schedule one face -to -face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated. consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you. in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face -to -face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE ". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS A LATE APPLICATION. WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The 'Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will. be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Br inp it up t0 date). NATURE OF THE DEFAULT — The MORTGAGE debt held by the above lender on your property located at: 1805 Creekview Ct. New Cumberland, PA 17070 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Payments of $1,010.10 for March 1, 2010 through April 1, 2010 = $2,020.20 Monthly Payment of $1,010.06 for May 1, 2010 = $1,010.06 Monthly Payments of $1,232.62 for June 1, 2010_throu2h October 1, 2012 = $35,745,.98 Late Ch arges $1,393.82 Other charges (explain/itemize): Property Valuation FeesBPO = $876.00 Property Inspection Fees= $63.00 _........_._ _. _ ... -- _. TOTAL AMOUNT PAST DUE: $41,109.06 B. YOU RAVE .FAILED TO 'TAKE THE FOLLOWING ACTION ( not use if not applicable N/A HOW TO CURE THE DEFAULT -- You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $41,109.06 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check, certified check or money order made payable and sent to: Udren Law Offices, P.C. Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 -3620 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) N/A IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mort2a2ed property. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you. will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period you will not be required to pay attorney's fees OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the ripA_ to cure the default and prevent the sale at an }_time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriff's 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 or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender /Servicer: Gewen Loan Servicing, LLC ..... __..._._.... -- Address: 1661 Worthington Road, Suite 100 West Palm Beach, FL 33409 _... ___..._....___......__..... -. -- _........__.._.__..__...__-..._.______....._..__......__.-_....._ ___........... .__...._...__.....__..._.___. Phone Number: (877 596 -8580 Fax Number: __(407 737 - 5693 __...__.....--- _.....___ ........ ___- ....__ -. Contact Person: Customer Service _.__......___... ..._ .... ............ _........._.. .... _-_ ...... ... _.._......._..... ..... -...__....._._. _ ........ - ......... ...._._..... E -Mail Address: ...... EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriffs Sale will end. your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff s Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You may have the right to transfer your' home 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 of the mortgage are satisfied. 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 11.1 Woodcrest Load, Suite 200 Cherry Hill, NJ 08003 -3620 (856) 669 -5400 YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF TIIE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTIIER LENDING INSTITU'T`ION TO PAY OFF THIS DEBT. • TO HAVE T141S DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. ® TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) ® TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, ® TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. ® TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY Cumberland County EMAP Consumer Credit Counseling Agencies CUMBERLAND County Report last updated; 08/17/2012 11:26 AM Community Action Commission of Capital Region CCCS of Western PA 1514 Derry Street 2000 Linglestown Road Harrisburg, PA 17104 Harrisburg, PA 17102 717 -232 -9757 888-511-2227 Maranatha PA Interfaith Community Programs Inc 43 Philadelphia Avenue 40 E High Street Waynesboro, PA 1.7268 Gettysburg, PA 17325 717- 762 -3285 717- 334 -1518 PHFA 211 North Front Street Harrisburg, PA 17110 717 -780 -3940 800- 342 -2397 ___ ........._... .... ......... .... ....... 1 a9 't LAW � t a C�jDCR ST CoRpO}RAT CE c 111 � woODCREST ROAD N ! 08003 .�_ CHE RRY HILL, *,� �.. �.3_�F..a� �r zS ?011 3500 0001 5620 6951 Ll a i I Irr COUKETRIHIS,SECTIO ® Complete items 1, 2, and 3. Also complete A. Signature item 4 if Restricted Delivery is desired. 0 Agent al Print your name and address on the reverse I] Addr so that we can return the Card to you. B. Received by {Ponied Name) C. Date of Delivery ® Attach this card to the back of the mailpiece, or on the front if space permits, D. Is delivery address different from item 1? C7 Yes 1. Article Addressed to: If YES, enter delivery address below: Cl No 3. rvice Type Certified Mail ❑ Express Mail D Registered ] Return Receipt for Merchandise 11 Insured M ail C) C.O.D. 4. Restricted Delivery? (Extra fee) i] Yes 2. Article Number 7011 5500 0001, 5620 6951, (Transfer from service label) PS Form 3811, February 2004 Domestic Return Receipt 102595.02- M•1540 :.. UDREN LAW WOODCREST CORPORA r :' i f EP 111 WOODCREST ROAD vt6P,to;, �� CHERRY HILL, NJ 08003 05. 7011 2970 0004 1347 3025 u PO W Complete items 1., 2, and 3. Also complete A. Signature ❑ Agent item 4 if Restricted Delivery is desired. X 0 A ddressee ® Print your name and address on the reverse so that we can return the card to you. B. Received by (Printed Name) C. Date of Delivery i1 Attach this card to the back of the mailpiece, or on the front if space permits. ? Oyes D. Is de livery address different from item 1 1. Article Addressed to: if YES, enter delivery address below. fl NO �if1�� --- �.� J` is.1�- L'�(��(" L�✓CJl- d.lri�i tom � Lt1 I.:ZL14a e - U c, Y /&l �t :) 3. 9 !!7 Certified Mail ❑ Express Mail ❑ Registered 'rt7 Return Receipt for Merchandise D Insure Mail b C.O 4. Restricted Delivery? (Extra Fee) O Yes 2. Article Number 7011 2970 0004 134 302 (Transfer from service label) PS Form 3811, February 2004 Domestic Return Receipt 102595 -02 -M -1540 I FORM 1 IN THE COURT OF COMMON PLEAS OF k . e CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) c -ri vs. Defendants / "� �` () / Civil t" T� C` NOTICE OF RESIDENTIAL MORTGAGE FORECLWW1_ 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 oppoiiunit - , lc nice, Vr'ltii a represei t,ve of your .: lea .. u "t f t: .vr; C: So..able ..� 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. Respectfully su itted: Date [Signature of Counsel for Plaintiff] ELIZABETH L WASSALL, ESQ PA ID 77788 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: CUSTOMER/PRIMARY APPLICANT 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): Citv: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email- 4 of people in household: How long? Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? FINANCfAL INFORMATION 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: S 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: Assets Amount Owed Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checkirig: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: Year: Amount owed: Value: Automobile 42 : Model: Year: Amount owed: Value: Other transportation (automobiles, boats, motorcycles): .Model: Year: Amount_ owed: Value Monthly Income Name of Employers: 1. J. 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) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other prop. payment Install. Loan Pa yment Cable TV i iniiri �n nnnrf %Glim Q1'�Pll /lIY1 Cf MOT P.V Da /Child Care /Tuft. 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: i _ ... .......................... ............................... 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): 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 I /we am /are under no obligation to use the ser -vices provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document alon with the following information to lender and lender's counsel: Proof of income Past 2 bank statements Proof of any expected income for the last 45 days Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation - ( (hardship letter) Y Listing agreement (if property is currently on the market) .. ....................... ............................... _ ............._.. . FORM 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) vs . Defendant(s) CIVIL REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: I . Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; �. 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 1.8 Pa. C.S. §4904 relatino to unsworn falsification to authorities. Signature of Defendant's Counsel /Appointed Date Legal Representative Signature of Defendant Date Signature of .Defendant Date i UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE GAZZARA DOYLE, ESQUIRE - ID #34576 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 SALVATORE CAROLLO, ESQUIRE - ID #311050 HARRY B. REESE, ESQUIRE - ID #310501' ELIZABETH L. WASSALL, ESQUIRE - ID #77788 c JOHN ERIC KISHBAUGH, ESQUIRE - ID #33078 NICOLE B. LABLETTA, ESQUIRE - ID #202194"` 3 DAVID NEEREN, ESQUIRE - ID #204252,, JORDAN DAVID, ESQUIRE - ID #311968 5i -- WOODCREST CORPORATE CENTER p. C 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 ..a 856- 669 -5400 Pleadin s udren.com Deutsche Bank National Trust Company as Trustee COURT OF COMMON PLEAS for GSAMP Trust 2006 -FM3, Mortgage Pass- CIVIL DIVISION Through Certificates, Series 2006 -FM3 CUMBERLAND County 1661 Worthington Road, Suite 100, West Palm Beach, FL 33409 Plaintiff NO. V. Steven A. Ebersole 1805 Creek View Ct New Cumberland, PA 17070 Tessa A. Giacobbe - Ebersole 1805 Creek View Ct New Cumberland, PA 17070 Defendant(s) ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the following counsel: Mark J. Udren, Esquire; Stuart Winneg, Esquire; Lorraine Gazzara Doyle, Esquire; Sherri J. Braunstein, Esquire; Harry B. Reese, Esquire; Salvatore Carollo, Esquire; Elizabeth L. Wassall, Esquire; John Eric Kishbaugh, Esquire; Nicole B. LaBletta, Esquire; David Neeren, Esquire, and Jordan David, Esquire on behalf of the Plaintiff, in the above - captioned matter. UDREN L OFFICES, P.C. BY. ELIZABETH L WASSALL, ESQ PA ID 77788 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Company COURT OF COMMON PLEAS as Trustee for GSAMP Trust 2006-FM3, CIVIL DIVISION Mortgage Pass-Through Certificates, Cumberland County Series 2006-FM3 Plaintiff NO. 13-2917 Civil c`aW=°: V. - - ; STEVEN A. EBERSOLE; TESSA A. GIACOBBE-EBERSOLE ' n C { c�►. ..D Defendant(s) r ° ca Cr PRAECIPE TO REINSTATE COMPLAINT s> .J --a TO THE PROTHONOTARY: Kindly reinstate the Complaint on the above-captioned matter. DATE: UDREN LAW OFFICES, P.C. B orneys for Pla' DaVid Neeren, Esqui- P 20 AD A 52 %41.76pd Q ck. ,:qqgol SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson 7F�I P��j�F��a��`�,+ a . Sheriff I Rxk��y,!'prt�aratttar�,��� i ri Fi 1 Jody S Smith °`' 2013 JUH 26 PM 2. 13 Chief Deputy T . Richard W Stewart CUMBERLAND COUNyY Solicitor OFF110E OFF' OF TT E S-1-ER'F: PENNSYLVANIA Duetsche Bank National Trust Company vs. Case Number Steven A Ebersole (et al.) 2013-2917 SHERIFF'S RETURN OF SERVICE 05/23/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Steven A Ebersole, but was unable to locate the Defendant in the Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 05/23/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Tessa A Giacobbe-Ebersole, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 05/24/2013 04:44 PM- Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Steven A Ebersole, 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 1805 Creek View Court, Lower Allen, New Cumberland, PA 17070. Residence is vacant. 05/24/2013 04:44 PM- Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Tessa A Giacobbe-Ebersole, 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 1805 Creek View Court, Lower Allen, New Cumberland, PA 17070. Residence is vacant. 05/29/2013 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure returned by the Sheriff of Dauphin County, the within named Defendant Steven A Ebersole, not found. Jack Lotwick, Sheriff, Return of Service attached to and made part of the within record. 05/29/2013 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure returned by the Sheriff of Dauphin County, the within named Defendant Tessa A Giacobbe-Ebersole, not found. Jack Lotwick, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $102.21 SO ANSWERS, June 24, 2013 RbNW R ANDERSON, SHERIFF (c)CounrySuito Sheriff,Teleosoft,Inc, Shelley Ruhl Jack Duignan Real Esta a Deputy Chief Deputy Matthew L. Owens Michael W. Rinehart Solicitor Assistant Chief Deputy Dauphin County 101 Market Street Harrisburg,Pennsylvania 17101-2079 ph:(717)780-6590 fax:(717)255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania DEUTSCHE BANK NATIONAL TRUST COMPANY, ET AL VS County of Dauphin STEVEN A. EBERSOLE Sheriff s Return No. 2013-T-1628 OTHER COUNTY NO. 2013-2917 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for STEVEN A. EBERSOLE the DEFENDANT named in the within COMPLAINT IN MORTGAGE FORECLOSURE and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, MAY 29, 2013. DEFENDANT DOES NOT RESIDE AT ADDRESS 1700 MOUNTAIN VIEW ROAD, APT. 7, HARRISBURG, PA 17110. 5/31/13 - SENT POST OFFICE REQUEST 6/19/13 -NO RESPONSE FROM POST OFFICE. PAPERWORK ABOUT TO EXPIRE. Sworn and subscribed to So Answers,! o before me this 19TH day of June, 2013 Sheriff of a. By COMMONWEALTH OF PENNSYLVANIA Deputy Sheriff NOTARIAL SEAL Deputy: W CONWAY Karen M.Hoffman,Notary Public City of Harrisburg,Dauphin County Sheriffs Costs: $66.5 5/28/2013 My Commission Expires August 17,2014 .; f yf Shelley Ruh] Jack Duignan Real Esta a Deputy ?^ Chief Deputy Matthew L. Owens ® Michael W. Rinehart Solicitor Assistant Chief Deputy Dauphin County 101 Market Street Harrisburg,Pennsylvania 17101-2079 ph:(717)780-6590 fax:(717)255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania DEUTSCHE BANK NATIONAL TRUST COMPANY, ET AL VS County of Dauphin STEVEN A. EBERSOLE Sheriff s Return No. 2013-T-1628 OTHER COUNTY NO. 2013-2917 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for TESSA A. GIACOBBE-EBERSOLE the DEFENDANT named in the within COMPLAINT IN MORTGAGE FORECLOSURE and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, MAY 29, 2013. DEFENDANT DOES NOT RESIDE AT ADDRESS 1700 MOUNTAIN VIEW ROAD,APT. 7, HARRISBURG,PA 17110. 5/31/13 - SENT POST OFFICE REQUEST 6/19/1.3 -NO RESPONSE FROM POST OFFICE. PAPERWORK ABOUT TO EXPIRE. Sworn and subscribed to So Answers, before me this 19TH day of June, 2013 ,+ Sheriff of D hin Cou f By �- COMMONWEALTH OF PENNSYLVANIA D t h riff NOTARIAL SEAL Deputy: W CONWAY Karen M.Hoffman,Notary Public City of Harrisburg,Dauphin County Sheriffs Costs: $66.5 5/28/2013 M Commission Expires August 17,2014 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson E .c 3_i F f""- Sheriff ; , , ,.;, HE i° R,l t H,.PI'4..G Jody S Smith Chief Deputy LFj 13 JUL 26 AN 10: 31 ` . Richard W Stewart i UMBER~A0 COUM"i,t, Solicitor rl PENNSYLVANIA Duetsche Bank National Trust Company VS Case Number Steven A Ebersole(et al.) 2013-2917 SHERIFF'S RETURN OF SERVICE 07/05/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Steven A Ebersole, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 07/05/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Tessa A Giacobbe-Ebersole, but was unable to locate the Defendant in the Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 07/18/2013 03:08 PM-The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure served by the Sheriff of Dauphin County upon Steven Ebersole,who accepted for Tessa A Giacobbe-Ebersole, at 3233 Vista Lane, Harrisburg, PA 17110. Jack Lotwick, Sheriff, Return of Service attached to and made part of the within record. 07118/2013 03:08 PM-The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure served by the Sheriff of Dauphin County upon Steven A Ebersole, personally,,,at 3233 Vista Lane, Harrisburg, PA 17110. Jack Lotwick, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $53.46 SO ANSWERS, , July 24, 2013 RONW R ANDERSON, SHERIFF (c)CeuntySuite Sheriff,Teieescft,Inc. P t 1 Shelley Ruhl Jack Duignan Real Estate Deputy ? Chief Deputy Matthew L. Owens Michael W. Rinehart Solicitor Assistant Chief Deputy Dauphin County 101 Market Street Harrisburg,Pennsylvania 17101-2079 ph:(717)780-6590 fax:(717)255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania DEUTSCHE BANK NATIONAL TRUST COMPANY, ET AL VS County of Dauphin STEVEN A. EBERSOLE Sheriff s Return No. 2013-T-2045 OTHER COUNTY NO. 2013-2917 And now: JULY 18, 2013 at 3:08:00 PM served the within REINSTATED COMPLAINT IN MORTGAGE FORECLOSURE upon STEVEN A. EBERSOLE by personally handing to STEVEN A. EBERSOLE 1 true attested copy of the original REINSTATED COMPLAINT IN MORTGAGE FORECLOSURE and making known to him/her the contents thereof at 3233 VESTA LANE HARRISBURG PA 17110 Sworn and subscribed to So Answers, before me this 19TH day of July, 2013 Q l(— Sheriff of D phin Co , 0-�-0*2 By .- COMMONWEALTH OF PENNSYLVANIA D u heriff NOTARIAL SEAL Deputy: W CONWAY Karen M.Hoffman,Notary Public City of Harrisburg,Dauphin County Sheriffs Costs: $66.5 7/15/2013 My Commission Expires August 17,2014 • z Terr, ff Shelley Ruhl Jack Duignan Real Esta e Deputy ? Chief Deputy Matthew L. Owens Michael W. Rinehart Solicitor Assistant Chief Deputy Dauphin County 101 Market Street Harrisburg,Pennsylvania 17101-2079 ph:(717)780-6590 fax:(717)255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania DEUTSCHE BANK NATIONAL TRUST COMPANY, ET AL VS County of Dauphin STEVEN A. EBERSOLE Sheriff s Return No. 2013-T-2045 OTHER COUNTY NO. 2013-2917 And now: JULY 18, 2013 at 3:08:00 PM served the within REINSTATED COMPLAINT IN MORTGAGE FORECLOSURE upon TESSA A. GIACOBBE-EBERSOLE by personally handing to STEVEN EBERSOLE * 1 true attested copy of the original REINSTATED COMPLAINT IN MORTGAGE FORECLOSURE and making known to him/her the contents thereof at 3233 VESTA LANE HARRISBURG PA 17110 * SPOUSE OF DEFENDANT AND ADULT PERSON IN CHARGE AT TIME OF SERVICE. Sworn and subscribed to So Answers, i before me this 19TH day of July, 2013 Q�✓�'�� ��� Sheriff o in , Pa. B COMMONWEALTH OF PENNSYLVANIA eputy Sheriff NOTARIAL SEAL Deputy: W CONWAY Karen M.Hoffman,Notary Public City of Harrisburg,Dauphin County Sheriffs Costs: $66.5 7/15/2013 My Commission Expires August 17,2014 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 as Trustee for COURT OF COMMON PLEAS GSAMP Trust 2006-FM3,Mortgage Pass-Through CIVIL DIVISION c—) --n Certificates, Series 2006-FM3 Cumberland County 1661 Worthington Road,Suite 100 �cx� �c West Palm Beach,FL 33409 MORTGAGE FORECLOSL —{ rn Plaintiff C)1. V. i—�" STEVEN A.EBERSOLE NO. 13-2917 Civil o 3233 VESTA LANE E HARRISBURG,PA 17110 v" , TESSA A. GIACOBBE-EBERSOLE 3233 VESTA LANE HARRISBURG,PA 17110 Defendant(s) 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), STEVEN A.EBERSOLE; TESSA A. GIACOBBE-EBERSOLE; 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 Plaintiffs damages as follows: FROM TO Unpaid Principal Balance $133,436.44 Interest Per Complaint $33,875.29 Additional Interest 04/26/2013 10/03/2013 $4,588.50 Late Charges Per Complaint $1,212.02 Additional Late Charges 04/26/2013 10/03/2013 $303.05 Escrow Per Complaint $12,226.81 Title Report $300.00 Attorney Fee $1,650.00 Property Valuation Fee-BPO $1,168.00 Property Inspection Fee $94.50 Prior Servicer Fee $1,278.00 Grand Total $190,132.61 1 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. UDRjjE LAW OFFICES, P.C. BY:4 HARRY B.,REESE ,ESQUIRE Att �T_; "f ID 310501 DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE: 1 0 10 —PRO.,PR MJU#: 11120774 CASE#: 11120774-1 - Transfer new Slog 3S � aq tpu,7 '�fn�vP n1a.� MAY/22/2013/WED 01 : 13 PM FAX No. 7172406573 P. 005 UDREN LAW OFFICES,P.C., ATTORNEY FOR PLAINTIFF BY:MARK J.UDREN,ESQUIRE-ID#04302 STUART WINNEG,ESQUIRE-ID#45362 LORRAINE GAZZARA DOYLE,ESQUIRE-ID#34576 SHERRI J.BRAUNSTEIN,ESQUIRE-ID1M675 ` SALVATORE CAROLLO,ESQUIRE-ID#311050 HARRY B.REESE ESQUIRE-ID#310501 ELIZABETH L.WASSALL,ESQUIRE-ID477788 KATHERINE E.KNOWLTON,ESQUIRE-ID#311713 r JOHN ERIC KISHBAUGH,ESQUIRE-ID#33078 NICOLE B.LABLETTA,ESQUIRE-ID4202194 DAVID NEEREN,ESQUIRE-ID#204252 c-) JORDAN DAVID,ESQUIRE- #311968 a 110311968 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadings@)udnen.com Deutsche Bank National Trust Company COURT OF COMMON PLEAS as Trustee for GSAMP Trust 2006-FM3, CIVIL DIVISION Mortgage Pass-Through Certificates, CUMBERLAND County Series 2006-FM3 C/O Ocwen Loan Servicing,LLC 2 V 1661 Worthington Road NO. J ' Suite 100 West Palm Beach,FL 33409 Plaintiff .. _... .... ..... .. V. STEVEN A.EBERSOLE 1805 CREEK VIEW CT NEW CUMBERLAND,PA 17070 TESSA A.GIACOBBE-EBERSOLE 1805 CREEK VIEW CT NEW CUMBERLAND,PA 17070 Defendant(s) 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 quA aA Verbal Confirmation of Service of Complaint Date: July 22, 2013 Spoke with: Kim @ Dauphin Countv Sheriff's Office Defendant(s): Steven A. Ebersole Q Served: 7/18/13 at: 3233 Vesta Lane, Harrisburg, PA 17110 Notes: Personal Defendant(s): Tessa A. Giacobbe-Ebersole Q Served: 7/18/13 at: 3233 Vesta Lane, Harrisburg, PA 17110 Notes: Service accepted by the Adult in Charge—Husband Steven Are there any additional fees due? No If so, how much? $ UDREN LAW OFFICES P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Company as COURT OF COMMON PLEAS Trustee for GSAMP Trust 2006-FM3, CIVIL DIVISION Mortgage Pass-Through Certificates,Series Cumberland County 2006-FM3 Plaintiff MORTGAGE FORECLOSURE V. Steven A.Ebersole,Tessa A. Giacobbe- NO. 13-2917 Civil Ebersole Defendant(s) TO: Steven A.Ebersole 3233 Vesta Lane Harrisburg,PA 17110 Date of Notice: September 17,2013 ! 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 i i NOTIFICACION IMPORTANTE USTED 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 NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA,USTED PUEDE PERDER BIENES Y OTROS DERECHOS,IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO t D AMEDIATAMENTE 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 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. UDREN LAW OF ICES,PC. BY:- I i� ey r aintiff HARRY B. RE E, ES I'IRE Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill,New Jersey 08003-3620 MJU#: 11120774 CASE#: 11120774-1...-.Transfer UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 Deutsche Bank National Trust Company as COURT OF COMMON PLEAS Trustee for GSAMP Trust 2006-FM3, CIVIL DIVISION Mortgage Pass-Through Certificates,Series Cumberland County 2006-FM3 Plaintiff MORTGAGE FORECLOSURE V. i Steven A.Ebersole,Tessa A.Giacobbe- NO. 13-2917 Civil Ebersole Defendant(s) TO: Tessa A.Giacobbe-Ebersole 3233 Vesta Lane Harrisburg,PA 17110 Date of Notice: September 17,2013 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 IM[PORTANTE USTED 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 NECESIDAD DE COMPAR.ARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA.EN SU CONTRA,USTED PUEDE PERDER BIENES Y OTROS DERECHOS, DOORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO BCvfEEDIATAMENTE SI USTED NO TIENE ABOGA.DO,O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO,VAYA EN PERSONA O LLAh1E POR TELEFONO A LA OFICINA,CUYA. DIRECCION SE ENCUENTR.A ESCRITA ABAJO PARA 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. UDREN LAW OF ICES,PC. BY: V, %homey for aintiff HARRY B. ESE, EWIRE Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill,New Jersey 08003-3620 MJU#: 11120774 CASE#: 11120774-1 -Transfer Pennsylvania Office UDRENLAW OFFICES, l .C. Florida Office 100 W.3rd Ave. 2101 W.Commercial Blvd Suite 200 New Jersey Office suite 5100 Conshohocken,PA 19428 WoodcreSf Corporate Center Fort Lauderdale,FL 33309 (PH) 215-568-9500 (PH) 954-378-1757 Markf.Udren,Fsq. 111 Woo crest Rd. Licensed.•PA,N PL Suite 200 (FX) 954-378-1758 Cherry Hill? NJ 08003 (PH)856-669-5400 (FX)856-669-5399 www.udren.com Prothonotary of Cumberland County One Courthouse Square Carlisle,PA 17013 Re: Deutsche Bank National Trust Company as Trustee for GSAMP Trust 2006-FM3,Mortgage Pass-Through Certificates,Series 2006-FM3 vs. STEVEN A.EBERSOLE,TESSA A. GIACOBBE-EBERSOLE, Cumberland County C.C.P.No. 13-2917 Civil MJU#: 11120774 CASE#: 11120774-1 -Transfer Dear Sir or Madam: Enclosed please find Affidavit of Non-Military Service for the above captioned matter. I have also enclosed a copy of the Affidavit of Non-Military Service to be time stamped and returned in the enclosed self-addressed stamped envelope. Thank you for your assistance in this matter. Sincerely yours, Alexandria Carr Foreclosure Specialist MTU/ Enclosures MJU#: 11120774 CASE#: 11120774-1-Transfer 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 COURT OF COMMON PLEAS Deutsche Bank National Trust Company as CIVIL DIVISION Trustee for GSAMP Trust 2006-FM3, Cumberland County Mortgage Pass-Through Certificates, Series 2006-FM3 MORTGAGE FORECLOSURE Plaintiff V. NO. 13-2917 Civil STEVEN A.EBERSOLE,TESSA A. GIACOBBE-EBERSOLE, Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE UNDER Pa.R.C.P 76 THE UNDERSIGNED states based upon a search of the Department of Defense Manpower Data Center for the Defendant(s),that the Defendant(s), STEVEN A.EBERSOLE,TESSA A. GIACOBBE- EBERSOLE,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 "All 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. Dated: October 3,2013 Attoto bi Phi/tiff HARRY S.R SE,ESQUIRE W 310501 MJU#: 11120774 CASE#: 11120774-1-Transfer Department of Defense Manpower Data Center Results as of:Oct-03-2013 0930:55 SCRA 3.4 Sta Report Pumuant to Servicemembers Civil Relief Act Last Name: EBERSOLE First Name: STEVEN Middle Name: A Active Duty Status As Of: Oct-03-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status - Service Component NA NA - o, NA AVO .✓ "_t;+',7:f.t"W ?^yam. This response reflects. a rndrvtdu5ls'act(ve6ty #.tu3`6asad on ff+eActva Duty'Status Data Left Active Duty Within 3 67 Days of Active Duty Status Date Active Duty Start Date Active}Duty End Date Status Service Component NAt!NA�''1 •E �4. r""" "�"NJa ',` J'4t NA i/ Ili .A . .^.:_--.-"�r"I—' �y y� This response reflects Wharrd he,indr dual left active dutyislatus within 36i.'days ptocoding thd,AC kr Duty Status Data The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NAA � NA This response recs whether tted e report for active duty Upon searching the data banks of the Department of Defense ManpowerData=Center,=b;'sed 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. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 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.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 left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAH 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/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: H4B5274DL005FFO ' Department of Defense Manpower Data Center Results as of:Oct-03-2013 09:33:54 SCRA 3.0 'i Staffs Reps Pursuant to Serv':cementbers Civil Relief Act. Last Name: GIACOBBE-EBERSOLE First Name: TESSA Middle Name: A Active Duty Status As Of: Oct-03-2013 On Active Duty On Active Duty Status Date Active Duty Start Dale Active Duty End �rDaattee p Status Service Component NA NA 'N . NA 1/�w This response reflects'the and tl a`IS'adlve d''Ory StSfu§!based on the_Actl elD.d4'tmtatus Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status i�`` 11 �.,�e �t � Service Component NA OVI NA '�,3.� .�•�l „ f7+=- N iR� NA This response reflects Where the Individual left adive_duty!status wlthle 36a;tlays preceding the 'ctive,'Dury Status Date r The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA�/�r_•� "�NO_��/ NA This response reflects whether the indict ual or hislher unit has Tci i!d y notification to report for active duty .._ .mot Upon searching the data banks of the Department of Defense Manpower rData-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. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. 7 Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 at seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:hftp://www.defenselink.mil/faq/pis/PC09SLDR.htmi. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARS),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: N4X8K7CD10C6QD0 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 as COURT OF COMMON PLEAS Trustee for GSAMP Trust 2006-FM3, CIVIL DIVISION Mortgage Pass-Through Certificates, Cumberland County Series 2006-FM3 Plaintiff MORTGAGE FORECLOSURE V. C__ C=P Steven A.Ebersole NO. 13-2917 Civil ;r- Tessa A. Giacobbe-Ebersole Q C-) f�_ r1i­4 C) Defendant(s) PRAECIPE TO ISSUE WRIT OF EXECUTION cc 21 Z5 -� TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due $ 190,132.61 Interest From 10/4/2013 $ 4,360.50 to Date of Sale March 5,2013 Ongoing Per Diem of$28.50 to actual date of sale including if sale is held at a later date (Costs to be added) $ LUDREN LAW OFFICES,P.C. IS BY: Atto e or mtiff OF A B.-REESE SQU. pliAAR PAID 3 501 u (>�. -? 5 1, MJU#: 11120774 CASE#: 11120774-1 -Transfer U4 E, UDREN LAW OFFICES, P.C. CD F ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENT, 111 WOODCREST ROAD, SUITE 2gfOCT ' 10 10 CHERRY HILL,NJ 08003-3620 CUMBERLAND COUNTY 856-669-5400 pleadings@udren.com Deutsche Bank National Trust Company as COURT OF COMMON PLEAS Trustee for GSAMP Trust 2006-FM3, CIVIL DIVISION Mortgage Pass-Through Certificates, Cumberland County Series 2006-FM3 Plaintiff MORTGAGE FORECLOSURE V. Steven A. Ebersole NO. 13-2917 Civil Tessa A. Giacobbe-Ebersole Defendant(s) CERTIFICATE OF ACT 91 I hereby state that as the attorney for the Plaintiff in the above-captioned matter: M Act 91 procedures have been fulfilled f� Premises is not subject to the provisions of Act 91 as this is an FHA insured mortgage This statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES,P.C. toAaky Mr Plaintiff . HARRY B_REE:S1 E,V UIRE PAZ 310 1 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 ipleadings(a-),udren.com Deutsche Bank National Trust Company as COURT OF COMMON PLEAS C= Trustee for GSAMP Trust 2006-FM3, CIVIL DIVISION I =nj W Mortgage Pass-Through Certificates, Cumberland County MM C-)C=1 Series 2006-FM3 Plaintiff MORTGAGE FORECLOSURE V. C=1 =7- C:) Steven A. Ebersole NO. 13-2917 Civil C-) =C =Z= =C') 25 C) Tessa A. Giacobbe-Ebersole 5;c= Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 Deutsche Bank National Trust Company as Trustee for GSAMP Trust 2006-FM3,Mortgage Pass- Through Certificates, Series 2006-FM3,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: 1805 Creekview Ct,New Cumberland, PA 17070 1. Name and address of Owner(s) or reputed Owner(s): Steven A. Ebersole 3233 Vesta Lane Harrisburg,PA 17110 Tessa A. Giacobbe-Ebersole 3233 Vesta Lane Harrisburg, PA 17110 2. Name and address of Defendant(s) in the judgment: Steven A. Ebersole 3233 Vesta Lane Harrisburg, PA 17110 Tessa A. Giacobbe-Ebersole 3233 Vesta Lane Harrisburg,PA 17110 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 2006-FM3,Mortgage Pass- Through Certificates, Series 2006-FM3 1661 Worthington Road, Suite 100 West Palm Beach,FL 33409 Allfirst Bank 25 South Charles Street Baltimore,MD 21201 Mortgage Electronic Registration Systems,Inc., as nominee for Fremont Investment& Loan P.O. 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 Real Estate Tax Department 1 Courthouse Square Carlisle,PA 17013 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Commonwealth of PA,Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg,PA 17128-1230 Tenants/Occupants 1805 Creekview Ct Cumberland, PA 17070 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 Beacon Hill Heights Address to Follow 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 unswom falsification to authorities. DATED: V3 UDRE LAW OF ICES, P.C. BY: _ AttcVieVorVnti f HARRY S. SE,fsQUIRE' MJU#: 11120774 CASE#: 11120774-1 -Transfer P D 310501 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER Ill WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 _4 pleadings@,.udren.com -0 C:) r.1 Deutsche Bank National Trust Company as COURT OF COMMON PLEAS rn Trustee for GSAMP Trust 2006-FM3, CIVIL DIVISIONS C) -4 Mortgage Pass-Through Certificates, Cumberland County Series 2006-FM3 C" Plaintiff MORTGAGE FORECLOSURE C_ v. STEVEN A.EBERSOLE,TESSA A. NO. 13-2917 Civil GIACOBBE-EBERSOLE Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Steven A.Ebersole 3233 Vesta Lane Harrisburg, PA 17110 Your house (real estate) at 1805 Creekview Ct,New Cumberland, PA 17070 is scheduled to be sold at the Sheriffs Sale on March 5, 2014 at 10:00am at the Cumberland County Courthouse, Commissioners Hearing Room,2nd Floor, Carlisle, PA 17013, to enforce the court judgment of$190,132.61, 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)664-5400. 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 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 j2leadin&s@lLdren.com Deutsche Bank National Trust Company as COURT OF COMMON PLEAS C. Trustee for GSAMP Trust 2006-FM3, CIVIL DIVISION C-> C= Mortgage Pass-Through Certificates, Cumberland County -O:c Series 2006-FM3 rrAcO Plaintiff MORTGAGE FORECLOSURE V. STEVEN A.EBERSOLE,TESSA A. NO. 13-2917 Civil GIACOBBE-EBERSOLE Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Tessa A. Giacobbe-Ebersole 3233 Vesta Lane Harrisburg, PA 17110 Your house(real estate) at 1805 Creekview Ct,New Cumberland, PA 17070 is scheduled to be sold at the Sheriffs Sale on March 5, 2014 at 10:00am at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle,PA 17013,to enforce the court judgment of$190,132.61, 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: I. 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 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-2917 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 2006-FM3,MORTGAGE PASS-THROUGH CERTIFICATES,SERIES 2006-FM3 Plaintiff(s) From STEVEN A.EBERSOLE,TESSA A. GIACOBBE-EBERSOLE (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 GARNISHEES)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: $190,132.61 L.L.:$.50 Interest FROM 10/4/2013 TO DATE OF SALE MARCH 5,2013-ONGOING PER DIEM OF$28.50 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE Atty's Comm: Due Prothy:$2.25 Atty Paid: $418.38 Other Costs: Plaintiff Paid: Date: 10110/13 David D.Buell,Prothonotary (Seal) Deputy C REQUESTING PARTY: Name: HARRY B.REESE,ESQUIRE Address:UDREN LAW OFFICES,P.C. WOODCREST CORPORATE CENTER I 11 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 Attorney for:PLAINTIFF Telephone:856-669-5400 Supreme Court ID No.310501 UDREN LAW OFFICES, P.C. 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 as Trustee for GSAMP Trust 2006 -FM3, Mortgage Pass - Through Certificates, Series 2006 -FM3 Plaintiff v. STEVEN A. EBERSOLE, TESSA A. GIACOBBE - EBERSOLE, Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County c_) °•' Cr. MORTGAGE FORECLOSURE C.0 P c� = AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 v c.r. NO. 13 -2917 Civil Plaintiff, by its/his/her Attorney hereby verifies that: 1. A copy of the Notice of Sheriffs Sale, a true and correct copy of which is attached hereto as Exhibit "A ", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriffs Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B ". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B ". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B ". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. 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: ' 1" - UDRE MJU #: 11120774 CASE #: 11120774 -1 LAW OFFICES, P.C. BY: • Atto t" eys or Plaintiff HARRY B. RE PA I ESQUIRE 310501 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 eadin s udren.com Deutsche Bank National Trust Company as Trustee for GSAMP Trust 2006-FM3, Mortgage Pass-Through Certificates, Series 2006-FM3 Plaintiff v. Steven A. Ebersole Tessa A. Giacobbe-Ebersole Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-2917 Civil AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 Deutsche Bank National Trust Company as Trustee for GSAMP Trust 2006-FM3, Mortgage Pass-Through Certificates, Series 2006-FM3, 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: 1805 Creekview Ct, New Cumberland, PA 17070 I. Name and address of Owner(s) or reputed Owner(s): Steven A. Ebersole 3233 Vesta Lane Harrisburg, PA 17110 Tessa A. Giacobbe-Ebersole 3233 Vesta Lane Harrisburg, PA 17110 2. Name and address of Defendant(s) in the judgment: Steven A. Ebersole 3233 Vesta Lane Harrisburg, PA 17110 Tessa A. Giacobbe-Ebersole 3233 Vesta Lane Harrisburg, PA 17110 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 2006 -FM3, Mortgage Pass - Through Certificates, Series 2006 -FM3 1661 Worthington Road Suite 100 West Palm Beach, FL 33409 Allfirst Bank 25 South Charles Street Baltimore, MD 21201 Mortgage Electronic Registration Syste Loan P.O. Box 2026 Flint, MI 48501 -2026 Inc., as nominee for Fremont Investment & 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 Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128 -1230 Tenants /Occupants 1805 Creekview Ct Cumberland, PA 17070 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 The Heights at Beacon Hill 1271 Yarmouth Lane (Homesite 178) New Cumberland, PA 17070 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: 1 r MJU#: 11120774 CASE#: 11120774-1 - Transfer UDREN LAW OFFICES, P.C. BY Att s ey or Pla,Inti HARRY VREESE, ESQUIRE ,,PA ID 310501 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 2006 -FM3, Mortgage Pass- Through Certificates, Series 2006 -FM3 Plaintiff v. STEVEN A. EBERSOLE TESSA A. GIACOBBE - EBERSOLE Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13 -2917 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY, TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S): STEVEN A. EBERSOLE AND TESSA A. GIACOBBE - EBERSOLE PROPERTY: 1805 Creekview Court, New Cumberland, PA 17070 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on March 12, 2014 at 10:00 AM, at the Cumberland County Courthouse, Commissioners Hearing Room, 2 °a Floor, Carlisle, PA 17013. Our records indicate that you may hold a mortgage or judgment on the property, which will be extinguished by the sale. You may wish to attend the sale to protect your interests. The Sheriff will file a Schedule of Distribution on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. MJU #: 11120774 CASE #: 11120774 -1 En'hit'a Name and Address of Sender Henrietta Crommarty UDREN LAW OFFICES, P.C. 111 Woodcrest Road, Suite 200 Cher Hill, NJ 08003 ri Registered Insured Ell COD 0 Certified 0 Return Receipt for Merchandise F7 Intl Re0orded Del. 0 Express ' Check appropriate block for Registered Mail: Postal Insurance lhout postal Insurance Affix stamp here if issued as s certificate of mailing or for additional copies of this bill. Postmark and Date of Recei.t Art'cle Number Name of Addressee, Street, and Post Office Address Postage Handling Charge Act. Value If Re is. Insured Value Due R.R. S.D. S.H. Sender Remarks If COD Fee Fee Fee 11111111111111.11 MEE 1 Cumberland County Real Estate Tax Department 1 Courthouse Square, Carlisle, PA 17013 Cumberland County Domestic Relations Section 13 North Hanover Street, Carlisle, PA 17013 IIIII 3 Commonwealth of Penna, Department of Revenue Bureau of Compliance, P.O. Box 281230 Harrisburg, PA 17128-1230 4 13-2917 Tenants/Occupants 1805 Creekview Court, New Cumberland, PA 17070 11111111111M1111111 Allfirst Bank 25 South Charles Street, Baltimore, MD 21201 MEI 6 03/12/2014 MERS Inc. as nominee for Fremont Investment Loan P.O. Box 2026, Flint, MI 48501-2028 Ewa IllaaIIIIIII 11111.1111111511 8 11.111111111111111111 111111111111C4141 MINEMI . III-I 9 10 11 .111.11111111...1.11.1 .11111111111.11.11111/1111 ILEIMINIMIONI 13 14 .1.11.1111111 11111111/1/11/ REIMMEMMI Total number of Pieces Listed by Sender Total Number Received of Pieces at Post Office Postmaster, Per (Name of Receiving Employee) The full declaration of value is required on all domestic and international registered mail. The maximum indemnity payable for the reconstruction of nonnegotiable documen s under Express Mail document reconstruction insurance is $50,000 per piece subject to a limit of $500,000 per occurrence. The maXimum indemnity payable on Express Mail merchandise is $500. The maximum indemnity payab e is $25,000 for registered mail, sent with optional postal inpurance. See Domestic Mail Manua R900, S913, and S921 for limitations of coverage on insured and COD mail. See International Mail Manual for limitations of coverage on international mail. Special handling charges apply only to third and fprth class parcels. 6 'w I PS Form 3877, February 1994 Form Must be Completed by Typewriter, Ink or Ball Point Pen Steven A. Ebersole - MJU# 11120774-1 (Cumberland County) Tess A. Giacobbe-Ebersole — MJU #11120774-1 (Cumberland County) Name and Address of Sender Henrietta Crommarty UDREN LAW OFFICES, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 0 Registered El Insured El COD ri Certified 1-1 L j Retum Receipt for Merchandise El Int'l Recorded Del. r7 Express Mail Check appropriate block for Registered Mail: 0 With Postal Insurance 0 Without postal Insurance Affix stamp here if issued as certificate of mailing or for additional copies of this bill. Postmark and Date of Receipt Line Article Number Name of Addressee, Street, and Post Office Address Postage Fee Hand ing Charge Act. Value . (If Regis.) Insured Value Due Sender If COD R.R. Fee S.D. Fee S.H. Fee Rst. Del. Fee Remarks 1 13-2917 The Heights at Beacon Hill 1271 Yarmouth Lane (Homesite 178) New Cumberland, PA 17070 2 3 04/09/2014 4 5 6 7 9 10 _11 12 13 14 15 ..„aifillai. Total number of Pieces Listed by Sender 1 otalNumber Rece f Pieces ved a Pos Office Postmaster, ' - r ..e )Vame of Receiving Employee) The full declaration of value is required on all domestic and international registered mail. The maximum indemnity payable for the reconstruction of nonnegotiable documents under Express Mail document reconstruction insurance is $50,000 per piece subject to a limit of $500,000 per occurrence. The maximum indemnity payable on Express Mail merchandise is 5500. The maximum indemnity payable is 525,000 for registered niail, sent with optional postal insurance. See Domestic Mail Manual R900, S913, and S921 for limitations of coverage on insured and COD mail. See International Mail Manual for limitations of coverage on international mail. Special handling charges apply only to third and forth class parcels. VA PS Form 3877, February '94 Form Must be Completed by Typewriter, Ink or Ball Point Pen Steven A. Ebersole - MJU# 11120774-1 (Cumberland County) Tessa A. Giacobbe-Ebersole - MJU# 11120774-1 (Cumberland County) Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY Duetsche Bank National Trust Company vs. Steven A Ebersole (et al.) Case Number 2013 -2917 SHERIFF'S RETURN OF SERVICE 12/12/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Steven A. Ebersole, but was unable to locate the Defendant in his bailiwick. He therefore deputized the Sheriff of Dauphin County to serve the within Real Estate Writ, Notice and Description, in the above titled action, according to law. 12/12/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Tessa A. Giacobbe - Ebersole, but was unable to locate the Defendant in his bailiwick. He therefore deputized the Sheriff of Dauphin County to serve the within Real Estate Writ, Notice and Description, in the above titled action, according to law. 01/09/2014 01:06 PM - Deputy Dennis Fry, 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 1805 Creekview Court, Lower Allen - Township, New Cumberland, PA 17070, Cumberland County. 01/30/2014 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff of Dauphin County upon Steven A. Ebersole, AIC who accepted for Tessa A. Giacobbe - Ebersole, at 3233 Vesta Lane, Harrisburg, PA 17110. So Answers: W. Conway, Deputy Sheriff. 01/30/2014 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff of Dauphin County upon Steven A. Ebersole, personally, at 3233 Vesta Lane, Harrisburg, PA 17110. So Answers: W. Conway, Deputy Sheriff. SHERIFF COST: $1,048.71 SO ANSWERS, January 30, 2014 RONK? R ANDERSON, SHERIFF EISIcoit [� (c) CountySuite Sheriff, Telecsoft, In . SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff of , raf�r Jody S Smith Chief Deputy I r Richard W Stewart , Solicitor Ea�t;rr°Y'L }r fli ids itit+ Duetsche Bank National Trust Company Case Number vs. 2013-2917 Steven A Ebersole (et al.) SHERIFF'S RETURN OF SERVICE 12/12/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Steven A. Ebersole, but was unable to locate the Defendant in his bailiwick. He therefore deputized the Sheriff of Dauphin County to serve the within Real Estate Writ, Notice and Description, in the above titled action, according to law. 12/12/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Tessa A. Giacobbe-Ebersole, but was unable to locate the Defendant in his bailiwick. He therefore deputized the Sheriff of Dauphin County to serve the within Real Estate Writ, Notice and Description, in the above titled action, according to law. 01/09/2014 01:06 PM - Deputy Dennis Fry, 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 1805 Creekview Court, Lower Allen -Township, New Cumberland, PA 17070, Cumberland County. 01/30/2014 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff of Dauphin County upon Steven A. Ebersole,AIC who accepted for Tessa A. Giacobbe-Ebersole, at 3233 Vesta Lane, Harrisburg, PA 17110. So Answers: W. Conway, Deputy Sheriff. 01/30/2014 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff of Dauphin County upon Steven A. Ebersole, personally, at 3233 Vesta Lane, Harrisburg, PA 17110. So Answers: W. Conway, Deputy Sheriff. 03/06/2014 As directed by Mark Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 4/9/2014 04/09/2014 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, PA 17013, on April 9, 2014 at 10:00 a.m. He sold the same for the sum of$1.00 to Attorney Mark Udren, on behalf of Deutsche Bank National Trust Company as Trustee for GSAMP Trust 2006-FM3, Mortgage Pass-Through Certificates, Series 2006-FM3, being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $900.22 SO ANSWERS, May 13, 2014 RbNW R ANDERSON, SHERIFF On December 11, 2013 the Sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA, Known and numbered as, 1805 Creekview Court, New Cumberland, as Exhibit "A" filed with this writ and by - c- this Reference incorporated herein. C) Q -- Date: December 11, 2013 By: Real Estate Coordinator LXIII 4 CUMBERLAND LAW JOURNAL 01/24/14 Writ No. 2013-2917 Civil Term Duetsche Bank National Trust Company vs. Steven A. Ebersole Tessa A. Giacobbe-Ebersole Atty.: Mark Udren ALL THAT CERTAIN LOT OF LAND SITUATE IN TOWNSHIP OF LOWER ALLEN, CUMBERLAND COUNTY, PENNSYLVANIA: BEING KNOWN AS 1805 Creekview Ct, New Cumberland, PA 17070. PARCEL NUMBER: 13-25-0010- 294. IMPROVEMENTS: Residential Property. 30 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 24, January 31, and February 7, 2014 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. isa Marie Coyne, Edit4r SWORN TO AND SUBSCRIBED before me this 7 day of February, 2014 Notary NOIAFIAL S'.AL DE_I'll GFiAN`A COLLINS t-,teCy Public CARLISLE S09,�CUGH,CUM3ERLAND COUNTY 1 try Ca�x�r�i'si r�Lxpires Apr 2 3.2014 a The Patriot-News Co. + 2020 Technology Pkwy Patr1ot*'X1tW5 Suite 300 Mechanicsburg, PA 17050 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 the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania,with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317. 2013-2917 Civil Term This ad ran on the date(s)shown below: Duetsche Bank National 01/19/14 Trust Company VS 01/26/14 Stevert A Ebefsole Tessa AGlacobbe- < 02/02/14 Ebersole Aftyr Mark Udren �. . . . . . ... . . . . . . . . . . . . . . . . . ALL THAT CERTAIN LOT OF LAND SITUATE IN TOWNSHIP OF Sworn an s bscribed before this 18 day of February, 2014 A.D. LOWER ALLEN,CUMBERLAND COUNTY,PENNSYLVANIA: BEING KNOWN AS 1805 Creekview Ct,New Cumberland,PA 17070 PARCEL NUMBER:13-25-0010-294 V Public IMPROVEMENTS: Residential Property Wr,t L •i rip per4Ntc.Yt.VAI IA MEWS R,✓Eaylba as?L: .y , COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Deutsch Bank National Trust Company as Trustee for GSAMP Trust 2006-FM3 Mortgage Pass-Through Certificates Series 2006-FM3 is the grantee the same having been sold to said grantee on the 9th day of April A.D., 2014,under and by virtue of a writ Execution issued on the 10th day of October, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 2917, at the suit of Deutsche Bank National Trust Company as Trustee for GSAMP Trust 2006- FM3 Mortgage Pass-Through Certificates Series 2006-FM3 against Steven A. Ebersole and Tessa A. Giacobbe-Ebersole is duly recorded as Instrument Number 201413641. IN TESTIMONY WHEREOF, I have hereunto set my hand a seal of said office this day of A.D. & //7( Recorder of Deeds cwnkeriew coway,Cwft,PA Expires the Fast Monday of Jan.2018