HomeMy WebLinkAbout13-6269 + Supreme Court of Pennsylvania
Cour of nom `°on Pleas
l'.MC 7 oV.ef, 9'_'lieet For Prothonotary Use Only:
CU IVIBERLA r' County Docket No:
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the filing and service of pleadings or other papers as required by law or rules of court.
Commencement of Action:
S ® Complaint ❑ Writ of Summons ❑ Petition
E] Transfer from Another Jurisdiction El Declaration of Taking
E Lead Plaintiff s Name: Deutsche Bank National Trust Company, as Lead Defendant's Name: Michelle Roach
C trustee for First Franklin Mortgage Loan Trust 2006 -FFl 1, Mortgage
T Pass - Through Certificates, Series 2006 -FFI1
Are money damages requested ?: ❑ Yes ® No Dollar Amount Requested: within arbitration limits
I (Check one)
X outside arbitration limits
N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJ Appeal? [:]Yes ® No
Name of Plaintiff /Appellant's Attorney: Scott A. Dietterick, Esq. c/o Zucker, Goldberg & Ackerman, LLC
A
❑ Check here if you have no attorney (are a Self- Represented [Pro 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
❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections
❑ Nuisance ❑ Dept. of Transportation
❑ Premises Liability ❑ Statutory Appeal: Other
S
El Product Liability (does not include
mass tort) ❑ Employment Dispute:
E ❑ Slander/Libel/Defamation Discrimination
❑ Other: ❑ Employment Dispute: Other
C ❑ Zoning Board
T
El Other:
I MASS TORT ❑ Other:
O
El Asbestos
❑ Tobacco
N ❑ Toxic Tort- DES
❑ Toxic Tort- Implant REAL PROPERTY MISCELLANEOUS
El Toxic Waste
El Ejectment El Common Law /Statutory Arbitration
❑ Other:
` ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment
I B ❑ Ground Rent ❑ Mandamus
❑ Landlord/Tenant Dispute ❑ Non- Domestic Relations
PROFESSIONAL LIABLITY ® Mortgage Foreclosure: Residential Restraining Order
❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto
❑ Dental ❑ Partition ❑ Replevin
❑ Legal ❑ Quiet Title ❑ Other:
❑ Medical ❑ Other:
❑ Other Professional:
Updated 1/1//2011
Zucker, Goldberg & Ackerman, LLC
XCP- 181778
062 -PA -V3
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
DEUTSCHE BANK NATIONAL TRUST COMPANY, CIVIL DIVISION
AS TRUSTEE FOR FIRST FRANKLIN MORTGAGE -
LOAN TRUST 2006 -FF11, MORTGAGE PASS- NO.:
THROUGH CERTIFICATES, SERIES 2006 -FF11,
TYPE OF PLEADING
Plaintiff,
vs. CIVIL ACTION - COMPLAINT
IN MORTGAGE FORECLOSURE
Michelle Roach; William Roach;
FILED ON BEHALF OF:
Defendants. Deutsche Bank National Trust Company, as
trustee for FirstFranklin Mortgage Loan Trust
TO: DEFENDANTS 2006 -FF11, Mortgage Pass -
YOU ARE HEREBY NOTIFIED TO PLEAD TO THE
ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS ThroughCertificates, Series 2006 -FF11
FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAYBE
ENTERED AGAINST YOU. COUNSEL OF RECORD FOR THIS PARTY:
I HEREBY CERTIFY THAT THE ADDRESS
OFTHE PLAINTIFF Is: ZUCKER GOLDBERG & ACKERMAN, LLC
3476 Stateview Blvd.
Ft. Mill, SC 29715
Scott A. Dietterick, Esquire
AND THE DEFENDANT: Pa. I.D. #55650
419 East Green Street Kimberly A. Bonner, Esquire
Shiremanstown, PA 17011 Pa. LD. #89705
- Joel A. Ackerman, Esquire
CERTIFICATE OF LOCATION Pa I.D. #202729 ---
I HEREBY CERTIFY THAT THE LOCATION OF Ashleigh Levy Marin, Esquire - - {--.
THE REAL ESTATE AFFECTED BY THIS LIEN IS Pa I.D. #3067991
419 East Green Street, Shiremanstown PA 17011
Ralph M. Salvia, Esquire
Municipality: Shiremanstown
Pa I.D. #202946 ---4
Jaime R. Ackerman, Esquire
#311032
ATTORNEY FOR PLAINTIFF Pa I.D
ATTY FILE NO.: XCP 181778 200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233 -8500
(908) 233 -1390 FAX
office @zuckergoldberg.com
File No.: XCP- 181778/rbo
a
C q 3S�
IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ. (1977),
DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF, IF
DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING,
COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION
THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN
THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S)
THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD
FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH
THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION
WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO
REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30)
DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE
DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD
THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR
EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE
REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE
CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT.
IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO
COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Deutsche Bank National Trust Company, as CIVIL DIVISION
trustee for First Franklin Mortgage Loan Trust
2006 -FF11, Mortgage Pass - Through Certificates, NO.:
Series 2006 -FF11
Plaintiff,
VS.
Michelle Roach; William Roach;
Defendants.
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claim set forth in the following pages,
you must take action within twenty (20) days after this complaint and notice are served, by entering a
written appearance personally or by attorney and filing in writing with the court your defenses or
objections to the claims set forth against you. You are warned that if you fail to do so the case may
proceed without you and a judgment may be entered against you by the court without further notice
for any money claimed -in the complaint or for any other claim or relief requested by the plaintiff.
You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO
YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
NOTICE TO DEFEND LAWYER REFERRAL
Cumberland County Bar Association Cumberland County Bar Association
32 S. Bedford Street 32 S. Bedford Street
Carlisle, PA 17013 Carlisle, PA 17013
Phone (800) 990 -9108 Phone (800) 990 -9108
(717) 249 -3166 (717) 249 -3166
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Deutsche Bank National Trust Company, as CIVIL DIVISION
trustee for First Franklin Mortgage Loan Trust
2006 -FF11, Mortgage Pass - Through Certificates, NO.:
Series 2006 -FF11
Plaintiff,
vs.
Michelle Roach; William Roach;
Defendants.
AVISO
LISTED HA SIDO DEMANDADO /A EN CORTE. Si usted desea defenderse de la demands establecida en
las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la
notificacion de esta Demanda y Aviso respondiendo personalmente o por medio de un abogado una
comparecencia esc rita y radicando en la Corte por escrito sus defensas y objeciones a las demandas
establecidas en su contra. Se le advierte de que si usted falla en tomar accion como se describe
anteriormente, el caso puede proceder sin usted sin previo aviso y un fallo por cualquier suma de
dinero reclamada en la demanda 0 cua Iquier otra reclamacion o remedio solicitado por el
demandante, puede ser dictado en contra suva por la Corte. Usted puede perder dinero o
propiedades u otros derechos importantes para usted.
USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN
ABOGADO 0 NO PUEDE PAGAR UNO, LLAME 0 VAVA A LA SIGUEINTE OFICINA PARA AVERIGUAR
DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
NOTICE TO DEFEND LAWYER REFERRAL
Cumberland County Bar Association Cumberland County Bar Association
32 S. Bedford Street 32 S. Bedford Street
Carlisle, PA 17013 Carlisle, PA 17013
Phone (800) 990 -9108 Phone (800) 990 -9108
(717) 249 -3166 (717) 249 -3166
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Deutsche Bank National Trust Company, as CIVIL DIVISION
trustee for FirstFranklin Mortgage Loan Trust / ^ of
2006 -FF11, Mortgage Pass- ThroughCertificates, NO.: LS
Series 2006 -FF11
Plaintiff,,'
VS.
Michelle Roach; William Roach;
Cl> s tC
Defendants. � �„ T1
a
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE' •µ
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action, you
may be able to participate in a court- supervised conciliation conference in an effort to resolve this
matter with your lender.
If you do not have a lawyer, you must take the following steps to be eligible for a conciliation
conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn
Legal Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request
appointment of a legal representative at no charge to you. Once you have been appointed a legal
representative, you must promptly meet with that legal representative within twenty (20) days of the
appointment date. During that meeting, you must provide the legal representative with all requested
financial information so that a loan resolution proposal can be prepared on your behalf. If you and your
legal representative complete a financial worksheet in the format attached hereto, the legal
representative will prepare and file a Request for Conciliation Conference with the Court, which must be
filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do
so and a conciliation conference is scheduled, you will have an opportunity to meet with a
representative of your lender in an attempt to work out reasonable arrangements with your lender
before the mortgage foreclosure suit proceeds forward.
If you are represented by a lawyer, you and your lawyer must take the following steps to be
eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for
the appointment of a legal representative. However, you must provide your lawyer with all requested
financial information so that a loan resolution proposal can be prepared on your behalf. If you and your
lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a
Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60)
days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is
scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to
work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds
forward.
Zucker, Goldberg & Ackerman, LLC
XCP- 181778
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED
BY THIS NOTICE. TIDS PROGRAM IS FREE.
ZUCKER, GOLDBERG & ACKERMAN, LLC
By: _ A mn x
Dated: October $ Scott A. Dietterick, Esquire; PA I.D. #55650
2013 Kimberly A. Bonner, Esquire; PA I.D. #89705
Joel A. Ackerman, Esquire; PA I.D. #202729
Ashleigh L. Marin, Esquire; PA I.D. #306799
Ralph M. Salvia, Esquire; PA I.D. #202946
Jaime R. Ackerman, Esquire; PA I.D. #311032
Attorneys for Plaintiff
XCP- 181778/ns
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233 -8500; (908) 233 -1390 FAX
Email: Office @zuckergoldberg.com
Zucker, Goldberg & Ackerman, LLC
XCP- 181778
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/PRI
Borrower name(s):
Property Address:
City: State: Zip:
Is the property for sale? Yes ❑ No ❑ Listing date: Price: $
Realtor Name: Realtor Phone:
Borrower Occupied? Yes ❑ No ❑
Mailing Address (if different):
City: State: Zip:
Phone Numbers: Home: Office:
.Cell: Other:
Email:
# of people in household: How long?
CO-BORROWER
Mailing Address:
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people in household: How long?
FINANCIAL 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: $ Included Taxes & Insurance:
Date of Last Payment:
Primary Reason for Default:
Is the loan in Bankruptcy? Yes ❑ No ❑
If yes, provide names, location of court, case number & attorney:
Zucker, Goldberg & Ackerman, LLC
XCP- 181778
Assets Amount Owed Value:
Home: $ $
Other Real Estate: $ $
Retirement Funds: $ $
Investments: $ $
Checking: $ $
Savings: $ $
Other: $ $
Automobile #1 : Model: Year:
Amount owed: Value:
Automobile #2 : Model: Year:
Amount owed: Value:
Monthly Income
Name of Employers:
1.
2.
3.
Additional Income Description (not wages):
1. Monthly amount:
2. Monthly amount:
Borrower Pay Days: Co- Borrower Pay Days:
Monthly Expenses (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mortgage Food
2 " Mortgage Utilities
Car Payment(s) Condo /Neigh. Fees
Auto Insurance Med. (not covered)
Auto fuel /repairs Other prop. payment
Install. Loan Payment Cable TV
Child Support/Alim. Spending Money
Day /Child Care /Tuit. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes ❑ No ❑
If yes, please provide the following information:
Counseling Agency:
Counselor:
Phone (Office): Fax:
Email:
Zucker, Goldberg & Ackerman, LLC
XCP- 181778
Have you made application for Homeowners Emergency Mortgage Assistance Program
(HEMAP) assistance?
Yes ❑ No ❑
If yes, please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your
delinquency?
Yes ❑ No ❑
If yes, please indicate the status of those negotiations:
Please provide the following information, if known, regarding your lender or lender's loan servicing
company:
Lender's Contact (Name): Phone:
Servicing Company (Name):
Contact: Phone:
AUTHORIZATION
I /We, , authorize the above named to use /refer this
information to my lender / servicer for the sole purpose of evaluating my financial situation for possible
mortgage options. I /We understand that I /we am /are under no obligation to use the services provided
by the above named
Borrower Signature Date
Co- Borrower Signature Date
Please forward this document along with the following information to lender and lender's counsel:
V Proof of Income
V Past 2 bank statements
V Proof of any expected income for the last 45 days
V Copy of current utility bill
V Letter explaining reason for delinquency and any supporting documentation (hardship letter)
V Listing agreement (if property is currently on the market)
Zucker, Goldberg & Ackerman, LLC
XCP- 181778
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Deutsche Bank National Trust Company, as CIVIL DIVISION
trustee for FirstFranklin Mortgage Loan Trust
2006 -FF11, Mortgage Pass- ThroughCertificates, NO.:
Series 2006 -FF11
Plaintiff,
vs.
Michelle Roach; William Roach;
Defendants.
REQUEST FOR CONCILIATION CONFERENCE
Pursuant to the Administrative Order dated February 28, 2012 governing the Cumberland
County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies
as follows:
1. Defendant is the owner of the real property which is the subject of this mortgage
foreclosure action;
1. Defendant lives in the subject real property, which is defendant's primary residence;
2. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion
Program" and has taken all of the steps required in that Notice to be eligible to participate in
a court - supervised conciliation conference.
The undersigned verifies that the statements made herein are true and correct. I understand
that false statements are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn
falsification to authorities.
Signature of Defendant's Counsel /Appointed Date
Legal Representative
Signature of Defendant Date
Signature of Defendant Date
Zucker, Goldberg & Ackerman, LLC
XCP- 181778
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Deutsche Bank National Trust Company, as CIVIL DIVISION
trustee for FirstFranklin Mortgage Loan Trust
2006 -FF11, Mortgage Pass- ThroughCertificates, NO.:
Series 2006 -FF11
Plaintiff,
VS.
Michelle Roach; William Roach;
Defendants.
CASE MANAGEMENT ORDER
AND NOW, this day of ,20 ,the defendant /borrower in the above -
captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference
verifying that the defendant /borrower has complied with the Administrative Rule requirements for the
scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that:
1. The parties and their counsel are directed to participate in a court- supervised conciliation
Conference on at M. in at the
Cumberland County Courthouse, Carlisle, Pennsylvania.
1. At least twenty -one (21) days prior to the date of the Conciliation Conference, the
defendant /borrower must serve upon the plaintiff /lender and its counsel a copy of the
"Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet"
(Form 2) which has been completed by the defendant /borrower. Upon agreement of the parties
in writing or at the discretion of the Court, the Conciliation Conference ordered may be
rescheduled to a later date and /or the date upon which service of the completed form 2 is to be
made may be extended. Upon notice to the Court of the defendant /borrower's failure to serve
the completed Form 2 within the time frame set forth herein or such other date as agreed upon
by the parties in writing or ordered by the Court, the case shall be removed from the
Conciliation Conference schedule and the temporary stay of proceedings shall be terminated.
2. The defendant /borrower and counsel for the parties must attend the Conciliation Conference in
person and an authorized representative of the plaintiff /lender must either attend the
Conciliation Conference in person or be available by telephone during the course of the
Conciliation Conference. The representative of the plaintiff /lender who participates in the
Zucker, Goldberg & Ackerman, LLC
XCP- 181778
Conciliation Conference must possess the actual authority to reach a mutually acceptable
resolution, and counsel for the plaintiff /lender must discuss resolution proposals with the
authorized representative in advance of the Conciliation Conference. If the duly authorized
representative of the plaintiff /lender is not available by telephone during the Conciliation
Conference, the Court will schedule another Conciliation Conference and require the personal
attendance of the authorized representative of the plaintiff /lender at the rescheduled
Conciliation Conference.
3. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and
explore all available resolution options which shall include: bringing the mortgage current
through a reinstatement; paying off the mortgage; proposing a forbearance agreement or
repayment plan to bring the account current over time; agreeing to tender a monetary payment
and to vacate in the near future in exchange for not contesting the matter; offering the lender a
deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the
mortgage default over sixty months; and the institution of bankruptcy proceedings.
4. All proceedings in this matter are stayed pending the completion of the scheduled conciliation
conference.
BY THE COURT,
J.
Zucker, Goldberg & Ackerman, LLC
XCP- 181778
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Deutsche Bank National Trust Company, as CIVIL DIVISION
trustee for First Franklin Mortgage Loan Trust
2006 -FF11, Mortgage Pass - Through Certificates, NO.:
Series 2006 -FF11
Plaintiff,
VS.
Michelle Roach; William Roach;
Defendants.
CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE
And now comes Deutsche Bank National Trust Company, as trustee for First Franklin
Mortgage Loan Trust 2006 -FF11, Mortgage Pass - Through Certificates, Series 2006 -FF11, by its
attorneys, Zucker, Goldberg & Ackerman, LLC, and files this Complaint in Mortgage Foreclosure as
follows:
1. The Plaintiff is Deutsche Bank National Trust Company, as trustee for First Franklin
Mortgage Loan Trust 2006 -FF11, Mortgage Pass - Through Certificates, Series 2006 -FF11, (hereinafter
"plaintiff ") c/o Wells Fargo Bank, NA, with its place of business located at 3476 Stateview Blvd., Ft.
Mill, SC 29715.
2. The Defendant, Michelle Roach, is an individual whose last known address is 419 East
Green Street, Shiremanstown, PA 17011.
3. The Defendant, William Roach, is an individual whose last known address is 419 East
Green Street, Shiremanstown, PA 17011.
4. Deutsche Bank National Trust Company, as trustee for First Franklin Mortgage Loan
Trust 2006 41711, Mortgage Pass - Through Certificates, Series 2006 -FF11, directly or through an agent,
has possession of the Promissory Note. Deutsche Bank National Trust Company, as trustee for First
Franklin Mortgage Loan Trust 2006 -FF11, Mortgage Pass - Through Certificates, Series 2006 -FF11 is
either the original payee of the Promissory Note or the Promissory Note has been duly indorsed. A
true and correct copy of said Promissory Note is marked Exhibit A, attached hereto and made a part
hereof.
5. On or about May 19, 2006, William Roach and Michelle Roach made, executed and
delivered to Mortgage Electronic Registration Systems, Inc. as nominee for First Franklin a Division of
Zucker, Goldberg & Ackerman, LLC
XCP- 181778
062 -PA -V3
Nat. City Bank of IN a Mortgage in the original principal amount of $110,000.00 on the premises
described in the legal description marked Exhibit B, attached hereto and made a part hereof. Said
mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on May 31,
2006, in Mortgage Book \Volume 1952, Page 3217. The mortgage is a matter of public record and is
incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the
Plaintiff from its obligation to attach documents to pleadings if those documents are of public record.
6. Plaintiff is the current Mortgagee. By Assignment of Mortgage recorded September
2, 2011, the mortgage was assigned to Deutsche Bank National Trust Company, as Trustee for First
Franklin Mortgage Loan Trust 2006 -FF11, Mortgage Pass - Through Certificates, Series 2006 -FF11
which assignment is recorded in the Office of the Recorder of Deeds for Cumberland County,
Instrument #201124567. The Assignment is a matter of public record and is incorporated herein by
reference in accordance with Pa.R.C.P. 1019(8), which rule relieves the Plaintiff from its obligation to
attach documents to pleadings if those documents are of public record.
7. William Roach and Michelle Roach, husband and wife are record and real owners of
the aforesaid mortgaged premises.
8. Defendants are in default under the terms of the aforesaid Mortgage for, inter alia,
failure to pay the monthly installments of principal and interest due April 1, 2013.
9. As of 10/10/2013 the amount due and owing Plaintiff by Defendant(s) is as follows:
Principal $101,600.93
Interest
From 03/01/2013 to 10/10/2013 $4,632.93
Late Charges $115.56
Escrow Advance $1,015.88
Property Inspections $0.00
Property Preservation $0.00
BPO /Appraisal $0.00
Escrow Balance $0.00
Corporate Advance Credit $0.00
Total $107,365.30
Zucker, Goldberg & Ackerman, LLC
XCP- 181778
062 -PA -V3
plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania Law,
actually and reasonably incurred by Plaintiff, including but not limited to, costs (including escrow
advances) and Plaintiff's attorneys' fees and expenses. Plaintiff reserves the right to file a motion in
the above - captioned action to add such additional sums authorized under the Mortgage and
Pennsylvania Law to the above amount due and owing when incurred.
10. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's
Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and /or
Notice of Default as required by the mortgage document, as applicable, have been sent to the
Defendant(s).
11. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is
not seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so in
a separate legal action if such right exists. If Defendant(s) have received a discharge of personal
liability in a bankruptcy proceeding, this action is in no way an attempt to re- establish such liability.
WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount
due of $107,365.30 with interest thereon plus additional costs (including additional escrow
advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged
premises.
ZUCKER, GOLDBERG & ACKERMAN, LLC
BY: MNLV
Dated: ��� `) Scott A. Dietterick, Esquire; PA I.D. #55650
Kimberly A. Bonner, Esquire; PA I.D. #89705
Joel A. Ackerman, Esquire; PA I.D. #202729
Ashleigh L. Marin, Esquire; PA I.D. #306799
Ralph M. Salvia, Esquire; PA I.D. #202946
Jaime R. Ackerman, Esquire; PA I.D. #311032
Attorneys for Plaintiff
XCP- 181778/rbo
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233 -8500; (908) 233 -1390 FAX
Email: Office @zuckergoldberg.com
THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.
Zucker, Goldberg & Ackerman, LLC
XCP- 181778
062 -PA -V3
EXHIBIT A
Zucker, Goldberg & Ackerman, LLC
XCP- 181778
062 -PA -V3
ADJUSTABLE RATE NOTE
(IABORStx-Month Index (As Published In The ) t a t1 Sneer J rat} Kate Caps}
THIS NOTE CONTAINS PROVISIONS ALLOWING FOIL CHANGES IN MY INTEREST RATE AND MY
MONTHLY PAYMENT. TIIIS NOTE LIMITS THE AMOUNT MY INTEREST RATE CAN 01ANGE, AT
ANY ONETIME AND THE MAXIMUM RATE I MUST PAY.
May 19, 2006 CAMP HILL Pennsylvania
fDatrj Icily) (suit!)
419 East Green Street
SHIREMANSTOWN, PA 17011
fPmMtY AdITWI
i. HORRO'WEN'S PROMISE TO PAY
In return fora loan that I have received, I promise to pay U.S. S 110,000.00 (this amount is called
"Principal"), plus interest, to the order of Lender, Lender is FIRST FRANKLIN A DIVISION OF NAT, CITY BANK OF IN
I will make all payments tinder this Note in the form of cash, check or.money order,
I understand that Lender may transfer this Note, Lender or anyone who takes this Note by transfer and who is entitled to
receive payments under this Note is called the "Note Holder.
2. INTEREST
Imerest will he charged on unpaid principal votli the full amount of Principal has been Paid. I will Pay interest at a yearly
rate of 7,5000%, The interest rate I will pay may change in accordance with Section 4 of this Nole.
The interest rate required by this Section 2 and Section 4 of this Note is the rate I will pay both before and after any
default described in Section 7(13) of this Note.
3. PAYMENTS
(A) Time and Place of Payments
I will pay principal and interest by making a payment every month.
I wilt make my monthly payments on the first day of each month beginning oil July 01, 2006
I will make these payments every month until I have paid all of the principal and interest and any other charges described
below that I may owe tinder this Note, Each monthly payment will be applied as of its scheduled due date and will be applied
to interest before Principal, lf, on June 01, 2036 1 1 still owe amounts tinder this Note, I wilt pay those
amounts in full on that date, which is called the "Maturity Date,"
I will make my monthly payments at 150 ALLEGHENY CENTER MALL, PITTSBURGH, PA 15212
or at a different place if required by the Note Holder.
(9) Amount orMyjnitiat rvionthly Payments
Each of my initial monthly plyroent5 will be in the amount of U.S. S 769.14 This amount
may change.
(C) Monthly Payment Changes
Changes in my monthly payment will reflect changes in the unpaid principal of my loan and in the interest rate that I
must pay. The Note Holder will detennine my new interest rate and the changed amount of my monthly PaYnItnt in
actordunce with Section 4 of this Note,
MIULTISTATF ADJUSTABLE KATE: NOTE -011011 SIX-MONT11 INDEX (AS PVBLISHEV IN THE WALL STRrFrJOURNAL}�—
Singic FainilyFininit Mat Unifon" Italrullitill
arEm STWU 9DI 1) MFCD6051 (Page I af4 pages)
4. INTEREST RATE AND MOINT11T.Y PAYMFNT CHANGES
(A) Change Dates
The interest rate I will pay may change on the first day of June 2008 and on that day every
sixth month thereafter. Each date on which my interest rate could change is c a D
(H) The Index
Beginning with the first Change Date, my interest rate will he based oil an Index, The "Iiulex* is the average of interbank
offered rates for six months V.S. dollar - denominated deposits in the London market ("LIBOR"), as published in The 13 711
Street Joranill. The most recent index figure available as of the first business day of the M611th immediately preceding the
month in which the Change Date occur-, is called the "Current Index",
It the Index is no longer available, the Note Holder will choose a new index that is based upon comparable inf The
Note Holder will give me notice of this choice,
(C) C31tUiStiful Of Changes
Before each Change Date, the Note Holder will calculate my new interest rate by adding Five and Three Eighths
percentage points ( 5,3750%) to the Current Index, The Note Holder will then round the result of this addition to the
nearest one-eighth of one percentage point (0,125 %). Subject to limits stated in Section 4(D) be-tow, this rounded amount will be
my new interest rate until the next Change. Date,
The Note Holder will then determine the Amount of the monthly payment that would be sufficient to repay the unpaid
principal that I am expected to owe at the Clual9c Date in full on the Maturity Date at my new interest rate in substantially
equal payments. The result of this calculation will be the new amount of my monthly payment.
(D) Limits on Interest Rate Change
`file interest rate I an' required to pay at the first Change Date will not be greater then M5000%or less than
One 7,5000 %, Thereafter, my interest rate will never be increased or decreased on any single Change Date by more than
percentage points ( . 1.0000 %) from (lie rate of interest I have been paying for the proceeding 6 months. my
interest rate will never be grtaicr than 13.5000 % 001 less than 7.5000 %,
(E) Effective Date of Changes
My new interest rate will become effective. on each Change Date. I will pay the amount of my new monthly payment
beginning on cite first monthly payment date after the C11411-9c Date until the amount of my monthly payment changes again,
(1) NotiteotChanges
The Note Holder will deliver or mail to me a notice of any changes in my 'interest rate and the amount of my m
payment before the effective date of any change. The notice will include information required by law to be given to me and also
the title and telephone number of a person who will answer any question I may have regarding the notice.
S. B0RROWER'SRJGHTTOkRVPAY-*
I have the fight to make payments of Principal at any time before they are due. A payment of Principal only is known as a
"Prepayrrient". When I make a Prepayrnerlt, I will fell the Note Holder in writing that I aur doing so. .1 ntay not designate a
payment as a Prepayment if I have not made all the monthly Payments due under this Note.
I may make a full Prepayment or partial Prepayments without paying any Prepayment charge. The N ote Holder will
use my Prepayments to reduce the amount of .Principal that I owe under this Note. However, the N H may app Illy
Prepayment to the accrued and, unpaid interest On the PrVaYllient amount before applying my Prepayment 14) reduce the
Principal amount of this Note. If I make a partial Prepayment, there will be no changes in the due dates of nily monthly
payments unless the Note Holder agrees in writing to those changes, My partial Prepayment may reduce the amount of my
monthly payments after the first Change Date following Illy Partial Prepayment. However, any reduction due to my partial
Prepayment may be offset by An interest rate increase,
6. LOXXCIIARGES
If a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest or other
loan charges collected or to be Collected in connection with this loan exceed the permitted limits, then: (a) any such loan
charge shall be reduced by the amount necessary to reduce the charge to the Permitted limit; and (h) any sums already
collected from me that exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refund by
reducing the Principal I owe under this Note or by malting a direct Payment to me. Ifa refund redum Principal, the reduction
will be treated as a partial. Priepayment,
MFCD6051 (Page 2 6f 4 paps)
J8-6775
7. BORROWER'S FAILURE TO PAY AS RFQIJIRED
(A) Late Charges for Overdue Pay men ti
If tire Note Holder has not received the full amount of any monthly payment by the end of Fifteen calendar
days after the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be 5.0000%
of my overdue payment of principal and interest. I will pay this late charge promptly but only once on each late paymeric
(B) Default
If i do not pay the full amount of each monthly payment on the date it is due I will be in default.
(C) Notice of Default
If I am in default, the Note Holder may send me a written notice telling Tire that if I do not pay the overdue amount by a
certain state, the Note Holder may require me to pay immediately the full amount of Principal that has not been paid and all
the interest that I owe on that Amount- That date must be at least 30 days after the date on which. the notice is mailed to me or
delivered by other means.
(D) No Waiver By Note Holder
Even it, at a time when I am in default, the Note Holder does not require me to pay immediately in full as described
above, the Note Holder will still have the right to do so if I am in default at a later time.
(E) Payment rit Note Rolder's Costs and Expenses
If tire Note Holder has required me to pay immediately in full as described above, the Note Holder will have the right to
be paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law.
Those expenses inchide, for example, reasonable attorneys' fee,
GIVING OF NOTICES
Unless applicable law requires a different method, any notice that must be given to me tinder this Note will be given by
delivering it or by moiling it by first class mail to me at the Property Address above or at a different address if I give the'Note
Holder a notice of my different address,
Unless the Note Holder requires a different.metbod, any notice that must be given to the Note Holder under this Note
will be given by mailing it by first class mail to the Note Holder at the address stated in Section 3(A) above or at a different
address i f I am given a notice of that different address.
9. OBLIGATIONS OF PERSONS UNDER T141S NOTE
if more than one person signs this Note, each person is ffilly and personally obligated to keep all of The promises made in
this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note
is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor,
surety of endorser of this Note, is also obligated to keep all of the promises made in this Note. The Note Holder may enforce
its rights tinder this Note against each person individually or against all of us together. This means (but any one of us may be
required to pay all of the amount owed under this Note,
10. NVAMMS,
1 and any other person who has obligations under this Note waive the rights of Presentment and Notice of Dishonor.
"Prcscriunerit" means the right to require the Note Holder to demand paymcirt of amounts due. "Notice of Dishonor" means
the tight to require the Note Holder to give notice to other persons that amounts due have not been paid.
Ti.
This Note is a uniform instrument. with limited variations in somojurisdictions—In. addition to the protections given to the
Note Holder under this Note, a Mortgage, Deed of Trust, or Security Deed (the "Security Instrument"), dated the same date
as this Note, protects the Note Holder from possible losses that might result if I do not keep the promises that I make in this
Note, That Security Instrument describes how and under what conditions I may be required to rnakt immediate payment in
full of all amounts I owe tinder this Note. Some of thostienaditions read as follows:
Transfer of the Property or a Beneficial Interest in Borrower. As used in this Section 18, "Interest in the
Property" means any legal or beneficial interest in the Property including, but not limited to, those beneficial
interests transferred in a bond for deed, contract for deed, installment sales contract or "crow agreement, the intent
of which is the transfer of title by Borrower at a fuiure date to a purchaser.
volm 3520 1101
ITEM SMU 00 1) MFCO5051
......................... ...
If At or any pail of the Proticrty or any Interest in the Property is Sold or transferred (Or if Borrower is not a
natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior written consent,
Lender may require immediate payment in full of all sums secured by this Security Instrument, However, this option
shall not be exercised by Lender if such exercise is prohibited by Applicable Low. Lender also shall not exercise this
option if. (a) Borrower causes to be submitted to tender information required by Lender to evaluate the intended
transferee as if new loan were being 'made to the transk=c; and (b) Lender reasonably determines that Lender's
security will nor be unpaired l the loan assumption and that the risk of breach of any covenant or agreement in
this Security instrument is :acceptable to Lender.
To the extent permitted by Applicable Law, Lender may charge a reasonable fee as a condition to Lender's
consent to the loan assumption. Lender also may require the transferee to sign an assumption agreement that is
acceptable to Lender and that obligates the transferee to keep all die promises and agreements made in the Note and
in this Security Instrument, Borrower %ill continue to be obligated under the Note and this Security Instrument
unless Lender releases Borrower in writing,
If Lender exercises the option to requite immediate payment in full, Lender shall give Borrower notice of
acceleration. The notice shall provide a period of not less than 30 days from the date the notice is given in
accordance with Section 15 within which Borrower must pay all sums secured by this Security Instrument, If
Borrower fails to pay these sums prior to the expiration of this period, Under may invoke any remedies permitted
by ibis Security Instrument without further notice or demand an Borrower.
Borrower has executed and acknowledges receipt of pages I through 4 of this Note.
WrrNl1-$S THE HAND(S) AND SF-AL(S) OF THE UNDMIGNED
1 4 uctt,�
—(Seal) & _(Seal)
WILLIAM ROACH -Barrower MICHELLEROACK
(Seal) (Seal)
-Borrower -Poffower
—(Seal) (seal)
•Borrower -Borrower
Pay to the order of PAY TO THE ORDER OF
NSI Franklin Financial Corporation
wboot recourse WITHOUT RECOURSE [Sign Original Only]
FirstFrInklin,adivisionoIN 'onalCity AMP rta FIRST FRANKLIN-FINA CIAL CORP
LtgrANWL
THE PREPAYMENT NOTE ADDENDUM ATTACHED HERETO AND MADE,A PART HEREOF
AMENDS THE PREPAYMENT PROVISIONS OF THIS NOTE 4a– __AL — — — —
Wft.tt twakfi Worts 101tWo WOW% 1.10st.
Form 35201/01
ffEM 5750 ( MFCDG051 (PoSe, 4 014M-) 1
PREPAYMENT NOTE ADDENDUM
This prepayment Note Addendum is made this 19th day of May 2406
and is incorporated into and shall be dcetned to amend and supplement the Note of the same date (the "Note") given
b th unde (the "Bot'rowar „ ) to evidence Borrower's indebtedness to
FIRST FRANKLIN A DIVISION OF NAT, CITY B ANK OF IN
(the "Lender "), which indebtedness is secured by a Mortgage, Deed of Trust or Security freed (the "Security
Instrument "), of the same date and covering the property described in the Security Instrument and located at:
419 East Green Street
SHIREMANSTOWN, PA 17011
ADDITIONAJ, COVENANT'S. Notwithstanding anything to the contrary set forth in the Note or Security
Instrument, Borrower and Lender further covenant and agree as follows:
1. Section 5 of the Adjustable Rate Note, is modified to provide for a prepayment charge upon Bo rower's full
prepayment. A "full prepayment" is the preprynrrt of all of the unpaid principal due under the Note. A
prepayment of only pan of.tbe unpaid principal is known as a "partial prepayment."
Borrower can snake a partial prepayment at anytime without paying any charge. Borrower may make a full
prepayment ut anytime subject to a prepayment charge as follows:
If within the first 24 months after the date Borrower executes the Note, Borrower makes a full prepayment
(including prepayments occurring as a result of the acceleration of the maturity of the Note), Borrower must, as a
condition precedent to a full prepayment, pay a prepayment charge on any amount prepaid in any 12 month period
in excess of 20% of the unpaid balance. 1lic prepayment charge will equal the interest that would accrue during a
six -month period on the Excess Principal calculated at the rats: of interest in effect under the terms of the Note at the
time of the fall prepay mcnt.
2. All other provisions of the Note are unchanged by this addendum and remain in full force and effect.
NOTICE10 IiCiitR+C,i'WER
i)o not sign this loan agreement before you teat! it. This loan agreement provides for the payment of a
penalty if you wish to repay the loan prior to the date provided for repayment in the loon agreement. i
BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in the Prepayment
Mote Addendum..
_(Seat) Cu t
WILLIAM ROACH ntn"waT' MICHELLE ROACH t3¢r<UWeC
; (Seal) . _ (Seal)
- r}nrrawer - t3orro + ;er
(Seat) (Seal)
•BCWT0 Cr - Uorrower
Adlastable Rate Prepayment Note Addendum - First Lien — AK, At„ A7 CA, CO CT, DC, DE, FL. GA, Hi, ]A, ln, ICS, LA, MA, MD.
;stN, MT. ND, NE, Nil, NJ, N \1, NV, NN, OK, tilt, PA. 111, SD, TN, TX, UT, VA, V'r, WA, WV
F CO$0 1 —�
EXHIBIT B
Zucker, Goldberg & Ackerman, LLC
XCP- 181778
062 -PA -V3
ALL MAT CERTAIN piece or parcel of land with the buildbgs and Improvements thereon
erected siUMO in the Borough of Shiranaustowo, gland County, Pa nsylvanta, bounded and
de Gibed as Mows, to wit: ✓
BEGINNING at a point an the northerly flue of 9MW Street, which point is 105.96 feet
westwardly of the northwesterly canner of Careen St+ect and St. John's Chumb Road at a point 01 foot
Past of the dividing line between Lots Nos. 24 and 29 on the heralnattar towdioned plan of lots, thence
along the northerly line of Careen Stteet'aforosaid, South 77 degtm 07 ikutes West, 53.02 feet to a
point; thence through Lot No. 29, North 10 dagreos 19 minutes 52 seconds West, a distance of 60.03 feet
to a point; them by the same. North 13 degrees 13 minutes 39 4wea ds 'West, a diet a e of 50 feat to a
point at Lot No. 23; tho= by Lot No, 23, North 76 degrees 46 minutes 21 seconds Bast, a distance of
60.68 foot to a point in Lot No. 24; thenoe through Lot 24, South 08. degrees, 43 minutes 16 aaeonds Past,
a dl$tanae of 110.58 feet to a point, the pllaoa of B10314NING.
BMNQ PARTS OF Lot Nos 24, 29, and 32 on plan of Lots known as Orchard Hilda, recorded
in the'C timberland County Recorder's Offte In Plan Book 6,.Pq* 22, sad having therron erected a ore
and one-half story shWo brick and Brame dwelling known as 419 Omen Street.
UNDER AND SUBJECA NEUR'TIIEMM, to tfi8e t6, restrictions, and rights -of -way set
forth in prior inauumeuts of record,
B{:I952PG323I
3 ,
VERIFICATION
Carol Adams, hereby states that he sh is Vice President Loan Documentation
of WELLS FARGO BANK, N.A., mortgage servicing agent for plaintiff in this matter that
he/ i is authorized to make this Verification, and verify that the statements made in the
foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his he
information and belief. The undersigned understands that this statement is made subject to the
penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
Further, due to its mortgage servicing agency relationship with plaintiff, WELLS
FARGO BANK, N.A. is in possession and control of all documents and records supporting the
statements in the foregoing pleading and, therefore, the undersigned, rather than an officer or
employee of plaintiff, is the appropriate individual to make this Verification pursuant to
Pa.R.C.P. 1024(c).
(24
Name: Carol Adams
Title: Vice President Loan Documentation
Company: Wells Fargo Bank, NA
Date: 10/11/2013
085 -PA -V2 File # 181778
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny RAnderson -G i ll�
Sheriff E` HE PRO THONO TA,
Jody S Smith
Chief Deputy c0 13 NOY 12 AM 10: 4 7
Richard W Stewart CUMBERLAND OOIJN 1 y
Solicitor F'ENFISYl.VAtfA
Deutsche Bank National Trust Company
Case Number
vs.
Michelle L. Roach (et al.) 2013-6269
SHERIFF'S RETURN OF SERVICE
10/31/2013 04:06 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by
"personally" handing a true copy to a person representing themselves to be the Defendant, to wit:
Michelle L. Roach at 419 E. Green Street, Shiremanstown Borough, Shiremanstown, PA 17011.
RYAN BURGETT, DEPU
10/31/2013 04:06 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing
a true copy to a person representing themselves to be Michelle Roach,wife, who accepted as"Adult
Person in Charge"for William Roach at 419 E Green Street, Shiremanstown Borough, Shiremanstown,
PA 17011.
RYAN BURGETT, DEPUTY`
SHERIFF COST: $60.95 SO ANSWERS,
November 04, 2013 RbNW R ANDERSON, SHERIFF
°
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
.---„ _r
.---„ ,
Deutsche Bank National Trust Comnpany,as [/V|LD|V/S|ON �— �-
`
tru�eefmrR�t FnankUn��n�QageLoanTrust o
ZOO6fF11,K8o�gagePass�hrough[erti�cate� NO.: 13-06269 '1
Series 2006'FF11 �`17 �� �--�
c ��—
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^=
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���heUeRoach; VVU|iamRoach; ~+
Defendants.
CIVIL DIVISION
Plaintiff,
PRAECIPE TO SETTLE, DISCONTINUE AND END
TO THE PROTHC)NOTARY:
Pleasennarkthecasefiledattheabove'captionedtennandnumberSEl7LE0,0ISCONTIN0ED
and ENDED, without prejudice.
Respectfully Submitted:
m.- �m'
/ � ���__�
BY:
Scott A. Die,. -rick, Esquire; RAiD.#SS6SU
Kimberly A. Bonner, Esquire; PA|.D.#D97OS
Joei A. Ackerman, Esquire; PA|.D.#IO2729
Ashleigh L. Marin, Esquire; PA I.D. #306799
Ralph M. Salvia, Esquire; PA I.D. #202946
Jaime R. Ackerman, Esquire; PA{.D.#311O32 --
Jana Fridfinnsdottir, Esquire; PA I.D. #315944
Brian Nicholas, Esquire; PA I.D. #317240
Denise Carlon, Esquire; PA|.D.#317Z26
Attorneys for Plaintiff
X[P'181778/dcr
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX