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Home My WebLink About13-3429 Supreme Court of Pennsylvania ./ Coa ,,.p�rro Common -leas rCivil Cover S ' t, For Prothonotary Use Only: CU1I ERL County Docket No: L �• / i The information collected on this form is used solely for court administration purposes. This form does not supplement or replace thefiligg and service ofpleadings or other papers as required by law or rules of court. Commencement of Action: ❑O Complaint ❑ Writ of Summons ❑ Petition S ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking E Lead Plaintiffs Name: Lead Defendant's Name: C DEUTSCHE BANK TRUST COMPANY ANTHONY CENTURIONE, JR or Occupants T AMERICAS, AS TRUSTEE FOR RESIDENTIAL I ACCREDIT LOANS, INC. L 2006- S17 O Name of Plaintiff /Appellant's Attorney: Phelan Hallinan, LLP N A ❑ Check here if you have no attorney are a Self-Represented Pro Sel Litigant Are money damages requested? : ❑ Yes dN0 Dollar Amount Requested: ❑ within arbitration limits (Check one) ❑ outside arbitration limits Is this a Class Action Suit? ❑ Yes [ItTIO Is this an MDJ Appeal? ❑ Yes EgNo 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 CIVIL APPEALS ❑ Intentional Judgments) Administrative Agencies ❑ Malicious Prosecution ❑ Buyer Plaintiff ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Credit Card ❑ Board of Elections ❑ Nuisance ❑ Debt Collection: Other ❑ Dept. of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other ❑ Product Liability (does not include mass tort) ❑ Slander/Libel/ Defamation ❑ Employment Dispute: S ❑ Other: Discrimination ❑ Zoning Board E ❑ Employment Dispute: Other ❑ Other: C T I MASS TORT O ❑ Asbestos ❑ Other: N ❑ Tobacco ❑ Toxic Tort - DES B ❑ Toxic Tort - Implant ❑ Toxic Waste RE L PROPERTY MISCELLANEOUS ❑ Other: [Ejectment ❑ Common Law /Statutory Arbitration ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations PROFESSIONAL LIABLITY ❑ Mortgage Foreclosure Residential Restraining Order • Dental ❑ Mortgage Foreclosure Commercial ❑ Quo Warranto • Legal ❑ Partition ❑ Replevin • Medical ❑ Quiet Title ❑ Other: • Other Professional: ❑ Other: Pa.R.C.P. 205.5 Updated 1/1/2011 Phelan Hallinan, LLP By: Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff n 1617 JFK Boulevard, Suite 1400 C One Penn Center Plaza 0 Philadelphia, PA 19103 rn _ -^ rrt 215 - 563 -7000 DEUTSCHE BANK TRUST COMPANY Court of Common Pleas AMERICAS, AS TRUSTEE FOR RESIDENTIAL G Z5 ACCREDIT LOANS, INC. (R.ALI) 2006 -QS 17 Civil Division p �? p 1100 VIRGINIA DRIVE, P.O. BOX 8300 FORT WASHINGTON, PA 19034 CUMBERLAND County Plaintiff � � - � 1 //,) V. No. ANTHONY CENTURIONE, JR or Occupants 142 15TH STREET UNIT G AWA 142 G 15TH STREET NEW CUMBERLAND, PA 17070 -1178 Defendant CIVIL ACTION — EJECTMENT "This firm is a debt collector attempting to collect a debt and any information obtained will be used for that purpose. If you have previously received a discharge in bankruptcy and this debt was not reaffirmed, this correspondence is not and should not be construed to be an attempt to collect a debt, but only enforcement of a lien against property. NOTICE 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 (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for and 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 or cannot afford one, go to or telephone the office set forth below to find out where you can get legal help. If you cannot afford to hire a lawyer, this office may be able to provide you with information about agencies that may offer legal services to eligible persons at a reduced fee or no fee. Cumberland County Cumberland County Bar Association 32 South Bedford Street ' Carlisle, PA 17013 (717) 249 -3166 7 ) PHS # 319104 o Cy � 'a CH L' Plaintiff is DEUTSCHE BANK TRUST COMPANY AMERICAS, AS TRUSTEE FOR RESIDENTIAL ACCREDIT LOANS, INC. (RALI) 2006 -QS17. 2. Defendant is ANTHONY CENTURIONE, JR or Occupants. 3. Plaintiff is the record owner of premises located at 142 15TH STREET UNIT G, A/K/A 142 G 15TH STREET, NEW CUMBERLAND, PA 17070 -1178, the legal is contained within the Sheriff's deed. 4. Plaintiff became the owner of said premises as a result of the foreclosure and judicial sale by the Sheriff of CUMBERLAND County, on 03/06/2013, as evidenced by the Sheriffs deed recorded 05/22/2013 in the Office of the Recorder of CUMBERLAND County in 201316841, a true and correct copy of which is attached hereto, made party hereof, and marked as Exhibit "A ". 5. Plaintiff, by virtue of the above, is the record owner of said premises, and is entitled to possession thereof. The defendant is occupying the said premises without right and so far as the plaintiff is informed, without claim of title. 6. Plaintiff has demanded possession of the said premises from the said defendant who has refused to deliver up possession of same. WHEREFORE, Plaintiff seeks to recover possession of the Premises. Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff Phelan Hallinan, LLP EXHIBIT "A" PHS # 319104 a02Yoo Tax Parcel No. 26-23- 0541 -218A- U7---- Know all Men by these Presents That I, Ronny R. Anderson, Sheriff of the County of Cumberland, In the State of Pennsylvania, for and in consideration of the sum of $1.00 (One Dollar) to me; n hand paid, do hereby grant and convey Deutsche Bank Trust Company Americas, as Trustee for Residential Accredit Loans, Inc. (BALI) 2006 -QS17 Writ No. 2009 -398 Civil Term Deutsche Bank Trust Company Americas as Trustee for Rali 2006QS17 Vs Anthony L. Centurione, Sr., A/K/A Anthony L. Centurione ALL T14AT CERTAIN unit in the properly known, named and identified in the declaration referred to below as'Cumberland Crossings Condominium; located in New Cumberland Borough, Cumberland County, pennsylvania, which has heret.orore been submined to the provisions of (he Uniform Condominium Act, 68 Pa. C.S.A. 3101 by the recording in the Office of the Recorder of Deeds of Cumberland County of a declaration dated March 1, 1988, and recorded on March 25, 1988, in Miscellaneous Book 347, Page l 111, as the same shall be amended from time to time, being and designated in such declaration, as the same may be amended from time to time, as Unit No.7, also known as 142 -0, which said Unit being part of said Unit, is more fully described in said declaration, as the same may be amended from time to time, together with a proportionate undivided interest in the Compton Elements (as defined in said declaration, as the same may be amended from time to time) BEING THE SAME PREMISES which Scott A. Lake, a single man, by Deed dated July 1, 2003 and recorded July 3, 2003 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Record Book 257, Page 4774, granted and conveyed unto Anthony L. Ccnturione, Sr.,a married man. UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights of way, easements and agreements of record. FURTHER UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights of way and easements as set forth on Plats and plans Site Plan, recorded in Plan Book 55, page 43 Parcel No.: 23-26-0541-218A-U7---- BEING KNOWN AS: 142 15TH STREET UNIT G A/K/A 142 G 15TH STREET, NEW CUMBERLAND, PA 17070 PROPERTY ID NO.: 23-26-0541.218A-U7---- TITLE TO SAID PREMISES IS VESTED IN ANTHONY L. CENTURIONE, SR., A MARRIED MAN BY DEED FROM SCOTT A. LAKE, A SINGLE MAN DATED 07/01/2003 RECORDED 07 /03/2003 IN DEED BOOK 257 PAGE 4774, Inst.# 201316841 -Page 1 of 5 05/2912013 12:56:38 PM CUMBERLAND COUNTY The same having been sold by me to the said grantee on the 6th day of March Anno Domini Two Thousand and Thirteen (2013) after due advertisement according to law, under and by Virtue of a Writ of Execution issued on the 3rd of December Anno Domini 2012 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Nine (2009) Number 398 at the suit of Deutsche Bank Trust Company Americas as Trustee for Rali 2006QS17 -vs- Anthony L. Centurione, Sr., A/K/A Anthony L. Centurione 05/29/2013 12:56:38 PM CUMBERLAND COUNTY Instl 201316841 - Page 2 of 5 In Witness Whereof, I have hereunto affixed my signature this 9th day of APr i 1 Anno Domini Two Thousand and Thirteen (2013) o R. Anderson, Sheriff Commonwealth of Pennsylvania, ss. County of Cumberland Before the undersigned, David D. Buell, Prothonotary of the Court of Common Pleas of Cumberland County, Pennsylvania, personally appeared Ronny R. Anderson, Sheriff of Cumberland County aforesaid, and in due form of law declared that the facts Set forth in the foregoing Deed are, true, and that he acknowledged the same in order that Said deed might be recorded. Witness my hand and seal of said Court, this 9th day of April Anno Domini Two Thousand and Thirteen (2013) onot tr a is%sm �� :�. . �, .• , ,!�;Y I hereby certify that the residence r' . ;�• �, s`' And Post Office address of the Within Grantee is S 2001 Australian Avenue, Bay 1 Riviera Beach, FL 33404 Richard W. Stewart Solicitor Page 3 of 5 05/29/2013 12:56:38 PM CUMBERLAND COUNTY Instl 201316841 - REV- 183 EX (4-10) i REALTY TRANSFER TAX State Tax RE d� ---�' ONLY • r pensylvania • 4kP�HI n Ck FkVENUk STATEMENT OF VALUE Book Number Buresu d tx4itvidual Taxes Page Nu mbe r PO BOX 280603 Harasburg PA 1712&0603 See Reverse for Instructions Date Recorded Complete each section and file in duplicate with Recorder of Deeds when (1) the full value /Consideration Is not set forth In the deed, (2) the deed is without consideration or by gift, or (3) a tax exemption is claimed. A Statement of Value is not required if the transfer is wholly exempt from tax based on family relationship or public utility easement. If more space is needed, attach acditional sheets. A. CORRESPONDENT — All inquiries may be directed to the following person: Name Telephone Number: UDREN LAW OFFICES, PC $56 669 -5400 Street Address ity State ZIP Code I 1 l WOODCREST RD., STE 200 HERBY HILL it 08003 B. TRANSFER DATA Date of Acceptance of Document Grantor(s) /Lessor(s) Grantee(s) /Lessee(s) EUTSCHE BANK TRUST COMPANY AMERICAS, as Trustee Sheriff of Cumberland County or Residential Accredit Loans, Inc. ) 2006-QS 17 Street Address itreet Address One Courthouse Square 901 Australian Avcnue. Bay l city State IP Code ity State ZIP Code Carlisle A 17013 ivicta Beach 3804 C. REAL ESTATE LOCATION' Street Address Ity, Township, Borough 142 15 Strect Unit G a/k/a 142 G 15' Street Few Cumberland Borough County Vst hool District ax Parcel Number Cumberland Shone SD E3-26-0541-21 8A-1U7 D. VALUATION DATA 1. Actual Cash Consideration 2. Other Consideration Total Consideration $1,515.55 1,515.55 4. County Assessed Value 5. Common Level Ratio Factor . Fair Market Value $97,770.00 X 1.00 97,770.00 E. EXEMPTION DATA — WAS TRANSACTION PART OF AN ASSIGNMENT OR RELOCATION? Z YEIN la. Amount of Exemption Claimed 1b. Percentage of Grantor's Interest in Real Estate 1c. Percentage of Grantor's Interest Conveyed 100% 100% 100% 2.Check Appropriate Box Below for Exemption Claimed Will or intestate succession. ❑ Transfer to Industrial Development Agency, ame o ece en a e I e umber ❑ Transfer to a trust. (Attach complete copy of trust agreement Identifying all beneficiaries.) ❑ Transfer From a trust. Date of transfer into the trust If trust was amended attach a copy of original and amended trust. ❑ Transfer between principal and agent/straw party. (Attach complete copy of agency /straw party agreement.) ❑ Transfers to the Commonwealth, the United States and Instrumentalities by gift, dedication, condemnation or in lieu of condemnation. (If condemnation or in lieu of condemnation, attach copy of resolution.) ® Transfer from mortgagor to a holder of a mortgage in default. (Attach copy of Mortgage and note /Assignment.) ❑ Corrective or confirmatory deed. (Attach complete copy of the deed to be corrected or confirmed.) ❑ Statutory corporate consolidation, merger or division. (Attach copy of articles.) ® Other (Please explain exemption claimed, if other than listed above.) Transfer from the Sheriff to the mort cc as a result of an action in mon a e foreclosure. Under penalties o law, declare t at a have examined this statement, Including accompanying i nformation, and to th best of my knowledge and beligf, it is true. r 7d e.t, 1 7NI3 FAILURE td CO LETE THIS FORM PROPERLY OR ATTACH REQUESTED DOCUMENTATION MAY RESULT IN THE RECORDER'S REFUSAL TO RECORD THE DEED. 05/29/2013 12:56:38 PM CUMBERLAND COUNTY Inst.# 201316841 - Page 4 of 5 T ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717 -240 -6370 Instrument Number - 201316841 Recorded On 5/22/2013 At 9:49:44 AM * Total Pages - 5 * Instrument Type - DEED - SHERIFF'S Invoice Number - 137529 User ID - KW * Grantor - CENTURIONE, ANTHONY L SR * Grantee - RESIDENTIAL ACCREDIT LOANS INC * Customer - SHERIFF * FEES STATE WRIT TAX $0.50 Certification Page STATE JCS /ACCESS TO $23.50 JtrsTlcE (DO NOT DETACH RECORDING FEES - $13.50 RECORDER OF DEEDS Th page is now art PARCEL CERTIFICATION $10.00 P g P FEES of this legal document. AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE' $2.00 ROD ARCHIVES FEE $3.00 WEST SHORE SCHOOL $0.00 DISTRICT NEW CUMBERLAND BOROUGH $0.00 TOTAL PAID $64.00 I Certify this to be recorded in Cumberland County PA ar RECORDER O 4 7E S * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 002YOD lllllllilll�lllllllllllllll 05/29/2013 12:56:38 PM CUMBERLAND COUNTY Inst.# 201316841 - Page 5 of 5 VERIFICATION. Dom awn Ba#es hereby states that he /she is ��jajrlZCGe V C Q� (name) (title) of P in C . tAn LLC—as servicer for DEUTSCHE BANK TRUST COMPANY AMERICAS, AS TRUSTEE FOR RESIDENTIAL ACCREDIT LOANS INC. (BALI) 2006 -QS 17, in this matter, that he /she is authorized to make this verification, and that the statements made in the foregoing Civil Action in Ejectment are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 19 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. v Date Signature PHS # 319104 Return to: Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400, One Penn Center Plaza Philadelphia, PA 19103 Attn: Eviction Department PHS # 319104 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson i9 ¢- Sheriff t.-�.lD-UF tL _ 0, �t eaiaratrr,, �rfy �`i,' THE PROTHCJNO 1A Jody S Smith Chief Deputy 2113 JUN 2 I AM 10: 31 Richard W Stewart Solicitor �� CUMBERLAND COUNTY ��• �-� �� PENNSYLVANIA Deutsche Bank National Association vs. Case Number Anthony Lewis Centurione, Jr 2013-3429 SHERIFF'S RETURN OF SERVICE 06/17/2013 08:30 PM - Deputy Tim Black, being duly sworn according to law, served the requested Complaint in Ejectment by"personally" handing a true copy to a person representing themselves to be the Defendant, to wit:Anthony Lewis Centurione, Jr at 257 Winding Way, Camp Hill, PA 17011. TIM LACK, DEPUTY SHERIFF COST: $64.62 SO ANSWERS, June 18, 2013 RONNK ANDERSON, SHERIFF ;ceetya1 iie Snont' rc,e',see '.c � Phelan Hallinan,LLP - ',-Meredith Wooters, Esq., Id. No.307207 C, 1.617 JFK Boulevard, Suite 1.400 Attorney for Plaintiff One Penn Center Plaza Philadelphia, PA 19103 rn 215-563-7000 rn DEUTSCHE BANK TRUST COMPANY C-n AMERICAS,AS TRUSTEE FOR 'n" RESIDENTIAL ACCREDIT LOANS, INC. CS ca (BALI) 2006-QS 17 v I> Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION vs No. 13-3429-CIVIL ANTHONY CENTURIONE, JR Or occupants 142 15TH STREET UNIT G A/K/A 142 G 15TH STREET CUMBERLAND County NEW CUMBERLAND, PA 17070-1178 Defendant PRAECIPE FOR JUDGMENT IN EJECTMENT TO THE PROTHONOTARY: Kindly enter Judgment in Ejectment in favor of Plaintiff, DEUTSCHE BANK 'TRUST COMPANY AMERICAS, AS TRUSTEE FOR RESIDENTIAL ACCREDIT LOANS, INC. (RALI) 2006-QS 17 and against the Defendant(s) ANTHONY CENTURIONE, JR and Or occupants for possession of premises 142 15TH STREET UNIT G, A/K/A 142 G 15TH STREET,NEW CUMBERLAND, PA 17070-1178 for failure to file an Answer within twenty (20) days of service. I hereby certify that according to Rule 23 7.1, written 10-day notice of Plaintiffs intention to file a praecipe for Entry of default Judgment was mailed to Defendant(s), a true and correct copy of which is attached hereto. Meredith Wooters, Esq., Id. No.307207 Attorney for Plaintiff Phelan Hallinan, LLP Default Judgment entered as indicated above. DATE: n. of rn te4 • J4?helan Hallinan, LLP Meredith Wooters, Esq.,Id. No.307207 1617 JFK Boulevard, Suite 1400 Attorney for Plaintiff One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 DEUTSCHE BANK TRUST COMPANY AMERICAS, AS TRUSTEE FOR RESIDENTIAL ACCREDIT LOANS, INC. (BALI) 2006-QS 1.7 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION vs No. 13-3429-CIVIL ANTHONY CENTURIONS, JR Or occupants 142 15TH STREET UNIT G A/KJA 142 G 15TH STREET CUMBERLAND County NEW CUMBERLAND, PA 17070-1178 Defendant VERIFICATION OF NON-MILITARY SERVICE I hereby verify that I am the Attorney for Plaintiff in the above captioned matter, and that on information and belief, I have knowledge of the following facts, to wit: (a) That Plaintiff is without information sufficient to determine whether the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors" Civil Relief Act of Congress of 1940, as amended. (b)That defendant ANTHONY CENTURIONE, JR and/or occupant(s)resides at 142 15TH STREET UNIT G, A/K/A 142 G 15TH STREET,NEW CUMBERLAND, PA 17070-1178. (c) That Plaintiff is without information sufficient to determine whether defendant, or occupants, is/are over 18 years of age. This statement is made subject to penalties of 18 PA. C.S.S 4904 relating to unsworn falsification to authorities. Date: July 24, 2013 Me edith Wooters, Esq., Id. No.307207 Attorney for Plaintiff Phelan Hallinan, LLP PH# 812862 Phelan Hallinan,LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia,-PA 19103 215-563-7000 DEUTSCHE BANK TRUST COMPANY AMERICAS, Court of Common Pleas AS TRUSTEE FOR RESIDENTIAL ACCREDIT LOANS, INC. (BALI)2006-QS 17 Plaintiff Civil Division VS No. 13-3429-CIVIL ANTHONY CENTURIONE,JR or Occupants Defendant CUMBERLAND COUNTY TO: ANTHONY CENTURIONE, JR or Occupants 142 15TH STREET UNIT G A/K/A 142 G 15TH STREET NEW CUMBERLAND,PA 17070-1178 DATE OF NOTICE: July 9, 2013 ** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. 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 of objections to.the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: Office of the Prothonotary Cumberland County Bar Association Cumberland County Courthouse 32 South Bedford Street I Courthouse Square Carlisle,PA 17013 Carlisle,PA 17013 (717)249-3166 (717)240-6195 By: Adam H. Davis, Esq., Id.No.203054 Attorney for Plaintiff Phelan Hallinan,LLP PH#319104 PRAECIPE FOR WRIT OF POSSESSION ' COMMONWEALTH OF PENNSYLVANIA r_, C.3 Q -7 COUNTY OF CUMBERLAND rx� DEUTSCHE BANK TRUST COMPANY'-- AMERICAS, AS TRUSTEE FOR RESIDENTIAL ACCREDIT LOANS, INC. (BALI) 2006-QS 17 .� Plaintiff COURT OF COMMON PLEAS '_ CIVIL DIVISION vs No. 13-3429-CIVIL ANTHONY CENTURIONS, JR Or occupants 142 15TH STREET UNIT G A/K/A 142 G 15TH STREET CUMBERLAND County NEW CUMBERLAND, PA 17070-1178 Defendant PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Issue Writ of Possession in the above matter for possession of: 142 15TH STREET UNIT G, A/K/A 142 G 15TH STREET, NEW CUMBERLAND, PA 17070-1178 "PLEASE SEE THE ATTACHED LEGAL DESCRIPTION" Being Known as No. 142 15TH STREET UNIT G, A/K/A 142 G 15TH STREET Mere ith ooters, Esq., Id. No.307207 Attorney for Plaintiff Phelan Hallinan, LLP DATE: a. 01 Ids �s /4 S6 �r �i 1 of 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEUTSCHE BANK TRUST COMPANY AMERICAS, AS TRUSTEE FOR RESIDENTIAL ACCREDIT LOANS, INC. (RALI)2006-QS 17 VS. No. 13-3429 Civil Term ANTHONY CENTURIONS, JR OR OCCUPANTS 142 15TH STREET UNIT G A/K/A 142 G 15TH STREET NEW CUMBERLAND, PA 17070 Costs Attorney's $213.37 Plaintiff's $ Prothonotary $ 2.25 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (1)To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff(s)) DEUTSCHE BANK TRUST COMPANY AMERICAS,AS TRUSTEE FOR RESIDENTIAL ACCREDIT LOANS, INC. (RALI)2006-QS 17 being: (Premises as follows): 142 15TH STREET UNIT G,A/K/A 142 G 15TH STREET,NEW CUMBERLAND, PA 17070 (2)To satisfy the costs against the defendant(s)you are directed to levy upon any property of the defendant(s)and sell his/her(or their) interest therein. David D.Buell, Prothonotary, Common Pleas Court of Cumberland County, PA Date 7/25/13 (Seal) e� o�r2 r 2 of 2 No 13-3429 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA DEUTSCHE BANK TRUST COMPANY AMERICAS,AS TRUSTEE FOR RESIDENTIAL ACCREDIT LOANS, INC. (RALI)2006-QS 17 VS. ANTHONY CENTURIONS,JR OR OCCUPANTS WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 213.37 Plff(s) $ Prothy $ 2.25 Sheriff $ Plaintiff(s)attorney name and address: MEREDITH WOOTERS,ESQUIRE - ID#307207 PHELAN HALLINAN,LLP 1617 JFK BLVD., SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 215-563-7000 Attorney for Plaintiff(s) Where papers may be served By virtue of this writ,on the day of . I caused the within named to have possession of the premises described with the appurtenances,and So Answers, Sworn and subscribed to before me this Day of , Sheriff By Prothonotary Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY e - r� Ronny R Anderson ',�.ED f .. Sheriff " Jody S SmithQk�yt Chief Deputy ,13 AUC) _Z Pli 3f A Richard W Stewart ' , + ' Girt Solicitor OF T usf w t - pENNSYL\'P'tdl Deutsche Bank National Association Case Number vs. Anthony Lewis Centurione, Jr 2013-3429 SHERIFF'S RETURN OF SERVICE 08/01/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Anthony Lewis Centurione, Jr, but was unable to locate the Defendant at the address provided of 142 G 15th Street, New Cumberland, PA 17070. The Sheriff therefore returns the within requested Possession as"NOT SERVED"at 142 G 15th St., New Cumberland Borough, New Cumberland, PA 17070. Property appears to be vacant and defendant does not reside at this address. Defendant Anthony Lewis Centurione, Jr.was served the original complaint in ejectment at an alternate address of 257 Winding Way, Camp Hill, PA 17011. 08/02/2013 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as STAYED. Property appears to be vacant. SHERIFF COST: $30.85 SO ANSWERS, d August 02, 2013 RONRY R ANDERSON, SHERIFF (c)CountySuite Sheriff.Teleosoft,Inc, W2 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA DEUTSCHE BANK TRUST COMPANY AMERICAS, AS TRUSTEE FOR RESIDENTIAL ACCREDIT LOANS, INC. (RALI)2006-QS 17 VS. No. 13-3429 Civil Term ANTHONY CENTURIONS, JR OR OCCUPANTS 142 15TH STREET UNIT G A/K/A 142 G 15TH STREET NEW CUMBERLAND,PA 17070 Costs Attorney's $213.37 Plaintiff's $ Prothonotary $ 2.25 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (1)To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff(s)) DEUTSCHE BANK TRUST COMPANY AMERICAS,AS TRUSTEE FOR RESIDENTIAL ACCREDIT LOANS, INC. (RALI)2006-QS 17 being: (Premises as follows): 142 15TH STREET UNIT G, A/K/A 142 G 15TH STREET,NEW CUMBERLAND,PA 17070 (2)To satisfy the costs against the defendant(s)you are directed to levy upon any property of the defendant(s) and sell his/her(or their)interest therein. IwAizz'—1 1� David D.Buell,Prothonotary, Common Pleas Court of Cumberland County PA Date 7/25/13 (Seal) j TRUE COPY FROM RECORD in Testimony whereof, I here unto set my hand and the seal of said Co rt Carlisle,Pa. This_p�j day of Prothonotary 2 of 2 No'13-3429 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA DEUTSCHE BANK TRUST COMPANY AMERICAS,AS TRUSTEE FOR RESIDENTIAL ACCREDIT LOANS,INC. (RALI)2006-QS17 VS. ANTHONY CENTURIONE,JR OR OCCUPANTS WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 213.37 Plff(s) $ Prothy $ 2.25 Sheriff $ Plaintiff(s)attorney name and address: MEREDITH WOOTERS,ESQUIRE - ID#307207 PHELAN HALLINAN, LLP 1617 JFK BLVD., SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 215-563-7000 Attorney for Plaintiff(s) Where papers may be served By virtue of this writ, on the day of I caused the within named ,to have possession of the premises described with the appurtenances,and So Answers, Sworn and subscribed to before me this Day of , Sheriff By Prothonotary Deputy WRIT OF POSSESSION (Ejectment Proceedings PRCP 3160-3165 etc.) DEUTSCHE BANK TRUST COMPANY AMERICAS, AS TRUSTEE FOR IN THE COURT OF COMMON PLEAS OF RESIDENTIAL ACCREDIT LOANS, CUMBERLAND COUNTY, PENNSYLVANIA. INC. (RALI) 2006-QS 17 Plaintiff Vo. 13-3429-CIVIL Term: Vs. No. Term: ANTHONY CENTURIONE, JR Or occupants 142 15TH STREET UNIT G A/K/A 142 G 15TH STREET NEW CUMBERLAND, PA 17070- Costs 1178 Defendant Att'y $ Pl'ff(s) $ — Prothy $ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND To the Sheriff of Cumberland County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver Possession of the following described property to: DEUTSCHE BANK TRUST COMPANY AMERICAS AS TRUSTEE FOR RESIDENTIAL ACCREDIT LOANS, INC. (RALI) 2006-QS 17 Plaintiff(s) Being: (Premises as follows): 142 15TH STREET UNIT G A/K/A 142 G 15TH STREET NEW CUMBERLAND, PA 17070-1178 (2) To satisfy the costs against the defendant(s) you are directed to levy upon any property of the defendant(s) and sell his/her (or their) interest therein. Prothonotary, Common Pleas Court of Cumberland County, Pennsylvania Date By: COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEUTSCHE BANK TRUST COMPANY AMERICAS, AS TRUSTEE FOR RESIDENTIAL ACCREDIT LOANS, INC. (RALI) 2006-QS 17 VS. ! ANTHONY CENTURIONE. JR OR OCCUPANTS ' WRIT OF POSSESSION P.R.C.P. 3160-3165 Costs Att,y $ Q a PPff(s) $ Prothy $ 3 Sheriff $ 3 ��u Az�w o ! Meredith Wooters, Esq., Id. No.307207 j Attorney for Plaintiff ; cn ' Phelan Hallinan LLP " ° : ' o o j j i i c o , ' Legal Description ALL THAT CERTAIN unit in the property known, named and identified in the declaration referred to below as 'Cumberland Crossings Condominium,' located in New Cumberland Borough, Cumberland County,pennsylvania, which has heretofore been submitted to the provisions of the pennsylvania Uniform Condominium Act, 68 Pa. C.S.A. 3101 by the recording in the Office of the Recorder of Deeds of Cumberland County of a declaration dated March 1, 1988, and recorded on March 25, 1988, in Miscellaneous Book 347, Page 1111, as the same shall be amended from time to time, being and designated in such declaration, as the same may be amended from time to time, as Unit No. 7, also known as 142-G, which said Unit being part of said Unit, is more fully described in said declaration, as the same may be amended from time to time,together with a proportionate undivided interest in the Common Elements (as defined in said declaration, as the same may be amended from time to time) BEING THE SAME PREMISES which Scott A. Lake, a single man, by Deed dated July 1, 2003 and recorded July 3, 2003 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Record Book 257, Page 4774, granted and conveyed unto Anthony L. Centurione, Sr.,a married man. UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights of way, easements and agreements of record. FURTHER UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights of way and easements as set forth on Plats and plans Site Plan, recorded in Plan Book 55, page 43 Parcel No.: 23-26-0541-218A-U7---- BEING KNOWN AS: 142 15TH STREET UNIT G A/K/A 142 G 15TH STREET,NEW CUMBERLAND, PA 17070 PROPERTY ID NO.: 23-26-0541-218A-U7---- TITLE TO SAID PREMISES IS VESTED IN ANTHONY L. CENTURIONE, SR.,A MARRIED MAN BY DEED FROM SCOTT A. LAKE, A SINGLE MAN DATED 07/01/2003 RECORDED 07/03/2003 IN DEED BOOK 257 PAGE 4774. Phelan Hallinan, LLP Adam H. Davis, Esq., Id. No.203034 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Attorney for Plaintiff 215-563-7000 DEUTSCHE BANK TRUST COMPANY Court of Common Pleas AMERICAS, AS TRUSTEE FOR RESIDENTIAL ACCREDIT LOANS, INC. (RALI) 2006-QS 17 Plaintiff Civil Division vs. CUMBERLAND County No. 13-3429-CIVIL - ANTHONY CENTURIONE, JR Or occupants Action in Ejectment 4 ' rri C-3 142 15TH STREET UNIT G, %r"' A/K/A 142 G 15TH STREET c5 NEW CUMBERLAND, PA 17070-1178 f- T' Defendant G _ c c MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURTS ' `r c:� Plaintiff, by its counsel, Phelan Hallinan, LLP, moves this Honorable Court for an Order directing service of the Writ of Possession upon the above-captioned Defendants by regular mail, and posting of the premises and in support thereof avers as follows: 1. Plaintiff commenced this action by filing a Writ of Possession. 2. Attempts to serve Defendants with the Writ of Possession have been unsuccessful. Plaintiff attempted to serve the Defendants on August 1, 2013 as indicated by the Affidavit of Service attached hereto as Exhibit A. 3. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defendants. An Affidavit of Reasonable Investigation setting forth the specific inquiries made and the results from there are attached hereto as Exhibit B. 4. Plaintiff submits that is has made a good faith effort to locate the Defendants, but has been unable to do so. 5. Plaintiff verified through property inspection on October 9, 2013 that the property was occupied by an unknown person. 6. In accordance with Cumberland County Rule 208.3(9), Plaintiff sent a copy of it's proposed Motion for Special Service to defendant on October 15, 2013 and requested Defendant's concurrence. Plaintiff did not receive any response from Defendant. A True and correct copy of Plaintiff's letter pursuant to 208.3(9) is attached hereto, made part hereof, and marked as Exhibit"C" WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Writ of Possession and all future pleadings by regular mail and posting of the premises Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff Phelan Hallinan, LLP Date: October 28, 2013 Phelan Hallinan, LLP Adam H. Davis, Esq., Id. No.203034 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Attorney for Plaintiff 215-563-7000 DEUTSCHE BANK TRUST COMPANY Court of Common Pleas AMERICAS, AS TRUSTEE FOR RESIDENTIAL ACCREDIT LOANS, INC. (RALI) 2006-QS 17 Plaintiff Civil Division vs. CUMBERLAND County No. 13-3429-CIVIL ANTHONY CENTURIONE, JR Or occupants Action in Ejectment 142 15TH STREET UNIT G, A/K/A 142 G 15TH STREET NEW CUMBERLAND, PA 17070-1178 Defendant MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Pennsylvania Rule of Civil Procedure 430(a) specifically provides: If service cannot be made under the applicable rule, the plaintiff may move the Court for a special order directing the method of service. The motion shall be accompanied by an Affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the Defendants and the reasons why service cannot be made. Although Plaintiff has attempted to serve Defendants with the Writ of Possession, Plaintiffs attempts have been unsuccessful. A true and correct copy of the Affidavit of No Service is attached hereto, made part hereof, and marked Exhibit A. Accordingly, Plaintiff ordered an investigation into the whereabouts of Defendants. A true and correct copy of the Affidavit of Reasonable Investigation is attached hereto, made part hereof, and marked as Exhibit B. The Affidavit reflects that Plaintiff's investigator has made at least three types of inquires listed under Rule 403.1(B)(1). Copies of any written responses obtained are attached to the Affidavit. The Affidavit also specifies the inquires made, responses made, and dates thereof, in accordance with Rule 430.1(B)(2). As Plaintiffs within motion and its affidavit are both in compliance with the applicable Pennsylvania and local rules, Plaintiff respectfully requests that its motion be granted. WHEREFORE, Plaintiff respectfully requests permission to serve the Writ of Possession and all future pleadings by regular mail and posting of the premises. Respectfully Submitted: Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff Phelan Hallinan, LLP Date: October 28, 2013 EXHIBIT "A" • • EXHIBIT "B" EXHIBIT "C" ap , ,.., _ , J , 4` [ ', Representiog LOsutfers in E n0SYIVacwin 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 FAX#: 215-563-4491 Email: JOSEPH.GARDELLIS @phelanhallinan.com October 15, 2013 ANTHONY CENTURIONE, JR Or occupants 142 15TH STREET UNIT G, A/K/A 142 G 15TH STREET NEW CUMBERLAND, PA 17070-1178 RE: Deutsche Bank Trust Company, et al.vs.Anthony Centurione,Jr.or occupants Cumberland County No. 13-3429 Civil Dear Anthony Centurione Jr. or occupants , Enclosed please find a true and correct copy of my proposed Motion for Special Service and Order. In accordance with Cumberland County Local Rule 208.3(9), I am seeking your concurrence with the requested relief that is, service of the complaint. Please respond to me within one week, by October 22, 2013. Should you have any questions, please feel free to contact me. Very truly yours, Phelan Hallinan, LLP. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ;;�P Jody S Smith Chief Deputy Richard W Stewart Solicitor Deutsche Bank National Association vs. Case Number Anthony Lewis Centurione,Jr 2013-3429 SHERIFF'S RETURN OF SERVICE 08/01/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Anthony Lewis Centurione, Jr, but was unable to locate the Defendant at the address provided of 142 G 15th Street, New Cumberland, PA 17070. The Sheriff therefore returns the within requested Possession as"NOT SERVED"at 142 G 15th St., New Cumberland Borough, New Cumberland, PA 17070. Property appears to be vacant and defendant does not reside at this address. Defendant Anthony Lewis Centurione, Jr. was served the original complaint in ejectment at an alternate address of 257 Winding Way, Camp Hill, PA 17011. 08/02/2013 Ronny R.Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as STAYED. Property appears to be vacant. SHERIFF COST: $30.85 SO ANSWERS, sv":09 August 02, 2013 RONNY R ANDERSON, SHERIFF AFFIDAVIT OF GOOD FAITH INVESTIGATION File Number: 319104 Attorney Firm: Phelan Hallinan,LLP Subject: Anthony L. Centurione Jr. Property Address: 142 15th Street,Apartment G,New Cumberland,PA 17070 I. CREDIT INFORMATION A. SOCIAL SECURITY NUMBER Our search verified the following information to be true and correct Anthony L.Centurione Jr. -xxx-xx-6741 B. EMPLOYMENT SEARCH Anthony L.Centurione Jr. -A review of the credit reporting agencies provided no employment information. C. INQUIRY OF CREDITORS Our inquiry of creditors indicated that Anthony L.Centurione Jr. reside(s) at: 142 15th Street, Apartment G,New Cumberland,PA 17070. II. INQUIRY OF TELEPHONE COMPANY A. DIRECTORY ASSISTANCE SEARCH Our office searched directory assistance databases,which had no listing for Anthony L.Centurione Jr. B. On 10-11-13 our office searched directory assistance databases,which had no phone number for Anthony L.Centurione Jr. III. INQUIRY OF RELATIVES AND NEIGHBORS On 10-11-13 our office made several phone calls in an attempt to contact Theresa A. Centurione,potential relative of Anthony L. Centurione Jr. at(717) 761-3144, 257 Winding Way,Camp Hill,PA 17011: answering machine. On 1041-13 our office made several phone calls in an attempt to contact Tony Louis Centurione,potential relative of Anthony L. Centurione Jr. at(941) 924-6878,4795 Hanging Moss Lane,Sarasota, FL 34238: answering machine. On 10-11-13 our office made a phone call in an attempt to contact Joseph M. Centurione,potential relative of Anthony L. Centurione Jr.at (717) 737-6594,1607 Wyndham Road,Apartment RD,Camp Hill, PA 17011: spoke with an unidentified female who could not confirm any information for subject. On 10-11-13 our office made a phone call in an attempt to contact Jason E. Harris 717- 774-2814,142 15th Street, Apartment M, New Cumberland,PA 17070: disconnected. On 10-11-13 our office made several phone calls in an attempt to contact Kelly J. Koppenhaver 717-770-0476, 142 15th Street, Apartment E, New Cumberland,PA 17070: answering machine. On 10-11-13 our office made a phone call in an attempt to contact James J. McNulty 717-774-7159, 142 15th Street,Apartment D,New Cumberland,PA 17070: disconnected. IV. ADDRESS INQUIRY A. NATIONAL ADDRESS UPDATE On 10-11-13 we reviewed the National Address database and found the following information: Anthony L.Centurione Jr.-14215th Street,Apartment G, New Cumberland,PA 17070. B. ADDITIONAL ACTIVE MAILING ADDRESSES Per our inquiry of creditors,the following is a possible mailing address:no addresses on file. V.OTHER INQUIRIES A. DEATH RECORDS As of 10-11-13 Vital Records and all public databases have no death record on file for Anthony L. Centurione Jr. VI. ADDITIONAL INFORMATION OF SUBJECT A. DATE OF BIRTH Anthony L.Centurione Jr. -09-1964 B. A.K.A. Anthony C.Centurione *Our accessible databases have been checked and cross-referenced for the above named individual(s). *Please be advised our database information indicates the subject resides at the current address. I hereby verify that the statements made herein are true and correct to the best of my knowledge,information and belief and that this affidavit of investigation is made subject to the penalties of 18 Pa C.S.Sec. 4904 relating to unsworn falsification to authorities. k� i /401, �. The above utfortnation is obtained from available public records and we are only liable for the cost of the affidavit. Phelan Hallinan, LLP Adam H. Davis,Esq., Id. No.203034 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Attorney for Plaintiff 215-563-7000 DEUTSCHE BANK TRUST COMPANY Court of Common Pleas AMERICAS, AS TRUSTEE FOR RESIDENTIAL ACCREDIT LOANS, INC. (RALI) 2006-QS 17 Plaintiff Civil Division vs. CUMBERLAND County No. 13-3429-CIVIL ANTHONY CENTURIONE, JR Or occupants Action in Ejectment 142 15TH STREET UNIT G, A/K/A 142 G 15TH STREET NEW CUMBERLAND, PA 17070-1178 Defendant CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of the Motion for Service Pursuant to Special Order was served by first class mail on the Defendant's on the date listed below: ANTHONY CENTURIONE, JR OR OCCUPANTS 142 15TH STREET UNIT G, A/K/A 142 G 15TH STREET NEW CUMBERLAND, PA 17070-1178 DATE: October 28, 2013 / .Z2e-c.y,,.) Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff Phelan Hallinan, LLP DEUTSCHE BANK TRUST COMPANY Court of Common Pleas AMERICAS, AS TRUSTEE FOR RESIDENTIAL ACCREDIT LOANS, INC. (RALI) 2006-QS 17 Plaintiff Civil Division vs. CUMBERLAND County No. 13-3429-CIVIL ANTHONY CENTURIONE, JR Or occupants Action in Ejectment 142 15TH STREET UNIT G, A/K/A 142 G 15TH STREET NEW CUMBERLAND, PA 17070-1178 Defendant ORDER St It is ordered this day of N o v , 2013 that Plaintiff's Motion for Service of Writ of Possession and all future pleadings Pursuant to Special Order of Court is GRANTED, permitting service by: X First Class Mail to ANTHONY CENTURIONE, JR or occupants at the property which is subject to this Ejectment Action*. Service by first class mail is effective upon the date of mailing. X Posting of the property which is subject to this Ejectment Action* * the property at: 142 15TH STREET UNIT G, A/K/A 142 G 15TH STREET NEW CUMBERLAND, PA 17070-1178 BY THE COURT: PH # 812862 3 �c:x ��fy >C") 3r . _ 1/3 PRAECIPE TO REISSUE WRIT OF POSSESSION COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DEUTSCHE BANK TRUST COMPANY AMERICAS, AS TRUSTEE FOR RESIDENTIAL ACCREDIT LOANS, INC. (RALI) 2006-QS 17 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION vs No. 13-3429-CIVIL ANTHONY CENTURIONE, JR Or occupants CUMBERLAND County 142 15TH STREET UNIT G A/K/A 142 G 15TH STREETz = NEW CUMBERLAND, PA 17070-1178 "`= ' c' Defendant PRAECIPE TO REISSUE WRIT OF POSSESSION - rc c5 TO THE PROTHONOTARY: Reissue Writ of Possession in the above matter, for possession of: 142 15TH STREET UNIT G, A/K/A 142 G 15TH STREET, NEW CUMBERLAND, PA 17070- 1178 **PLEASE SEE THE ATTACHED LEGAL DESCRIPTION** Being Known as No. 142 15TH STREET UNIT G, A/K/A 142 G 15TH STREET / 4? — Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff Phelan Hallinan, LLP 4 Div6 teios pcl Hti e H■ 13c,o th►" pc)ci 2/D6 Phelan Hallinan, LLP Adam H. Davis,Esq., Id. No.203034 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Attorney for Plaintiff 215-563-7000 DEUTSCHE BANK TRUST COMPANY Court of Common Pleas AMERICAS, AS TRUSTEE FOR RESIDENTIAL ACCREDIT LOANS, INC. (RALI) 2006-QS17 Plaintiff Civil Division vs. CUMBERLAND County No. 13-3429-CIVIL ANTHONY CENTURIONE, JR Or occupants 142 15TH STREET UNIT G, A/K/A 142 G 15TH STREET NEW CUMBERLAND, PA 17070-1178 Defendant AFFIDAVIT OF SERVICE VIA REGULAR MAIL I hereby certify that a true and correct copy of the Writ of Possession in the above captioned matter was sent by Regular Mail, to the following person(s): ANTHONY CENTURIONE, JR or Occupants at 142 15TH STREET UNIT G, A/K/A 142 G 15TH STREET,NEW CUMBERLAND, PA 17070-1178 in accordance with the Order of Court dated November 1, 2013. The undersigned understands that this is subject to the Penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn Falsification to authorities. DATE: November 18, 2013 G 'ei%� ?/u/l.l10 Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff Phelan Hallinan, LLP PH# 812862 C ii err Fn tar-r C SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff �. �aEkraPrrfrt� .�t' � Jody S Smith t�<�i ?5 P ; E2 11 Chief Deputy ` `�Uc`ltiti Ahu E; �" { Richard W Stewart s �� Y�l�� 0 U Solicitors" - Deutsche Bank National Association Case Number vs. Anthony Lewis Centurione, Jr 2013-3429 SHERIFF'S RETURN OF SERVICE 11/22/2013 By virtue of this writ, Sheriff Ronny R.Anderson caused the within named Plaintiff to have possession of the premises described as 142 14th Street Unit G,A/K/A 142 G 15th Street, New Cumberland, PA 17070. 11/22/2013 10:09 AM - Deputy Ronald Hoover, being duly sworn according to law, posted one true and attested copy of the within Writ of Possession upon Real Estate located at 142 G 15th St., New Cumberland Borough, New Cumberland, PA 17070. SHERIFF COST: $91.24 SO ANSWERS, November 25, 2013 RbNW R ANDERSON, SHERIFF a pd . gvo-)-� l � . rht PRO THONO TA 't 2613 DEC 16 AH 10: 13 • UM ERLAND COUNTY PENNSYLVANIA Phelan Hallinan,LLP Attorney For Plaintiff 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 DEUTSCHE BANK TRUST COMPANY AMERICAS, : Court of Common Pleas AS TRUSTEE FOR RESIDENTIAL ACCREDIT : LOANS,INC.(RALI)2006-QS17 : Civil Division Plaintiff : CUMBERLAND County v. : No. 13-3429-CIVIL ANTHONY CENTURIONE,JR Or Occupants Defendant(s) PRAECIPE TO THE PROTHONOTARY: n Please withdraw the complaint and mark the action Discontinued and Ended without prejudice. I _ Please mark the above referenced case Settled, Discontinued and Ended. n Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice. ® Please mark the judgment Satisfied and the action Discontinued and Ended. Please Vacate the Judgment entered. Date: /2JAI PHELAN - LI •N,LLP By: ... Joh, ichael Kolesnik,Esq.,Id. No.308877 Attorney for Plaintiff PH#812862 • Phelan Hallinan,LLP Attorney For Plaintiff 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 DEUTSCHE BANK TRUST COMPANY : Court of Common Pleas AMERICAS, AS TRUSTEE FOR RESIDENTIAL : ACCREDIT LOANS,INC.(RALI)2006-QS17 : Civil Division Plaintiff : CUMBERLAND County v. : No. 13-3429-CIVIL ANTHONY CENTURIONE,JR Or Occupants Defendant(s) CERTIFICATION OF SERVICE I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe was served by regular mail to the person(s) on the date listed below: ANTHONY CENTURIONE,JR Or Occupants 142 15TH STREET UNIT G A/K/A 142 G 15TH STREET NEW CUMBERLAND,PA 17070-1178 Date: /Z/( 3/3 PHELA O L AN, LLP B : Y �� Joh• tic ael Kolesnik,Esq.,Id. No.308877 Attorney for Plaintiff