HomeMy WebLinkAbout05-1116
AVISO
LE HAN DEMANDADO A USTED EN LA CORTE, SI DESEA DEFENDERSE CONTRA LAS
QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO
DE 20 DIAS DESPUES DE SER SERVIDO CON EST A DEMANDA Y A VISO, PARA DEFENDERSE ES
NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL
PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA
DEMANDA.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, P A I 7013
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 twenty (20) days after the 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 claim in the Complaint
of for any other claim or relief requested by the Plaintiff, You may lose money or property or other rights
important to you,
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW,
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER,
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE,
LEGAL SERVICES INC
8 Irvine Row
Carlisle, P A 17013
717-243-9400
C;o,{
/&..""\
Term
No,OS- -lilt:,
CIVIL ACTION: MO~TGAGE
FO~eCLOIUf\E
Defendant
ROBERT L. SHOFF
Mortgagor and Real Owner
26 Maple Avenue
Walnut Bottom, PA 17266
ACTION OF MORTGAGE FORECLOSURE
vs.
Plaintiff
CIVIL ACTION - LAW
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE FOR LONG BEACH MORTGAGE LOAN
TRUST 2004-5
9451 Corbin Avenue
Northridge, CA 91324
OF CUMBERLAND COUNTY
IN THE COURT OF COMMON PLEAS
GOLDBECK McCAFFERTY & McKEEVER
By: JOSEPH A. GOLDBECK, JR.
ATTORN.E;Y I.D. #16132
St;ITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
(215) 627-1322
ATTORNEY FOR PLAINTIFF
This Action of Mortgage Foreclosure will continue unless you take action to stop it.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
1), Call an attorney, For referrals to a qualified attorney call either of the following numbers: 717-243-
9400 or .
2), Call Pennsylvania Housing Finance Agency at 800-342-2397 for a counseling agency in your
neighborhood,
3), Visit HUD'S web site www,hud,gov/officeslhsg/sfuleconlecon,cfm for Help for Homeowners Facing
the Loss of Their Homes,
4). Call your lender 866-926-8937 and ask to speak to someone about Loss Mitigation or Home
Retention options,
5), Call or contact our office to request the amount to bring the account current, or payoff the mortgage
or request a Loan Workout / Home Retention Package, Call Carol at 215-825-6329 or Nancy at 215-825-6358
or fax 215-825-6429 or 215-825-6458, The figure and/or package you requested will be mailed to the address
that you request or faxed if you leave a message with that information, The attorney in charge of our firm's
Homeowner Retention Department is Edward Sparkman who can be reached at 215-825-6318 or Fax: 215-825-
6418, Please reference our Attorney File Number of WM-0495 ,
Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you
still may be able to SAVE YOUR HOME FROM FORECLOSURE,
ACT NOW!
Resources available for Homeowners in Foreclosure
TillS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT
A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROMYOll
WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
RECUERDE: SI USTED NO REPONDE A EST A DEMANDA, SE PUEDE PROSEGUIR CON EL
PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A
FAVOR DEL DEMAND ANTE Y REQUERlRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES
DE EST A DEMANDA, POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER
DINERO, PROPIEDAD U OTROS DERECHOS IMPORT ANTES ,
USTED DEBE LLEV AR ESTE P APEL A SU ABOGADO ENSEGUIDA SI USTED NO TIENE UN
ABOGADO, V A Y A 0 LLAME POR TELEFONO LA OFICINA FIJADA AQuI ABAJO, EST A OFICINA
PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO.
SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE
INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS
ELIGIBLE AQ UN HONORARIO REDUCIDO 0 GRATIS,
LEGAL SERVICES INC
8 Irvine Row
Carlisle,PA 17013
717-243-9400
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG
BEACH MORTGAGE LOAN TRUST 2004-5, 9451 Corbin Avenue, Northridge, CA 91324,
2, The name and address ofthe Defendant is ROBERT L. SHOFF, 26 Maple Avenue, Walnut Bottom, PA
17266, who is the mortgagor and real owner of the mortgaged premises hereinafter described.
3, On June 10, 2004 mortgagor made, executed and delivered a mortgage upon the premises hereinafter
described to LONG BEACH MORTGAGE COMPANY, which mortgage is recorded in the Office of
the Recorder of Deeds of Cumberland County as Book 1869 Page 2102, The mortgage has been
assigned to: DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG
BEACH MORTGAGE LOAN TRUST 2004-5 by Assignment of Mortgage, which assignment is lodged
for recording, The Mortgage and Assignment(s) are matters of public record and are incorporated by
this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g) which Rule relieves the
Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public
record,
4, The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit
"A",
5, The mortgage is in default because monthly payment of principal and interest upon said mortgage due
September 01, 2004, and each month thereafter are due and unpaid, and by the terms of said mortgage,
upon default in such payments for a period of one month, the entire principal balance and all interest due
thereon are collectible forthwith,
6, The following amounts are due on the mortgage:
Principal Balance
Interest from 08/01/2004
through 03/31/2005 at 7,0500%
Per Diem interest rate at $12,81
Reasonable Attorney's Fee
If the Mortgage is reinstated prior to a Sheriffs Sale the
Attorney's Fees may be less than this amount based on
work actually performed, The Attorney's Fees requested
are in conformity with the Mortgage and Pennsylvania
law, Plaintiff reserves its right to collect Attorney's fees
of up to 5% of the remaining principal balance ($3,317.31)
in the event the Property is sold to a third party purchaser
at Sheriff's Sale or if the complexity of the action requires
additional fees in excess of the amount demanded in the
Action,
Late Charges from 09/01/2004 to 03/31/2005
Monthly late charge amount at $26,64
Costs of suit and Title Search
$66,346,10
$3,112,83
$1,250,00
$186.48
Fees
$900,00
$71,795.41
+$92,60
$71,888,01
7, Plaintiff is not seeking a judgment of personal liability (or in personam judgment) against the Defendant
in this Action but reserves it's right to bring a separate Action to establish that right, if such right exists,
If Defendant has received a discharge of their personal liability in a Bankruptcy proceeding, this Action
of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was
discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to
Pennsylvania law,
8, Notice ofIntention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has
been sent to Defendant by Certified and regular mail, as required by Act 160 of 1998 ofthe
Commonwealth of Pennsylvania, on the date( s) set forth in the true and correct copy of such notice( s)
attached hereto as Exhibit "B", The Defendant has not had the required face-to-face meeting within the
required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant
through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit
Counseling Agency,
WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $71 ,888,01,
together with interest at the rate of$12,81, per day and other expenses incurred by the Plaintiff which are
properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law, and for the foreclosure
of the Mortgage and Sheriffs Sale of the Property,
By:
y~~
GOL
VERIFICATION
I,
CASSANDRA INOUYE
as the representative of
the Plaintiff corporation within named do hereby verify that I am
authorized to and do make this verification on behalf of the
Plaintiff corporation and the facts set forth in the foregoing
Complaint are true and correct to the best of my knowledge,
information and belief. I understand that false statements therein
are made subject to the penalties of 16 Pa. C.S. 4904 relating to
unsworn falsification to authorities.
-- ,
Date: f<dJhAo.ry () q/ roar
DEUTS BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR LONG
BEACH MORTGAGE LOAN TRUST
2004-5
#0665594766 - ROBERT L. SHOFF
06/14/2884 16:31
717243185.
MDWO
.
PAGE 21/21
Schedule A
ALL those two certain pieces orparcelll of1~d situa~ in South NCl'WtOn Township; County of
Cumberland and State of Pennsylvania, bounded and described IIlI follows. to wit:
TRACT NO.1: llEGINNING at an iron pin in the center of the public road leading from Jacksonville ta
the Stoupstown publio road also known as Maple Avenue; thence by the center oithe same, North 36
degrees West, a distance of 29.8 feet to an iron pin in the center aHhe publi~ tOad; thence along lands,
now or timnerly of John Robinson, South 57 de~ 40 minutes Wesl. a distance of 161.2 feet to a st8ke;
thence by lands now or formerly of Clarence Ga:rduer. South.37 degrees 40 minutes East, a distance of
[34.3 feet to a stake; thence by lands now or formerly ofMrs, John Myers, North 41l.) degrees East, a
distance of 16.9 feet to a. post; thence along lands now or fonnerly of Lena B. Tbxusb Estale and being
Tract No.2 hereinaflet" de=ibed, North 41 degree 3 () minutes W cst, a distance af 83.4 fectto a stake,
thence oontinuing by lands now or f011lllll'Iy 01 Lena B, Thrush Estate and being Tract Na. 2 hereinatler
described, North 51 degrees 30 minutca East, a distance of 147.6 feet to tho place ofBEGINNlNG,
CONTAlNlNG 0.55 aczes.
TRACT NO.2: BOUNDED on the East by the public road leading from Jacksonville to the Stoughstown
public road also lmown as Maplo Avenue, on the North and West by lands now or formerly of tile Estate
otLena B. Thrush, being Tract No.1 hereinafter described; and on the South by land DOW or fot1ocr1y af
Jolm Killinger and Mae Killingea-, his wife, contaWng one-fourth acre, more or less.
The: above two tracts ofland COYrtaining a total frontage of 96 feet more or less, imd being improved with
a dwelling houso, known as 26 Maple Avenue, Walnut Bottom, South Newton Township. Cumberland
County, Pennsylvania. .
BBlNG the same premises which Clinton L. Craig and Cynthia C. Craig, husband and wife. by Deed
dated Novmnbet 19, 2001 which Deed is recorded in the Office of the Recorder of Deeds in and for
Cumberland County, Petmsylvania. Deed Book 249,Page 1604, gnmted and conveyed unto Cynthia C.
Craig.
Fob-2S-05
01:41..
From-
T-045 P.002/001 F-510
Washington Mutual
9451 Corbin Aveoue
MailsIOp NO] 0207
Northridge, CA 91328
0665594768
November 16, 2004
#BWIIlCLNIIl#
#0906659594976894'
QOOB::III: IPA
ROBERT L SHOF=F
26 MAPLE AVE
WALl\4uT BOTTOM PA 17286
WE ARE A DEBT COLLECTOR, THIS IS AN ATIEMPT TO COLLECT A DEBT, AND
ANY INFORMATION OBTAINED WILL BE USED FOR TI-lAT PURPOSE.
PLEASE REVIEW THE DEBT VALIDATION NOTICE ENCWSED
NOTICE OF COLLECTION ACTIVITY
~: ACCOUNT # 0665594768
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
Thio; 1';':lIT! offtr!fl'll 'I'It'nicl! thBt 1hp. mtrrtll':lPl! 011 yRllr hnmf! io; In dp.fsmlt .:ll'ltl t'hll''''TUI_ iTlhlnrl.. to fl'lrTcl~ ~...r.iTlr: ;nmrm~tinl'l t1hnnf the
nll~h'l!'! h( tht' n",r~nh ;c T'lrnvided i'l'l tnr Jl1'fl'lll"lu.~l l1:i1"'....
'nI... HOMp.nWN'PJl'~ MnR'T'(;Ar.F. Ac;~rc:T'^N'r.F PRnIlll'AY fMp..M"P~ 1'l'.IJlV hi' 1I'h1~ tt\ hl!'lp Tn 4:1vt'l vnnT' t!(\m",
Thk Nm~"'~ "''W1:Dno; t1nw ,'10.... nrn~m ,.,..,rk-o;
Tn cl!ll.lfHRMAP t'JlTl h4!l\'11 YOu m1~1 MFF.'l' W1TH A r.nNotfl'h.(l:;'Q rn~nIT C"OIJNI:'I=lrmr,. An'P.Nf"VWlTMIN
:l,n n^~ {'"')f;"l"J.i'H nAT~"1= TJ.JT~ Nn'TTr'Fl T;lt,.... Th;IINnll~I'!!~"h ynu wnrn 'Vnll ~~~"'Wit'h lnl'! (".nnnCl!HIl.f' A.Prnl"V
Thill !'lilT"",,! n,MT_ JI'Il.tt nhnn.e nll1'I'Ilv-T nf C":'tm'hl1'1'1f'!r t"n-rih rnnft..:ell.n.. A~n"'ip.~ qrryjl'lll' vl'tnr ("'.lmntv ~tf: l;~.n lit r'hlfl! pru~ nf tllill N'oti~ If
ynn t1!1yt'! lInv t'I'ul'l't;n....'Il 'Ym. may "::111 t'hl' Prnn"lvlv.1l'1b Hnm:lnll' Fiil:lnr.... AtI"n~ Inn frl!e ~t 1.PIItI_~2_'2C\07 f1I'M"VlnS .."nth ~'l'ad
h~M'm9 ,."n I"'!Irll 1117\ '7l\n.. 1RfoR'l
TbUi Nota'. COIltUn' importadl !qw informatiQu. If,.h hllYt OIny qllestjon" rtPl'csmtadftl at the Consbmer Credit CoWWiclin,Jl' Agent)'
m.ay b~ able to help aplaid it. You ma,. alsa want to COntact. an attorney in your :at~. 'The 1oC31 bar a"ociatkm DUl1 ~ ab~c to helP.Y01I
find a. laWJ'cr,
LA I'fOTlFlCAClON EN ADJUNTO ES DE SUMA 1MPOR'l'.l.NCIA, Punl AFECTA SU DEREClIO A CONTINUAR VIVIE!IllO EN S\j
CASA, SI >l0 COMPllE>mE EL CONTENR>O DE ES'l'A NOTIFICAClON OBTllNGA UNA 'I'IlADUCCION 1NMED1TAMl!.N'l'l;:
LLAMANDO ESTA AGENCIA (Pl!.I'INSYLVANlA HOUS1>lG FlNANCl! AGJ;NCY) SIN CARGOs AI. NUMERo MENClONADQ ARRIBA,
PUEDllS SER ELEGlILE PARA UN }tUSTAMO PoR EL PJtOGltAMA Ll.A.M.A.DO ItJ{OMEOWNER.'8 :EMERGENCY MORTGAGB
ASSlS'l'ANCE PROGRAMu:m.. CIJAL PUEDE SALVAR Sf) CAsA DE LA PIl:RP1DA D~I.. DERECfIO A REDIMIR SU HlPOTECA.
SP'"
Fob-28-05
09:47a.
From-
,-045 p,OOS/009 F-570
HOMEOWNER'S NAAIE(S).
Rabert L. Sholl'
PROPERTY ADDRIlSS: 26 Maple A~
WalnulllotlOlll I'A 17U6
LOAN Acer. NUMBER: 0665"'4768
ORIGmA.1. LENl>ER: LIml
CURRENT LENDERlSERVlCER: WashinilOD IIIutual 11"",. Loans. Ine,
ROME;O\VNElt'S ~GENCY MORTGAGE ASSISTANCE PROGRAM
yOU MAY BE ELIGlBI,E FOR FlNANCIAL As.'nSTANCE WHICH CAN SAW YOlJR ROMI;;
FROM FORECLOSURE AND R'RJ.P 'l'OU MAKE F'ImJRE MORTGAGE PA'VMIlN1'S.
IF 'l'OU COMPLY WITH TIlE I'ROVISIONS OF 'I'IfE IIOMEOWNER'S nmRCENCY MORTGAGE ASSiSTANCE ACI' OF
1?1l3 (THE "ACT"). YOU MAY liE ELlCIJJLB FOR EMERGENCY MO,aTGACI!: ASSIS'I"t.NCE>
. IF YOUR DEFAULT HAS BEEN CAUSRl) BY C1RctJMSTANCEs BE'l:'OND YOOR CONTROL.
. IF YOU HA VI! A REASONABLE I'ROSPECT OF BEING ABLE TO PAl' YOUR MORTGJ\GIlI'AYMENTS, AND
. ill' YOU MEIlT OTIIER BLlGIlIILITY llllQ{JIREMENTS EST~)) IJY Till!. PIlNNS11L V ANlA 1I01JSmc FINANCE
AGENCY,
'nl:MPllYlARV ~AV ov vnDRl':I.rnO"nnr. ~ Under tl1e Act,. you liTe totitl.:! to a temporary nay offote.clo9U'r.a OJ\ ~UT mor~ for thiff)'"
(30) daY' fr(Il"I'I the dale of this. Notice.. 0\11'1'1'1& that time you m.ust (u'r:a.n.,c md auend II 1lra.:e.tQ.~11 m~ting wi.th oue of the OO'AS\JllIel
~redit CO\lnseJi1'l.1 asencies listed &t the l!:n4 ofmu. Noliee-. Tl-I"I~ M1I'1nTN~ MTr~ nt"I""ITl;! WT'J'R'JN 'nI'F. 'NJi!Y'r nul) nAV';; ~ von nn
NOT APPLY FOR. EMRR(';F:nr.Y MORTGAr.F. A~SlSTA.N~ V011 Mn!IT R1HNG YOlJR MnRT(;Ar.r:r. UP TO rJA"J"'C! TRP PART
Of THr!'i: N'tl'TI'r.~ rAT.r OPt) "H("')WTn r.ImF. VntN MORTnAnF. n'ftll'AllT T\.\ 'J'.!'XPI ATNS ~nWTO ~RrNr. VOTTA: MORTnAn'Fl.
UP Tn nATR
~nN!il.lrMn ("'1I'1O'nlT ~tn1M:lcr.JN(; AOF.N'l"I'6:!ii' . !f)'ou meet wh:h one of ll1lJccm.SUtlW" credit counse.ling aJl2.'ncies llstm.a:t: ;h.e end af
this nQtlGe. thl!. len4e.'l' may NOT ta~ eet.i@ qa1Jl!Jt )'QI.! fur thin)' ~O) daY' after tbe date of this 1tIC$tin~ The n'lilmr'll ""ih'e$tr.i llnd
fll!lennnne numh!!" ot d...'ti~:l.f'('zl ~M\"nmCT cNdit C71nnvl'il'lll ~.-.nr!ll"'I fnt the mun'lv;n "hieb tn~ ProDflrtv I.. "........"....1 aW! ~ foMb :It ,hll!
end nf 1M'!; Nntl~,. It is only I\6casSBty lO xohcdule otle mcc.to--face m~ting. Advise your h:lIldel' immrrlrBtflly of your lntentioruL.
,APPl.'rrATlnW Mil 'Mnll~A.O'F. ...q~'~ANt!F.- YOllr monpge udn defa'ult fer the 1'tUJI13 set forth later in lhis; Noliee (se!l fullQWing
pages for spcclflc.lnformatiQn .bout thm nlt1.m~ Dfyaul" def3.uh). If)'OU hiNC uied, cmd aJ'e unuble10 resolve this probltm with lbe Jender,
you have the Ti,flht to apply for financial esistance from the Homeowner's El:t1~ey Mort~ AsaiswJce Program. To do JO,)'OP must
fill Q\\"t, lAgn and fil" eompl"e4 HalJU!:OWt'Icr':!i Emergency ~l'I'tJnce Program A:pplic;.Q.tiQR with on~ of the designated OODS\llttClT cmdit
c:oun5ll11.ng. 3.gencla HStea a.t the enll of this Notlc~ Only con~um.r credit couftsellnti: a;ent;iQi haw applk.atiCll$ IOY ,be proW3m, and they
will <11lls1 you in S\1bmtrting,;a. c:.Qmpletc application 10 the Pennsyt'\l3nia Housing Fin.ance Agency. Your appUc'Idon MUST b. filed. Or
pOStma.r)r;cd wilhil1: thin,. (3Q) day,infyour fac.e-w-fau mCftlng.
YOU MIJST FILE YOUR APPLICATION PROMPTLY, II' vau FAJL 'TO DO 50 OR IF YOU IlO NOT FOu.oW TlIE OTHER TIME
PERJOl)S SET FO'D:TH IN TIllS LE'M"SR. l<'ORECLOStIRE MA. V 'tllOCEED ACAlNST VOlJR HOME IMMEDTA 'rELY) A.1'Ir.O YOUR
1t.?PLlCATJON FOR MORTGAGF.: ASSISTA.NCE WILL BE DE~IED.
AGli:.NC'.V A.C':TION - Available fun49 for emergency mortgage a!ii~'tanee il.re vcrylimittd. Tl\ey wUl __ ~nllobutsed 'by tl1e A&encYtlTlder lh.c:
eligibility criteria establl.!lhed. by the Act. The Ptnnsylvania HOUsing Financ:e. Aucm:y bas siny (60) day-. tQ. mak& lit drci~on after it U!ce1\1'e$
your llpplication. D\ltlnc. 'tbat "me. no fo-rec1DSUre proceedings will be pursued a~n!i"[ YOl,l. i1yau h~v" 1:t\f1t the. time. 'tCqU1.l'lltneTl'ta set
forth above. YOu win be noti:5ed c1irec;tly by lbe Pmnsylw,nia Housing: F1nancc Agency of 11$ ~eeisi~n an your applicatiQn.
NOTll.o IF YOU AR'E: CUltRENT\,Y PROTEC'I'ED BY TIre FILING OF A PETITlON 'N BANKRUPTCY, THE
FOI.LoWING PAJrr OF TIDS NOTICE Is FOR INFORMATION pURPOSEs ONl,. Y AND SHOULD NOT JIll
CONSIPEIlIlD AS AN ATl'EMPT TO COLLECl' TIm Oil"",
(It you h:a\'@flled bankrupkY, you rail ltiJJ aJl~" tor Bmergel1C)' Martp'" A&1iwanee.)
F.b-28-05
01:41a.
F rem-
r-04S P.004/001 F-51G
OQQll"~8'S~"!I.!I
-
HOW 'to CURJi!. YOUR MOJlTr..4.GE J)EPAUl~T fBrin~ It un to uta).:
NA.Tt!:RII': nFTJ.fR OF,U'A.111 T.. The MORTGAGE debt held by the above lendo1I' on)'cur prt;lpertylot.tted a.t:
26 Map1All Av~
WalU\lt Bottom PA J72G6
IS SERlOUSLYIN OEFAIJLT BBCAlJS~
Ncm"payment
^. YOU.flh V~ NOT MADE. MONTal.Y MORTGACE PAYMENTS fur the foUowmg. months atln the fi;)]lowins alnOQ'Ots an 1'l(Iw
~due:
MOl1tb.ly I.Q~uallmenu:
0910>1201)4
10l0In004
llillll2llU'
S444,OO
"",00
$444,00
Other cb.arSlUl (f.XplainJittmiu:):
US1G01l~ Latc Ch:l.r&cs
U:l1Callill:~cd.f'~
CorpOrate adv:mcs,
t.mCredits
TOTAL A""OUNrpAST DUE<
B, YOU llA VE FAIJ.ED TO T Al<E THE FOLLOWING ACTION (NQI .ppU"'b1.):
HOW TO r.wrRlt THF. DD4tl1 'J - You may cure th~ ~efauh within mIRT"l (30) DAYS of the dine of this DOn" BY PAYING THE
TO'l'AL AMOl.lNT PAST PUE TO THE LENJ)ER, WHlCH IS $1411,92, PLUS ANY MORTGAQ1! PAYMENTS AND UTI> CHARGES
WHICH BECOME bIJE PU'lUNO THE 'tHIRTY (30) DAY PERlOD. 'Pn~1"n11t 1"I'l1lo:t M ft'lM... ~1thp1' ~ CIl,h PlI"hill!ol"'< r.twr.1t .........lArd
clleck nr mnnlN mri~ mo1de. P."I'VlIhlR lI.nd <Ml't 't~
J19.92
10,00
10,00
$0.00
$1411.9%
WubiJ\ttVn Mptu:al fhml! LoQn:f,lne.
9451 Corbin A."PUUI
Nonbrid.c., CA 91.324
You """- ""'" ."y other clofaull by ..killg 1:lw /o1lowing &do~ wilhi" THIRTY (30) DAYS of ,be cL1., of Ihls leI."" (NolOoo.,0I>1.),
IF vml no NM nrv1i'. 'TAl!: DRFAITI .T - ffyou do tlot cu.re. tbe ddanlt within THIRTY (30) DAYS of the. Qirtc Df'lbis Notice,. thfI '_d....
t",t~.h: M .....,,~_ it'"- ..,"ok..n .~1_..... tlw ~p_ "..... This. meam Nt. the e:rnil"t outstandh,& balance of \hia dew will be considered
due i.mmed.iattlly. and you may lose the the: ehant:C to pay me mortgage. in U\,Qn11l1y installments. tffUll ps:yment of'tbc"tQtal amount: put
dUll is nOt mJ.de. within THIRT'{ (30) DAYS. the: lender also iMends to Insll'Uet its at\O'tnC)'! tg stat't lep.l K'tJ,oP to rll.--I__ "pM" l~''f'
mru't$>lvll nmben:"
.'Ii" T~ ~"r:An'R D1l1l'n'RF.l'!r.l'Wlm TTPtlN'The mongaged property win '-so14 by the' Sheriff'to pay,oHthe mort:pge dEtn. Tflbll!l
ICJJder refcn)'O\11' eak tQ iCS aUorn~i, but yOn cure the 4tHnq'Qerlcy btror. the 1ende1' 'otgi.re; le1111 prottlaiiibj;t against you, you wi1I Jtill be
l'tquin:.a to pay th~ I'laIOtlahle IItlOrney"$ feu that wen: actually ir:Il:.\11'T8d, up tQ $50.00. However, it legal p~np are Stan;" against you,
you will have tOo pay ,n rea!onable <1tu1tlCry's fee.! ~uallr inl:urred by 'tl1e lender even if th.y e'lCued $50.00. Any a.t'tOffley's fees win be
sddt!l.d. to. the amo~nt you awe. thll lender, whi.-h"RlJJ.'J al~o include O1:hcTt'8Q01\ab1e~ostj. "vall ('"....11111' dP.f\lnlr: ....11"" the TAlRTV r.M)
1). Y n.....d \16M wil1 11M: h,. rlll'lUtl'f!d b1 DlIT attnl"'lll"~ "eM_
OTIi'F..R I,'F.I'm1r.Jl RRMnlTF$l_ The lender may a1so s:ue yon pa'SGnaUy fDrthe upaid principal bala1lceand.u other mms due under 'Che.
mot'tgagt...
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Pob-28-05
01:48am
Prcm-
T-046 P.005/001 P-570
RTGlrT m r.[1RR TIlt;: OW....... rTT T 'PIITOR Tn J31TmTFPIS:! SALE. - If ytJU h:l'Y1I! not (:l,JTM l.he ddaul.1 within the. THIRTY (30) DAY period
and .&:lrcclost.lre proceedings have be&un., "011 nt.v 11'/;11 l'IJn'~ rllf!. rilJ!ht 10 Con.... Ih~ ""''''lilt lint! T'Jt"I'!vronr fhr: !lUll at :ilny 'imp. up ,,, An.. hn.\II'
hnfnM .hp. ~h",t';fF'<;. lIl:!lll!!. You "'~ do v. ~ p"ylnr ~'hl'! tn.JI\ t1....^..nt ill.." nRCl' dm: pin.. ;my bfl'! nr nthP.r I"'hJl'Ptl';.1 tllM] dl1t": rl!a.~rnI:lhlA
lInO!l'P1~y"4 fW>.q .llI".lIf t'Mts r.nnlll!r.t""Ii uiI,h tlul fnt'N:lfKl1PP- IIItlle lmd "'P1V nT}U'!T I"'.J"ID.M ""...n'P'u!!jl!1'I!n witll '''Po ~'u.";H'oI: ""-III!! ::14: omat';.r.;.-,r in ~t;n..lly
,hI! ll!nrll~r :Anti hy DlR"!'fnl'l"nh1t. IIVlV m'hHo J'1"nniN'!mI'!n'I'G mlllAT t'h" Yl'Inl'"f,?,t''' Curid.g y<)\U' 4ef."I\ in the lIlanner set forth in tbis ~til!e wUl
...estm-e ;YOUr mOl"tpp to the 8"~. pasitlolt u if you had never dl!l'atdt!ld.
F.Aln.Y~ 1tftC!I;.TRI'Il! ~fn;'I~ A'" 'v. nA."~ -It is esthnaWd. ,'41: t.he euliesl datllUmt SUCb:l. ShsrUrs Sale of the mortgap propeny
could be hcltl 'Would be BpproxlmatcJy 9 mOdths from the ~ of thilf;. NoIice. A .oadc:e of the actu.aI daw of the Sheriff'e: Sale. will be
!iCD.t to you before. the SDle.. Of ~tU'!ie, me atIlO'\.U'lt neeC!ad to curs tbe ddauh wilt U1eteaSf; lhe 1cJ:l&e1' you wait. 'You may:ftnd out at any
time ~ly wbat the t'Bq\1\~ f4:ftncnt OY' act10R wUl be by eonlll~liftg tDC: lendiCT.
now Tn rnNTA.~ TNF. CF.N1Um.-
Namli! of Lfdder:
Addrou:
W.shbtafgn Mulo.] HOrtIe Lo.ItW~, Ine..
9451 CQrbin A'VeI'Iur;
Nortb.I'Wae, CA 91324
1-_1745
1.s18-~
Colll!!f;tion DepartmllDt
PhOJle Number;
Fa N\\m'-":
Contact PerMlII:
F.lfIi'IU'~1'~ nli' ~lI1i'DTIiT'~ 1lO:A.1 JO'... You should realiz;c that a. Sheriff's Sale will end your ownership of 'the JhOrtgage4 propenyand. your
rigbl1C! occupy i.t. If you ccnUnue: to live IIi the property after tlw Sber~ .'Sale. .::lls:wsui~ to remove you and your furmmlnp:l:od. other
hclongingi c;oull;l. be stanect by the Ic11d.a at. any time..
.ARgfJMPTrON OF Mn'DTC:AGR. Yotl_ may or ANy not 5E.IJ or ~ your home to & bu.yc:r 01' tr.anmr~ who lIIlll assume \he
mo'tgap Wl-b\,. pl'ovJAtd 1ha1. aU !.be oulSlaWlln& paydll:nt5, chat'gCS, .and attorney's ices and ~O!its are paid prior to DT 8t the ~le, and that
tl:ll~ other requirements of the mortaage an. sati.sfied,
VOU 'MAY Al ~ HAVE THE RIGHT:
TO SELL THE PROPERty TO OBTAIN MONEY ,0 PAY OFF THl! MORTOAGE DEBT OR TO BORROW MONEY FROM
ANOnmR LENDINO lNSTITU110N TO PA.Y OFF TInS DEBT.
. TO HAVE TI\E.PEFAULT CURED BY ANY THIRD PAATY A<;TING ON YOUR. BEHALF.
. TO HAve TlIE MORTGAGE RBSTOIlEI> TO THE SAM]!. POSITION AS IF NO Dl!PAUL T HAD OCCURIlBD, IF YOU CURl!
'I'Ill! DEFAULT_ (HOWEVER. YOU DO NOT HAVE THI~ RIGHT TO CURE YOUR. DEFAULT MORE THAN 'l'HIU!E TIMBS
IN }\NY CALENDAR YBAR.)
. TQ ASSERT TtiE :NONEXJSTENCE OP A OEFAULT IN ANY FORECLOSURE PRocr.EDlNG OR ANY OTIfflR LAWsurr
INSTITUTer> UNDER THE MORTGAO",POCUMEN'fS,
. TO ASSERT ANy OTHER DEFENSE YOU BELIEVE YoU MAY HAVE To SUctIA<;TION BY THE U;NOl!R.
. TO SEEK PROTECTION UNDER 'I'IlE Fl!OERAL lIANnl]PTCY LAW,
CONSUMER CREDIT COUNSELIN<; A.GENClQ; Bl!R.VING YOUR COllNT'l Altl! A1TACHED
We may reJ)art inl'onu.tioD .about,our acanmt to ettdit bureaus. Late paymeltlUl, mil"", payments 01" .rtbt:r dc:faultsl;tn lQur
a<<oa;nt ma)' bE "net;ted in )'OUT credit repDM.
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VERIFICATION
I,
CASSANORAIN.OUYE
as the representative of
the Plaintiff corporation within named do hereby verify that I am
authorized to and do make this verification on behalf of the
Plaintiff corporation and the facts set forth in the foregoing
Complaint are true and correct to the best of my knowledge,
information and belief. I understand that false statements therein
are made subject to the penalties of 18 Pa. C.S. 4904 relating to
unsworn falsification to authorities.
-- ,
Date: ~hAo.ry ;J ~, }1:io1~
DEUTS BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR LONG
BEACH MORTGAGE LOAN TRUST
2004-5
#0665594768 - ROBERT L. SHOFF
SHERIFF'S RETURN - REGULAR
CASE NO: 2005-01116 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
SHOFF ROBERT L
RONALD HOOVER
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according t law,
says, the within COMPLAINT - MORT FORE
was served upon
SHOFF ROBERT L
the
DEFENDANT
, at 1956:00 HOURS, on the 18th day of March
, 2005
at 26 MAPLE AVENUE
WALNUT BOTTOM, PA 17266
by handing to
JANISE JENKINS, ROOMMATE,
ADULT IN CHARGE
a true and attested copy of COMPLAINT - MORT FORE
together w'th
and at the same time directing Her attention to the contents ther of.
Sheriff's Costs:
Docketing
Service
Affidavi t
Surcharge
18.00
10.36
.00
10.00
.00
38.36
So Answers:
-:;:P'X:J?",:.c..:':
R. Thomas Kline
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03/21/2005
GOLDBECK MCCAFFERTY MCKEEVER
me this
Jl~
day of
Sworn and Subscribed to before By:
:~~l
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney LD. #16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR LONG BEACH MORTGAGE
LOAN TRUST 2004-5
9451 Corbin Avenue
Northridge, CA 91324
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
vs.
CIVIL ACTION LAW
ROBERT L. SHOFF
(Mnrtgagnr(s) and Recnrd nwner(s))
26 Maple Avenue
Walnut Bottom, PA 17266
ACTION OF MORTGAGE FORECLOSURE
Defendant( s)
No. 05-1116
ORDER FOR JUDGMENT
Please enter Judgment in favor of DEUTSCHE BANK NA TrONAL TRUST COMPANY, AS
TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2004-5, and against ROBERT 1. SHOFF for
failure to tile an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States
of America) from the date of service of the Complaint, in the sum of$72,298.95.
I hereby certify that the above names are correct and that the pre ise residence address of the judgment
creditor is DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH
MORTGAGE LOAN TRUST 2004-59451 Corbin Avenue Northridge, CA 91324 and that the name(s) and last
known addressees) of the Defendant(s) is/are ROBERT 1. SHOFF, 26 Maple Avenue Walnut Bottom, PA 17266;
GOLDBE
BY: Joseph A. G
Attorney for Pial
,ERTY & McKEEVER
k, Jr.
ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly assess the damages in this case to be as follows:
Principal Balance
$66,346.10
Interest from 08/0112004 through
04/30/2005
$3,497.13
REASONABLE Attorney's Fee
$1,250.00
Late Charges
$213.12
Costs of Suit and Title Search
$900.00
FEES
$92.60
($0.00)
$72,298.95
Y & McKEEVER
Jr.
AND NOW, this ]~ay of fll2j
, 2005 damages are assessed as above.
(!~-U~~
Pro Prothy
VERIFICATION OF NON-MILITARY SERVICE
The undersigned, as the representative for the Plaintiff
corporation within named do hereby verify that I am authorized
to make this verification on behalf of the Plaintiff corporation
and that the facts set forth in the foregoing verification of
Non-Military Service are true and correct to the best of my
knowledge, information and belief. I understand that false
statements therein are made subject to penalties of 18 Pa. C.S.
4904 relating to unsworn falsification to authorities.
1. That the above named Defendant, ROBERT L.
about
unknown
years
of
age,
that
Defendant's
SHOFF, lS
last known
residence is 26 Maple Avenue, Walnut Bottom, PA
17266, and is
engaged in the unknown business located at unknown address.
2. That Defendant is 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 Action of
Congress of 1940 and its Amendments.
Date:
In the Court of Common Pleas of Cumberland County
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST
2004-5
9451 Corbin Avenue
Northridge, CA 91324
Plaintiff
vs.
ROBERT L. SHOFF
(Mortgagor(s) and Record Owner(s))
26 Maple Avenue
Walnut Bottom, P A 17266
No. 05-1116
Defendant( s)
PRAECIPE FOR JUDGMENT
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE
OF COLLECTING THE DEBT.
Enter the Judgmenl in favor of Plaintiff and against ROBERT L. SHOFF by default for want of an Answer.
Assess damages as follows:
$72,298.95
Debt
Interest - 08/01/2004 to 04/30/2005
Total
(Assessment of Damages attached)
I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO
BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT.
I certify that written notice of the inlention to file this praecipe was mailed or delivered to the party against whom judgment
is to be entered and to his attorney of record, if any, after the default occurred at lea ten days prior to the date of the
tiling of this praecipe. A copy of the notice is attached. R.C.P. 237.1
Joseph . k, Jr,
Attorney
LD. #1613
AND NOW fYl ::J Ti ....:< , ;;JC)& r ' Judgment is entered in favor of
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST
2004-5 and against ROBERT L. SHOFF by default for want of an Answer and damages assessed in the sum f $72,298.95
as per the above certification.
e.~+.n' ~
Prothonotary
---~----------
----------- ---------------
WM-0495
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED
, FRO\\l YOU WILL BE USED fOR THE PURPOSE O!!, COLLECTiNG THe DEBT.
DATE OF THIS NOTICE: AprilS, 2005
TO:
ROBERT L. SHOFF
26 Maple Avenue
Walnut Bottom, PA 17266
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST
2004-5
9451 Corbin Avenue
Northridge,CA 91324 '
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Plaintiff
Action of
Mortgage Foreclosure
vs.
ROBERT 1. SHOFF
(Mortgagor(s) and Record Owner(s))
26 Maple Avenue
Walnut Bottom, PAl 7266
Term
No.05-1116
Defendant(s)
TO: ROBERT L. SHOFF
26 Maple Avenue
Walnut Bottom, P A 17266
IMPORT A NT NOTH'R
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS
TO THE CLAIMS SET FORTH AGAINST YOu. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF
TIllS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE
YOUR PROPERTY OR OTHER IMPORTANT RIGlITS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT
ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO
HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES
THA T MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LEGAL SERVICES lNC
g Irvine Row
Carlisle, PA 17013
7t7-243-9400
CUMBERLAND COUN1Y BAR ASSOCIATION
2 Libelty Avenue
Carlisle, P A 17013
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney fot' Plaintiff
Suite 5000 - Mellon Independence Center.
701 Market Street
Philadelphia. PA 19106 215-627-1322
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Rule of Civil Procedure No. 236 - Revised
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST
2004-5
9451 Corbin Avenue
Northridge, CA 91324
Plaintiff
No, 05-1116
vs.
ROBERT L. SHOFF
(Mortgagors and Record Owner(s))
26 Maple Avenue
Walnut Bottom, P A 17266
Defendant(s)
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE
PURPOSE OF COLLECTING THE DEBT.
NOTICE
Notice is given that a judgment in the above-captioned matter has been entered against you.
Curt Long
Prothonotary ~
~. ~~~P. ~
Deputy
If you have any questions concerning the above, please contact
Joseph A. Goldbeck, Jr.
Goldbeck McCafferty & McKeever
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
-
PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, P A 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR LONG BEACH MORTGAGE
LOAN TRUST 2004-5
9451 Corbin Avenue
Northridge, CA 91324
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
vs.
CIVIL ACTION - LAW
ROBERT L. SHOFF
Mortgagnr(s) and Record Owner(s)
26 Maple Avenue
Walnut Bottom, P A 17266
ACTION OF MORTGAGE FORECLOSURE
No. 05-1116
Defendant( s)
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
$72,298.95
Interest from
08/01/2004 to
04/3012005 at
7.0500%
(Costs to be added)
TY & McKEEVER
GOLDBEC
BY: Joseph A.
Attorney for PI
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AlL those two cer1ain pieces or parcels ofl8l)d situate in South Newton Township; County of
Cumberland and State ofPet\MYlvallia, bounded and described as follows, to wit:
TRACT NO.1; BEGlNNlNO at an iron pin in the =rtllr of the public road leading fr01ll Jacksonville to
the Stouabatown public road also known as Maple Avmme; thence by the center of the same, North 36
degrees Wl:8t, a disbnca of29.8 feet to 111 iron pin In the center oftha public tOad; tb.tnce along lands,
now or f'onnerty of John Robinson, South 57 de~a 40 minutes Wesl, a distance 0061.2 feet to a stake;
thcIlce by Iands now or fom1ei-ly of Clarence Gardner, South 37 degrees 40 minutes East, a distance of
134.3 feet to a stake; thence by lan&now od'orlllerly of Mrs. 10bn Myers, North 41 Yo degrees East, a
distanoe of 16.9 feet to a post; thcIlce along lands now or formerly of Lena B. Tbrush Estate and being
Tract No.2 hereinafter dllScribed, North 41 degree 30 minutes West, a distance of 83.4 feet ta a stake,
thence oontinuing by lands now or formerly of Lena B. Thrush &tate and being TfIlCt No.2 hereinat\cr
deswibed, North 51 degrees 30 min\lles East, a distance of147.6 feetta thepla.ce ofBBGINNlNO.
CONTAIN1NG 0.55 aeres.
TRACT NO.2: BOUNDED on the East by the public road leading from Jacksonville to the Staughstown
public road Blso known as Maple Avenue, on the North and West by lands noW' or fonnerly of tile Estate
of Lena B. TIuush, being Tract No. 1 hClCinafter described; and on the South by land now or fonncrly of
John Killinger and Mae Killinger, bia wife, containing one-fourth aore, mote Ot less.
The above two tracts of land c:ontaining a total frontage of 96 feet more or less, and being improved with
a dwelling hO'US" known as 16 Maple AVlllIue, Walnut Bgttom, South Newton Township, Cumberlancl.
Couoty, Pennsyl-na.
_~~".~~.~c~-
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 05-1116 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2004-5, Plaintiff (s)
From ROBERT L. SHOFF
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the gamishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $72,298.95
Interest FROM 8/1/04 TO 4/30/05 AT 7.0500%
L.L. $.50
Arty's Comm %
Atty Paid $120.36
Plaintiffpaid
Date: MAY 3, 2005
Due Prothy $1.00
Other Costs
CURTIS R. LONG
(Seal)
Prothonotary 2. 7r~
~,0D/>O_ .
Deputy
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK, JR., ESQUIRE
Address: GOLDBECK MCCAFFERTY & MCKEEVER
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ID No, 16132
Golqbeck McCafferty & McKeever
. BY: Joseph A. Goldbeck, Jr.
Attorney LD. #16132
Suite 5000 - Mellon Independence Center
70 I Market Street
Philadelphia, P A 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR LONG BEACH
MORTGAGE LOAN TRUST 2004-5
9451 Corbin Avenue
Northridge, CA 91324
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
vs.
CIVIL ACTION - LAW
ROBERT 1. SHOFF
(Mortgagor(s) and Record Owner(s))
26 Maple Avenue
Walnut Bottom, PAl 7266
ACTION OF MORTGAGE FORECLOSURE
Defendant( s)
No. 05-1116
AFFIDAVIT PURSUANT TO RULE 3129
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN
TRUST 2004-5, Plaintiff in the above action, by its attomey, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the
praecipe for the writ of execution was filed the following information conceming the real property located at:
26 Maple Avenue
Walnut Bottom, P A 17266
I.Name and address ofOwner(s) or Reputed Owner(s):
ROBERT L. SHOFF
26 Maple Avenue
Walnut Bottom, P A 17266
2. Name and address of Defendant(s) in the judgment:
ROBERT L. SHOFF
26 Maple Avenue
Walnut Bottom, P A 17266
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
P A DEPARTMENT OF PUBLIC WELF ARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O, Box 2675
Harrisburg, PA 17105-2675
4. Name and address of the last recorded holder of every mortgage of record:
~
LONG BEACH MORTGAGE COMPANY
1400 S. DOUGLASS ROAD
STE 100
ANAHEIM, CA 92806
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7, Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
26 Maple Avenue
Wa'nut Bottom, P A 17266
(attach separate sheet if more space is needed)
I verifY that the statements made in this affidavit are true and correct to the best of my personal knowledge or
information and belief. 1 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
GOLDBECK Mc
BY: Joseph A. Gold ec
Attorney for Plaintif
DATED: April 30. 2005
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.
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
AttorneyI.D.#16132
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, P A 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR LONG BEACH
MORTGAGE LOAN TRUST 2004-5
9451 Corbin Avenue
Northridge, CA 91324
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
vs.
ROBERT 1. SHOFF
Mortgagor(s) and Record Owner(s)
ACTION OF MORTGAGE
FORECLOSURE
26 Maple Avenue
Walnut Bottom, P A 17266
Term
No. 05-1116
Defendant(s
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: SHOFF, ROBERT L
ROBERT L. SHOFF
26 Maple Avenue
Wa1nutBottom,PA 17266
Your house at 26 Maple Avenue, Walnut Bottom, P A 17266 is scheduled to be sold at SheriIl's
Sale on Wednesday, September 07,2005, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse
to enforce the court judgment of $ 72,298.95 obtained by DEUTSCHE BANK NATIONAL TR US T
COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2004-5 against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
I, The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2004-S, the back payments, late
charges, costs and reasonable attorney's fees due. To find out how much you must pay call:
215-627-1322
05-1116
.
.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
Yau may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7, You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale,
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, P A 17013
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attome for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR LONG BEACH MORTGAGE
LOAN TRUST 2004-5
9451 Corbin Avenue
Northridge, CA 91324
WM-0495
CF: 03/03/2005
SD: 09/07/2005
$72,298.95
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
Plaintiff
vs.
ACTION OF MORTGAGE FORECLOSURE
ROBERT L. SHOFF
Mortgagor(s) and
Record Owner(s)
Term
No. 05-\116
26 Maple Avenue
Walnut Bottom, PA 17266
Defendant( s)
CERTIFICATE OF SERVICE
PURSUANT TO Pa.R.C.P. 3129.2 (c) (2)
Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the
Defendants ofthe Notice of Sheriff Sale was made by:
*
( )
Personal Service by the Sheriff's Office/competent adult (copy of return attached).
Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached).
Certified mail by Sheriffs Office.
Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record
(proof of mailing attached).
Acknowledgment of Sheriff's Sale by Attorney for Defendant(s) (proof of acknowledgment
attached).
( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record.
IF SERVICE WAS ACCOMPLISHED BY COURT ORDER.
( ) Premises was posted by Sheriff's Office/competent adult (copy of return attached).
( ) Certified Mail & ordinary mail by Sheriffs Office (copy .of return attached).
( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified
Mail attached).
( )
Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been
made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached).
The undersigned understands that the statements herein are subject to the penalties provided by 18 P.
Section 4904.
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000 - Mellon Independence Center
70 I Market Street
Philadelphia, P A 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR LONG BEACH
MORTGAGE LOAN TRUST 2004-5
9451 Corbin Avenue
Northridge, CA 91324
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CNIL ACTION - LAW
vs.
ACTION OF MORTGAGE FORECLOSURE
ROBERT 1. SHOFF
Mortgagor(s) and Record Owner(s)
Term
No. 05-1116
26 Maple Avenue
Walnut Bottom, P A 17266
Defendant( s)
AFFIDAVIT PURSUANT TO RULE 3129
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN
TRUST 2004-5, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the
praecipe for the writ of execution was filed the following information concerning the real property located at:
26 Maple Avenue
Walnut Bottom, PA 17266
l.Name and address ofOwner(s) or Reputed Owner(s):
ROBERT 1. SHOFF
26 Maple Avenue
Walnut Bottom, PA 17266
2. Name and address ofDefendant(s) in the judgment:
ROBERT 1. SHOFF
26 Maple Avenue
Walnut Bottom, P A 17266
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
P A DEPARTMENT OF PUBLIC WELFARE - Bun,"u of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
4. Name and address of the last recorded holder of every mortgage of record:
LONG BEACH MORTGAGE COMPANY
1400 S. DOUGLASS ROAD
STE 100
ANAHEIM, CA 92806
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
26 Maple Avenue
Walnut Bottom, P A 17266
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.s. Section 4904
relating to unsworn falsification to authorities.
DATED: August 5, 2005
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See Rever cloT Instructions
Certified Mail Provides:
. A mailing receipt
. A unique identifier for your mailpiece
. A record of delivery kept by the Postal Service for two years
Im/?Ortant Reminders:
. Certified Mail may ONLY be combined with First-Class MajlQ.t. or Priority MaUl!!_
. Certified Mail is notavailable for any class of international malt.
. NO INSURANCE COVERAGE IS PROVIDED with Certified Mail. For
valuables, please consider Insured or Registered Mail.
. For an additional fee. a Return Receipt may be requested tOJ'ToviQ9 proof of
delivery. To obtain Return Receipt service, please complete an attacn a Return
Receipt (PS Form 3811) to the article and add applicable postage te cover the
fee. Endorse mail piece "Return Receipt Requested". To receive a fee wafvet' for
a duplicafe retum receipt, a USP~ postmark on your Certified Man receipt is
required. .
. For an additional fee, delivery may be restricted to the addressee or
addressee's authorized a~ent. Advise tha clark or mark the maJlplece with the
endorsement ~RestrictedDelivery".
. If a postmark on the Certified Mail receipt is desired, please present the arti-
cle at the post office for postmarking. It a postmark on the Certified Mail
receipt is not needed, detach and affix Jabel with postage and mail.
IMPORTANT: Sa.ethis receip'and present it when making an inquiry.
Internet access to delivery informaUon Is not available on mail
addressed to APOs and FPOs.
(as.J8118/;j) Goa~ aunr 'OOaE:'WJO.:l Sd
COMPLETE YIS SECTiON ON DEUVERY
SENDER: COMPLeTe THIS SECT/ON
. Complete ~ems 1, 2. and 3. Also complete
~em 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mailplece,
or on the front W space permits.
1. ArtIcle Addressed to:
WM-0495 9/7
SHOFF, ROBERT L.
26 Maple Avenue
Walnut Bottom, PA 17266
2. Articte Number
{7IBtIsfertrom_18befJ
PS Form 3811. February 2004
A. Signature
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Deutsche Bank National Trust Company
As Trustee for Long Beach Mortgage
Loan Trust 2004-5
VS
Robert L. Shoff
The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2005-1116 Civil Term
Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that
on May 11,2005 at 7:11 o'clock PM, he served a true copy ofthe within Real Estate
Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the
within named defendant, to wit: Robert L. Shoff, by making known unto Robert L. Shoff,
personally, at 26 Maple Ave., Walnut Bottom, Cumberland County, Pennsylvania, its
contents and at the same time handing to him personally the said true and correct copy of
the same.
Gerald Worthington, Deputy Sheriff, who being duly sworn according to law,
states that on July 05, 2005 at 7:05 o'clock P.M., he posted a true copy of the within Real
Estate Writ, Notice, Poster and Description, in the above entitled action, upon the
property of Robert L. Shoff, located at 26 Maple Ave., Walnut Bottom, Pennsylvania,
according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he
served the above Real Estate Writ, Notice, Poster and Description in the following
manner: The Sheriff mailed a notice of the pendency of the action to the within named
defendant, to wit: Robert L. Shoff, by regular mail to his last known address of26 Maple
Ave., Walnut Bottom, PA 17266. This letter was mailed under the date of July 01, 2005
and never returned to the Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED per instructions from Attorney Joseph Goldbeck.
Sheriffs Costs:
Docketing
Poundage
Advertising
Posting Handbills
Levy
Mileage
Law Library
Prothonotary
Certified Mail
Postage
Surcharge
30.00
18.76
15.00
15.00
15.00
22.40
.50
1.00
4.26
.74
20.00
Postpone Sale
Share of Bills
Law Journal
Patriot News
20.00
18.20
419.00
356.78
$ 956.64
Sworn and subscribed to before me
So AnsweIJ ~
r~~r 'C4!
R. Thomas Kline, Sheriff
BY JD~S~1
Real Estate ergeant
'of\;
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i Goldbeck McCafferty 8: McKeever
BY: Joseph A, Goldbeck,.Ir.
Attorney J.D. #16132
Suite 5000 - Mellon Independence Center
70 I Market Street
Philadelphia, P A 19106
215-627-1322
Attorney lix Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR LONG BEACH
MORTGAGE LOAN TRUST 2004-5
9451 Corbin Avenue
Northridge, CA 91324
IN TilE COURT OF CO~1'\10N PI.EAS
ofCulI1berland ('ounty
Plaintiff
V.s.
CIVIL ACTION - I,A W
ROBERT 1. SHOFF
(Mortgagor(s) and Record Owner(s))
26 Maple A venue
Walnut Bottom, I'll. 17266
ACTION OF MORTGAGE FORECLOSURE
Dcfcmlant(s)
No.05-1116
AFFIDAVIT PURSUANT TO RULE 3129
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN
TRUST 2004-5, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr.,Esquire, sets forth as ofthc date the
praecipe for the writ of execution was filed the follmving infonnation concerning the real propeJiy located <II:
26 Mapte Avenue
\Valnut Bottom, PA 17266
l.Name and address ofOwner(s) or Reputed Owner(s):
ROBERT L. SHOFF
26 Maple Avenue
Walnut Bottom, P A 17266
2. Name and address of Defendant(s) in the judgment:
ROBERT L SHOFF
26 Maple Avenue
Walnut Bottom, PA 17266
3. Name and last knO\vn address of every judgmcn\ creditor whose judgment is a record lien on the property In he sl\ld:
DOMESTIC RELATIONS UF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
PA DEPARTMENT OF PUBLIC WEFFARE - BlIlcallllfChitd SUppOrl Ent"rcuncnl
Health and \Velfare Bldg. - Room 43:2
1'.0, Box 2675
Harrisburg, PA 17105-2675
4. Name and addrcs~ of the la~t recorded holder of every mort~,lgc or record:
, ,
:
LONG BEACH MORTGAC;[ CO'vIPANY
14()0 S DOUGLASS ROAD
STI: 100
ANAl-lI:lIvI. CA 92806
5. Name and address of CVCl)' other person \vl1o has any record interest in or record lien on the property' and whose interest
may be afTected by the sale:
6. Name and address of every other person of\vho111 the plaintiff has knO\vledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintitThas Jmmvledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
26 Tv1aple Avenue
Walnut Bottom, P A 17266
(attach separate sheet if more space is needed)
J verify that the statements made in this affidavit are true and correct to the best of my IJCfsPllal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties or ] X Pa. C.S. Section 4904
relating to unswom falsification to authorities.
GOLDBECK Mc '
BY: Joseph A, Gold
Attorney for Plaintif
, & McKEEVER
" Esq.
DATED: April 30, 2005
..
0)-\ \ \6
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph /\.. (jnldbcck. Jr.
Altoll1cy I.D.f/] 613~
Suite 5000- lV'h::lloll lndepcndcllce ('l'llk'r
70 I Market Street
PllIladelphla. P A 19106
215-627-13:':'
Attollley for Plaintiif
DEUTSCHE BANK NATIONAL TRUST
COMPANY. AS TRUSTEE FOR LONG BEJ\ClI
MORTGAGE LOAN TRUST 2004-S
9451 Corbin Avenue
Northridge, CA 91324
IN TIlE COURT OF COMMON PLEAS
of Cumberland County
PlaintilT
CIVIL ACTION - LAW
VS,
ROBERT L SIlOFF
Mortgagor(s) and Rccord Owner(s)
ACTION OF MORTGAGE
FORECLOSURE
26 Maple A venue
Walnut Bottom, P A 17266
Term
No.05-l116
Defendant(s
THIS LAW FIRM IS A BEIH COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY IN FORlIIATION OBTAINED f'ROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: SHOFf. ROBERT L
ROBERT L. SHOFF
26 Maple Avenue
\Valnut Bottom, P 1\ 17266
Your house at 26 Maple Avenue, Walnut Bottom, P A 17266 is scheduled to be sold at Sheriff's
Sale on Wednesday, September 07, 2005, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse
to enforce the court judgment 0[$72,298,95 obtained by DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE "OR LONG BFACH MORTGAGE LOAN TRUST 2004-S against you.
NOTICE OF OWNER'S RIGHTS
YOU MA V BE ABLE TO PREVENT THIS SlmRIFF'S SALE
To pn..'\"ent this Sheriffs Sa!c Y"Ol! ll1uq take iJ11mediate action:
\, The sale Will be cancelled if you pay 10 DEUTSCII!: BANK NA nONAL TRUST COMPANY,
AS TRUSTEE H)R LONG IlEACII MORI (jAG" LOAN TRUST 2004-5. the back payments. late
charges. costs and reasonable ,-lllornc)""'; fcl's due. To find Ollt how much )'OLl must pay call:
2]5-627-1322
, r
liS-III,
, You IlWY be able to stop the S<lle by filing (l petition asking the ('ourt to strike or open judgnwnL j t
the judgment \\-;IS improperly entered. You may 3Is() ask the Court to postpone the ~:ale for good G\t\~e,
J. You may also be able to stop the sale through other legal proceedings.
'{ou may need an aHomey to assert your rights. The sonner Yl\LJ contact one, the more chance YOll
will han; of slOpping the sale. (See notice helow on how to obtain an nttomey).
YOU MAY STILL BE ABLE TO SA VE YOUR PROPERTY ANI) YOU HAVE OTHER RIGHTS
EVEN IF nIE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. Y Oll may find
out the price bid price by calling the Sherifl of 717-240-6390,
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3, The sale will go through ouly if the buyer pays the Sheriff the full amount due in the sale, To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the dlllount due from the Buyer is not paid to the Sheriff you will remain the OWller oCthe
properl)' as if the ",ale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. Y Oll may be entitled to a share of the money which \vas paid for your house. A schedule of
distribution of the money bid for your house will be 1iled by the Sberiff within thirty (30) days from the
dale of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons v,"hy the proposed distribution is
\\nmg) are tiled with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP,
IUiAL SERVICES INC
8 Irvine Row
Carlisle, P A \7013
CUMBERLAND COUNTY BAR ASSOCIA nON
2 Liberty A v.enue
Carlisle, P A 17013
ALL those two certain pieces orparcels ofJlU)d situate in South Newton Township; County IIf
Cumberland and State of Pennsylvania, bounded and described as fllllows, to wit:
TRACT NO.1; BEOlNNlNG at an iron pin in the center of the public road leading from Jacksonville to
the Stoughstown publio toad also known as Maple Avenue; thence by the oenter of the same, North 36
dcgrell5 West, a distance of29.8 feet to an iron pin in the center of the public road; thence along lands,
now or {onnerly of John Robinson, South 57 degl"eCS 40 minutes Wes~ a distance of 161.2 feet to a stsk.e;
thence by lands now or fOl1llerly of Clarence Gardner, Soutb 37 degrees 40 minute5 East, a di5tllnoe of
134.3 feet to a stake: thence by lands now or formerly of Mrs. 10hn Myers, North 41 y,degrees Ea5t, a
distance of 16.9 feet to a post: thence along lends now or formerly of Lena B. Thlusb Eslale and being
Tract No.2 hereinaftcl described, North 41 degree 30 minutes West, a distance of 83.4 feet to a stake,
thence continuing by lands now or formerly of Lena B. Thrush Estate and being Tract No.2 hereinlUler
desaribed, North 51 degrees 30 minutes Bast, a distance of 147.6 feet to the place ofBEGl1\'NlNQ,
CONTAlNlNG0.55 acres.
TRACTNO. 2: BOUNDED on the East by the public road leading from Jacksonville to the Sloughstown
public road also Imown as Maple Avenue, 'm tile North and West by lands now or formerly of the Estate
ofLcna B. Thrush, being Treet No.1 hCleinafter described; and on the South by land now or formerly of
John Killinger and Mae Killing..r, bh wife, contalning one-fourth acre, more or less.
The above two tracls of lll!ld containing a total frontage of 96 feet more or less, and being improved with
a dwelling hOllSe, Imown as 26 Maple Avenue, Walnut Bottom, South Newton Township, Cumberland
COllOty,l'ennsylvania.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYL VANIA)
COUNTY OF CUMBERLAND)
NO 05-1116 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2004-5, Plaintiff (s)
From ROBERT 1. SHOFF
(I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for tbe account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $72,298.95
Interest FROM 811/04 TO 4/30105 AT 7.0500%
L.L. $.50
Atty's Comm %
Arty Paid $120.36
Plaintiff Paid
Date: MAY 3, 2005
Due Prothy $1.00
Other Costs
(Seal)
CURTIS R. LONG
Prothono~ m
~0fU1J1.2. r LO?/?./c-r--
Deputy
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK, JR., ESQUIRE
Address: GOLDBECK MCCAFFERTY & MCKEEVER
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court lD No. 16132
Real Estate Sale #29
On May 09, 2005 the Sheriff levied upon the
defendant's interest in the real property situated in
South Newton Township, Cumberland County, PA
Known and numbered as 26 Maple A venue,
Walnut Bottom, more fully described on Exhibit "A"
Date: May 09, 2005
By;,J()J~J S~th
Real Estate Deputy
GS>
~
c:-..::::::;
G"i)
~
filed with this writ and by this reference incorporated herein.
\ Z 't. d \'\- ,,~\'\ ~fifiI
. ."< ..~\~<\'!,
"Jd 'H';\\ \00;,,\'-\;' JO'3~\;l~Q
J:l\<l1\-\S ~, --
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Joseph A. Dennison, being duly sworn according to law, deposes and says:
That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the
laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market
Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-
News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market
Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established
March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published
in their regular daily and/or Sunday/ Metro editions which appeared on the 19th and 26th day(s) of July and the 2nd
day(s) of August 2005. That neither he nor said Company is interested in the subject matter of said printed notice or
advertising, and that all of the allegations of this statement as to the time, place and character of publication are true;
and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed
and adopted severally by the stockholders and board of directors of the said Cornpany and subsequently duly
recorded in the office for the Recording of Deeds in and for said County of Dauphin in Misc eous Book "MOO,
Volume 14, Page 317.
COpy
S ALE #29
Sworn to and subser
NOTARY PUBLIC
My commission expires June 6, 2006
PUBLICATION
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
Statement of Advertising Costs
I
To THE PATRIOT-NEWS CO.
For publishing the notice or publication attached
hereto on the above stated dates
356.78
REAL ESTATE SALE No. 29
Writ No. 2005-1116
Civil Term
Deutache Bank Nellonel Trust
Company, .s Trustee for Long
Beech Mortgege Loan Trust 2004-
5
Vs
Robert L. Sholl
Ally: Joseph 90ldbeck
DESCRIPTION
AU those two certaii1 pikes or parcels of land
situate in South Newton Township; County of
Cumberland and State of Pennsylvania, bounded
and described as follows. to wit:
lRACTNO.l: BEGINNING at an iron pin in the
center of the public road 1eading from Jacksooville
to the Stoughstown public road also known as
Maple Avenue; thence by the center of the same,
North 36 degrees West, a distance of 29.8 feet to
aniroo pin in1be center of the public road; thence
along lands. now or fonnerl.y of Jobn Robinson,
Sooth 57 degrees 40 lIiinutes West, a distance of
1611 feet to a stake; thence by lands now or
fonneely of Clarence Gardner, South 37 degrees
40 minutes East, a distance of 1343 feet to a
stake; thence by lands now or formerly of Mrs.
JobnMyers,North 41.5 degrees East,a distance of
169 feet to a post; thence along lands now or
formerlyofI.ena B. ThroshE_and beingTract
No.2 hereinafter _bod, NOI1h 41 de_ 30
minutes West, a distance of 83A feet to a stake,
thence continuing by lands now or formerly of
Le" B. Throsh Estate and being Tract No, 2
hereinafter described, North 51 degrees 30
minutes East,a distance of 147.6 feet to the place
of BEGINNING.
CONTAINING 0.55 am;.
mACrllO.%; -....lIatbylbe
_1'01II__..... ......
-.....-......."'-.....
famodyoftbe_ofi-B.1kW,~
'\llIctNo. 1 hereinafterdesaibed; and....
South by land now oc formerly of Jobn KiDinger
and Mae Killinger,his wife,oontaiDing ooe-iourth
acre,more or Jess.
mE above two tracts of land containing a total
frootage of 96 feet more or less, and being
improved with a dwelling house. known as 26
Maple Avenue, Walnut Bottom, South Ne'?'tOO
Township, Cumba100lI amy; Pamsytvarria,
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. 1.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Curnberland Law
Journal on the following dates,
V1Z:
July 15, 22, 29, 2005
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
( Lis
SW~ AND SUBSCRffiED before me this
29 day of Julv. 2005
N SEAll
LOIS E. SNYDER, Notary Public
Carhsle 8oro, Cumberland County
My Commission Expires March 5. 2009
REAL ESTATE SALE NO. 29
Writ No. 2005-1116 Civil
Deutsche Bank National
Trust Company, as Trustee for
Long Beach Mortgage Loan
Trust 2004-5
vs.
Robert L. Shoff
Atty.: Joseph Goldbeck
ALL those two certain pieces or
parcels ofland situate in South New-
ton Township; County of Cumber-
land and State of Pennsylvania,
bounded and described as follows,
to wit:
TRACT NO.1: BEGINNING at an
iron pin in the center of the public
road leading from Jacksonville to
the Stoughstown public road also
known as Maple Avenue; thence by
the center of the same, North 36
degrees West, a distance of 29.8
feet to an iron pin in the center of
the public road: thence along lands.
now or formerly of John Robinson,
South 57 degrees 40 minutes West,
a distance of 161.2 feet to a stake;
thence by lands now or formerly of
Clarence Gardner, South 37 degrees
40 minutes East, a distance of
134.3 feet to a stake; thence by
lands now or formerly of Mrs. John
Myers, North 41 1/2 degrees East,
a distance of 16.9 feet to a post;
thence along lands now or formerly
of Lena B. Thrush Estate and being
Tract No.2 hereinafter described,
North 41 degree 30 minutes West,
a distance of 83.4 feet to a stake,
thence continuing by lands now or
formerly of Lena B. Thrush Estate
and being Tract No. 2 hereinafter
described, North 51 degrees 30
minutes East, a distance of 147.6
feet to the place of BEGINNING.
CONTAINING 0.55 acres.
TRACT NO.2: BOUNDED on the
East by the public road leading from
Jacksonville to the Stoughstown
public road also known as Maple
Avenue, on the North and West by
lands now or formerly of the Estate
of Lana B. Thrush, being Tract No.
1 hereinafter described; and on the
South by land now or formerly of
John Killinger and Mae Killinger. his
wife, containIng one-fourth acre,
more or less.
The above two tracts of land con-
taining a total frontage of 96 feet
more or less, and being improved
with a dwelling house, known as 26
Maple Avenue, Walnut Bottom, South
Newton Township. Cumberland
County, Pennsylvania.
.
PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
Joseph A. Goldbeck, .lr.
Attorney ID,#16132
Suite 5000 - Mellon Independence Center
70\ Market Street
Philadelphia, P A 19106-\532
215-627-132:
Attomcy for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR LONG BEACH MORTGAGE
LOAN TRUST 2004-5
9451 Corbin Avenue
NOrlhridge. CA 91324
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
VS.
CIVIL ACTION - LAW
ROBERT L SHOFF
Mortgagor(s) and Record Owner(s)
26 Maple Avenue
Walnut Bottom. PA \7266
ACTION OF MORTGAGE FORECLOSURE
No, 05-11\6
Defendant(s)
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue \Vrit of Execution in the above matter:
Amount Due
$72,298.95
interest from
08/01/2004 to
04/30/2005 at
7.05000;;)
(Costs to be added)
Gt CAFEFRry & McKEEVER
B : J seph A. Goldbeck, .If.
ton cy for Plaintiff
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All those two certain pieces or parcels of land situate in South Newton Township, County of
Curnberland and State of Pennsylvania, bounded and described as follows, to wit:
Tract No.1: Beginning at an iron pin in the center of the public road leading from Jacksonville to the
Stoughstown public road also known as Maple Avenue; thence by the center ofthe same, north 36
degrees west, a distance of29.8 feet to an iron pin in the center of the public road; thence along lands,
now or formerly of John Robinson, south 57 degrees 40 minutes west, a distance of 161.2 feet to a stake;
thence by lands now or formerly of Clarence Gardner, south 37 degreed 40 minutes east, a distance of
134.3 feet to a stake; thence by lands now or formerly of Mrs. John Myers, north 41 Y2 degrees east, a
distance of 16.9 feet to a post; thence along lands now or formerly of Lena B. Thrush Estate and being
Tract No.2 hereinafter described, north 41 degrees 30 minutes west, a distance of 83.4 feet to a stake,
thence continuing by lands now or formerly of Lena B. Thrush Estate and being Tract No.2 hereinafter
described, north 51 degrees 30 minutes east, a distance of 147.6 feet to the place of beginning.
Containing .5 5 acres.
Tract No.2: Bounded on the east by the public road leading from Jacksonville to the Stoughstown
public road also know as Maple Avenue, on the north and west by lands now or formerly ofthe Estate of
Lena B. Thrush, being Tract NO.1 hereinafter described; and on the south by land now or formerly of
John Killinger and Mae Killinger, his wife, containing one-fourth acre, more or less.
The above two tracts of land containing a total frontage of 96 feet more or less, and being irnproved with
a dwelling house, known as 26 Maple Avenue, Walnut Bottom, South Newton Township, Cumberland
County, Pennsylvania.
TAX PARCEL # 41-31-2230-004
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 05-1116 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2004-5, Plaintiff (s)
From ROBERT 1. SHOFF
(I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $72,298.95
Interest FROM 8/1/04 TO 4/30/05 AT 7.0500%
L.L.
Atty's Comm
%
Due Prothy $1.00
Other Costs
Ally Paid $1089.50
Plaintiff Paid
Date: JANUARY 13, 2006
(Seal)
By:
Deputy
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK, JR., ESQUIRE
Address: SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106-1532
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Conrt ID No, 16132
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
INRE:
ROBERT LEE SHOFF
Debtor
CHAPTER 13
DEUTSCHE BANK NA TWNAL TRUST
COMP ANY, AS TRUSTEE FOR LONG BEACH
MORTGAGE LOAN TRUST 2004-5
Moving Party
NO.05-bk-05921-MDF
vs.
ROBERT LEE SHOFF
Debtor
11 U.S.c. Section 362
CHARLES J. DEHART, III
Trustee
ORDER
Upon consideration of the failure of Debtor and the Trustee to file and Answer or otherwise plead, it is
ORDERED AND DECREED that:
The Automatic Stay of all proceedings, as provided under 11 U.S.C. Sections 362 and 1301 of the
Bankruptcy Reform Act of 1978 (The Code) 11 U.S.c. 11 U.S.c. Sections 362 and 1301 (if applicable), are
modified to allow DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH
MORTGAGE LOAN TRUST 2004-5 and its successor in title to proceed with the execution process through,
among other remedies but not limited to Sheriff's Sale regarding the premises 26 Maple A venue Walnut Bottom,
P A 17266 and a possessory action if necessary.
By till' ('G1Dt,
.
~~~~
This electronic order is signed and filed on the same date.
Dated: December 20, 2005
U~BC PAM - LIVE - V2.7 - Docket Report
Page 1 of5
MotDism, PreACT, CREDS
u.s. Bankruptcy Court
Middle District of Pennsylvania (Harrisburg)
Bankruptcy Petition #: 1:0S-bk-OS921-MDF
Assigned to: Mary D France
Chapter 13
Voluntary
Asset
Date Filed: 09/0612005
Robert Lee Shoff
26 Maple Avenue
Walnut Bottom, PAl 7266
SSN: xxx-xx-9558
Debtor
represented by Robert L. O'Brien
O'Brien Baric and Scherer
19 West South Street
Carlisle, PA 17013
717 249-6873
Fax: 717249-5755
Email: robrien@obslaw.com
Charles J. DeHart, III (Trustee)
PO Box 410
Hummelstown, PA 17036
7]7566-6097
Trustee
United States Trustee
PO Box 969
Harrisburg, PA 17108
(717) 221-4515
Asst. U.S. Trustee
Filing Date # Docket Text
09/06/2005 1 Chapter 13 Voluntary Petition missing Schedules and Statements.
Filing fee due in the amount of $ 194.00 Filed by Robert Lee Shoff.
(DD) (Entered: 09/06/2005)
09/06/2005 Receipt of Voluntary Petition Filing Fee, Chapter 13 - $194.00
Receipt Number: 00620618. (By CReg by AG) (RE: related
document I) (Entered: 09/07/2005)
09/07/2005 2 Notice of missing documents (RE: related document(s)1 ). (DD)
(Entered: 09/07/2005)
09/07/2005 Tentative Date for Meeting of Creditors (Case missing matrix or
plan). THIS IS SUBJECT TO CHANGE. 10/27/2005 at 09:00 AM.
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(DD) (Entered: 09/07/2005)
] 0/03/2005 3 Motion to Dismiss Case for failure to file required documents. Notice
sent to all Creditors. Filed by Trustee. Objections due by 10/25/2005.
(dehart, III(jg), Charles) (Entered: 10/03/2005)
10/04/2005 Tentative Date for Meeting of Creditors (Case missing matrix or
plan). THIS IS SUBJECT TO CHANGE. 12/1/2005 at 09:00 AM.
(DG) (Entered: 10/04/2005)
10/05/2005 4 Matrix filed/Creditor List Uploaded Filed by Robert L O'Brien Esq
on behalf of Robert Lee Shoff (RE: related document(s)1 ). (DB)
(Entered: 10/06/2005)
10/05/2005 5 Schedules A-J , Statement of Disclosure of Compensation of Attorney
for Debtor, Statement of Pin an cia I Affairs, Summary of Schedules
Piled by Robert L. O'Brien of O'Brien Baric & Scherer on behalf of
Robert Lee Shoff(RE: related document(s)l). (DB) (Entered:
10/06/2(05)
10/05/2005 6 Chapter 13 Plan Piled by Robert L. O'Brien of O'Brien Baric &
Scherer on behalf of Robert Lee Shoff (RE: related document(s)l ).
(DB) (Entered: 10/06/2(05)
10/06/2005 Tentative Date for Meeting of Creditors. THIS IS SUBJECT TO
CHANGE. 12/8/2005 at 09:00 AM. (DB) (Entered: 10/06/2(05)
10/06/2005 7 BNC Certificate of Mailing. (RE: related document(s)3). Service
Date 10/06/2005. (Admin.) (Entered: 10/07/2005)
10/12/2005 8 Request to BNC - Meeting of Creditors. 341(a) meeting to be held on
12/8/2005 at 09:00 AM Pederal Bldg, Trustee Hearing Rm, Rm 1160,
I Ith PI, 228 Walnut St, Harrisburg, PA Proofs of Claims due by
3/8/2006 Last day to Object to Plan Confirmation 4/7/2006 (DG)
(Entered: 10/12/2(05)
10/14/2005 9 BNC Certificate of Mailing of 341 Meeting Notice (Chapter 13) (RE:
related document(s)~). Service Date 10/14/2005. (Admin.) (Entered:
10/15/20(5)
10/14/2005 10 BNC Certificate of Chapter 12/13 Plan (RE: related document(s)~).
Service Date 10/14/2005. (Admin.) (Entered: 10/15/2005)
11103/2005 lJ Objection to Confirmation of Plan Piled by Leslie E Puida of
Goldbeck McCafferty and McKeever on behalf of Long Beach
Mortgage Loan Trust 2004-5 (RE: related document(s)Q).
(Attachments: # 1 Proposed Order # 2 Exhibit A. Ch. 13 Plan# 3
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Exhibit B. POC# 4 Certificate ofService)(Puida, Leslie) (Entered:
11/03/2005)
11/04/2005 12 Notice to Parties: (RE: related document(s)ll ). Hearing scheduled
for 12/6/2005 at 09:00 AM at 3rd & Walnut Sts., Bankruptcy
Courtroom (3rd Floor), Ronald Reagan Federal Building, Harrisburg,
PA. (Attachments: # I Certificate of Service) (KZ) (Entered:
11/04/2005)
11/23/2005 13 Objection to Claim # Long Beach Mortgage Loan Trust (Claim does
not appear on claims register) Filed by Robert 1. O'Brien of O'Brien
Baric and Scherer on behalf of Robert Lee Shoff. (O'Brien, Robert)
Additional attachment(s) added on 11/29/2005 (BW). (Entered:
11/23/2005)
11/23/2005 14 Corrective Entry: previous attachment omitted/incorrect/incomplete
Filed by Robert 1. O'Brien of O'Brien Baric and Scherer on behalf of
Robert Lee Shoff(RE: related document(s)13). (O'Brien, Robert)
(Entered: 11/23/2005)
11/25/2005 15 Notice sent to counsel for mailing fixing answer/objection date (RE:
related document(s)13 ). (KZ) (Entered: 11/25/2005)
11/28/2005 16 Objection to Claim # Notice to Claimant of Objection to Claim.
Notice sent to c1airnant. Filed by Robert 1. O'Brien of O'Brien Baric
and Scherer on behalf of Robert Lee Shoff. Answers are due on:
12/28/2005. (O'Brien, Robert) (Entered: 11/28/2005)
12/01/2005 17 Motion for Relief from Stay. Filing fee due in the amount of$ 150.00
Filed by Leslie E Puida of Goldbeck McCafferty and McKeever on
behalf of Deutsche Bank National Trust Company, as Trustee for
Long Beach Mortgage Loan Trust 2004-5. (Attachments: # 1
Proposed Order # 2 Payment History# 3 Certificate of
Nonconcurrence) (Puida, Leslie) (Entered: 12/01/2005)
12/01/2005 Receipt of Motion for Relief From Stay(1 :05-bk-05921-MDF)
(motion,mrlfsty] ( 150.00) filing fee. Receipt number 1414465,
amount $ 150.00. (U.S. Treasury) (Entered: 12/01/2005)
12/02/2005 18 Order (RE: related document(s) 17 ). Answers are due on: 12/17/2005.
Hearing scheduled for 12/21/2005 at 09:00 AM at 3rd & Walnut Sts.,
Bankruptcy Courtroom (3rd Floor), Ronald Reagan Federal Building,
Harrisburg, P A. (KZ) (Entered: 12/02/2005)
12/05/2005 19 Certificate of Service Filed by Leslie E Puida of Goldbeck
McCafferty and McKeever on behalf of Deutsche Bank National
Trust Company, as Trustee for Long Beach Mortgage Loan Trust
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2004-5 (RE: related document(s)l 11, I Z ). (Puida, Leslie) (Entered:
12/05/2005)
12/06/2005 20 Proceeding Memo hearing called and continued. Matter continued to
be rescheduled when the Objection to Claim is scheduled for hearing.
Appearances: James Jones. Non-Appearances: Robert O'Brien. (There
is no image or paper document associated with this entry.) (RE:
related document(s)11, 12 ). (JG) (Entered: 12/06/2005)
12/15/2005 21 Certification that 341 Meeting of Creditors (Ch. 13) Not Held on
12/08/05. To be Rescheduled for Debtor. (There is no image or paper
document associated with this entry.). (dehart, III(cm), Charles)
(Entered: 12/15/2005)
12/1 9/2005 22 Request to BNC - Meeting of Creditors Rescheduled. 341(a) meeting
to be held on 2/2/2006 at II :00 AM at Federal Bldg, Trustee Hearing
Rm, Rm 1160, 11th Fl, 228 Walnut St, Harrisburg, P A. (DG)
(Entered: 12/1 9/2005)
12/20/2005 23 Order Granting Motion for Relief from Stay (RE: related document(s)
1Z). (KZ) (Entered: 12/21/2005)
12/21/2005 24 BNC Certificate of Mailing. (RE: related document(s)~2). Service
Date 12/21/2005. (Admin.) (Entered: 12/22/2005)
12/22/2005 25 Answer to Objection to Claim Filed by Leslie E Puida of Goldbeck
McCafferty and McKeever on behalf of Deutsche Bank National
Trust Company, as Trustee for Long Beach Mortgage Loan Trust
2004-5 (RE: related document(s) 1 ~ ). (Attachments: # 1 Certificate of
Service) (Puida, Leslie) (Entered: 12/22/2005)
12/23/2005 26 Notice to Parties: (RE: related document(s)l:i, 22). Hearing
scheduled for 1/23/2006 at 09:30 AM at 3rd & Walnut Sts.,
Bankruptcy Courtroom (3rd Floor), Ronald Reagan Federal Building,
Harrisburg, PA. (Attachments: # 1 Certificate of Service) (KZ)
(Entered: 12/23/2005)
01/06/2006 27 Motion to Dismiss Case for material default and hearing notice to
parties. Filed by Trustee. Hearing scheduled for 2/15/2006 at 09:00
AM at 3rd & Walnut Sts., Bankruptcy Courtroom (3rd Floor), Ronald
Reagan Federal Building, Harrisburg, PA. (dehart, III(ds), Charles)
(Entered: 01/06/2006)
II
II
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I PACER Service Center I
I Transaction Receipt I
I 01/11/200609:53:15 I
PACER ~a0060 I Client
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Description: Docket Search Fil Doc From: 0 Doc To:
Report Criteria: 99999999 Term: y Links: n
Formal: HTMLfmt
Billable D810.24 I
Pages:
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05-1116
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, P A 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR LONG BEACH
MORTGAGE LOAN TRUST 2004-5
9451 Corbin Avenue
Northridge, CA 91324
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
vs.
ROBERT 1. SHOFF
Mortgagor(s) and Record Owner(s)
ACTION OF MORTGAGE
FORECLOSURE
26 Maple Avenue
Walnut Bottom, P A 17266
Term
No. 05-1116
Defendant( s
THIS LAW fiRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBT AINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: SHOFF, ROBERT L.
ROBERT L. SHOFF
26 Maple Avenue
Walnut Bottom, PA 17266
Your house at 26 Maple Avenue, Walnut Bottom, PA 17266 is scheduled to be sold at Sheriffs
Sale on Wednesday, June 07, 2006, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to
enforce the court judgment of $72,298.95 obtained by DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2004-5 against you.
NOTICE OF OWNER'S RIGHTS
YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2004-5, the back payments, late
charges, costs and reasonable attorney's fees due, To find out how much you must pay call:
215-627-1322
,.,
......
05-1116
2. You maybe able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attomey).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1, If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fmd
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriffof717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, yon will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6, You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
(..-
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Goldbeck McCafferty & McKeever
BY:)oseph A. Goldbeck, Jr.
Attomey 10. #16132
. Suite 5000 - Mellon Independence Center
70 I Market Street
Philadelphia, P A 19106-1532
215-627-1322
Attomey fllr Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR LONG BEACH
MORTGAGE LOAN TRUST 2004-5
9451 Corbin A venue
Northridge, CA 91324
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plainti ff
vs.
CIVIL ACTION - LAW
ROBERT 1. SHOFF
(Mortgagor(s) and Record Owner(s))
26 Maple Avenue
Walnut Bottom, PA 17266
ACTION OF MORTGAGE FORECLOSURE
Oefendant( s)
No.05-1116
AFFIDAVIT PURSUANT TO RULE 3129
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN
TRUST 2004-5, Plaintiff in the above action, by its attomey, Joseph A. Goldbeck, .lr., Esquire. sets forth as of the date the
praecipe for the wrlt of execution was filed the follO\ving information concerning the real property located at:
26 Maple Avenue
Walnut Bottom. PA 17266
I.Name and address ofOv.mcr(s) or Reputed Owncr(s):
ROBERT L. SHOFF
26 Maple Avenue
Walnut Bottom, I' A 17266
2. Name and address of Dcfendant(s) in the judgment:
ROBERT L SllOFF
26 Maple Avenue
\Valnut Bottom, PA 17266
3. Name and last knov/Il address of every judgment creditor \vhose judgment is a record lien on the property \0 be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
PA DEPARTMENT OF ['UHUC WELFARE - Bureau orCliild Support Enlllreement
llealth and Welfare Bldg, - Rnnm 432
[,,0, llox 2675
llarrisburg. P A 17105-2675
4. Name and address of the last recorded holder of every mortgage of record:
.
LONG BEACH MORTGAGE COMPANY
1400 S, DOUGLASS ROAD
STE 100
ANAHEIM, CA 92806
5. Name and address of every other person \vho has any record interest in or record lien on the property and \vhose interest
may be atleeted by tbe sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge \\'110 has any interest in the property which
may be affected by the sale.
TENANTS/OCCUP ANTS
26 Maple Avenue
Walnut Bottom, PA 17266
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
DATED: Januarv 11, 2006
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Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 5000 - Mellon Independence Center
70 I Market Street
Philadelphia, P A 19106-1532
215-627-1322
Attorney I'Jr Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE FOR LONG BEACH MORTGAGE LOAN
TRUST 2004-5
9451 Corbin Avenue
Northridge, CA 91324
IN THE COURT OF
COMMON PLEAS
Plaintiff
YS.
of Cumberland County
ROBERT L. SHOFF
Mortgagor(s) and Record Owner(s)
26 Maple A venue
Walnut Bottom, PA 17266
CIVIL ACTION - LAW
ACTION OF
MORTGAGE FORECLOSURE
Defendant(s)
NO. 05-1 116
CERTIFICATION AS TO THE SALE OF REAL PROPERTY
I, Joseph A. Goldbeck, Jr., Esquire hereby certify that I am the attorney of record for the Plaintiff in this
action, and I further certify that this property is subjcct to Act 91 of 1983 and the Plaintiff has complied with all
the provisions of the Act.
~
I
SHORT DESCRIPTION
IMPROVEMENTS consist of a residential dwelling.
BEING PREMISES: 26 Maple Avenue
Walnut Bottom, PA 17266
SOLD as the property of ROBERT 1. SHOFF
TAX PARCEL #41-31-2230-004
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorne for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR LONG BEACH MORTGAGE
LOAN TRUST 2004-5
9451 Corbin Avenue
Northridge, CA 91324
WM-0495
CF: 03/03/2005
SD: 06/07/2006
$72,298.95
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
Plaintiff
vs.
ACTION OF MORTGAGE FORECLOSURE
ROBERT 1. SHOFF
Mortgagor(s) and
Reeord Owner(s)
TeIm
No. 05-1116
26 Maple Avenue
Walnut Bottom, P A 17266
Defendant(s)
CERTIFICATE OF SERVICE
PURSUANT TO Pa.R.C.P. 3129.2 (c) (2)
Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the
Defendants of the Notice of Sheriff Sale was made by:
( ) Personal Service by the Sheriff's Office/competent adult (copy of return attached).
6() Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached).
( ) Certified mail by Sheriff's Office.
( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record
(proof of mailing attached).
( ) Acknowledgment of Sheriff's Sale by Attorney for Defendant(s) (proof of acknowledgment
attached).
( ) Ordinary mail by Sheriff's Office to Attorney for Defendant(s) of record.
IF SERVICE WAS ACCOMPLISHED BY COURT ORDER.
( ) Premises was posted by Sheriff's Office/competent adult (copy of return attached).
( ) Certified Mail & ordinary mail by Sheriff's Office (copy of return attached).
( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified
Mail attached).
Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been
made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached).
The undersigned understands that the statements herein are subjectto the penalties provided by 18 P.S.
Section 4904.
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, P A 19106
215-825-6320
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR LONG BEACH
MORTGAGE LOAN TRUST 2004-5
9451 Corbin Avenue
Northridge, CA 91324
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVlL ACTION - LAW
vs.
ACTION OF MORTGAGE FORECLOSURE
ROBERT 1. SHOFF
Mortgagor(s) and Rec:ord Owner(s)
Tenn
No. 05-1116
26 Maple Avenue
Walnut Bottom, P A 17266
Defendant( s)
AFFIDAVIT PURSUANT TO RULE 3129
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE
LOAN TRUST 2004-5, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of
the date the praecipe for the writ of execution was filed the following information concerning the real property located
at:
26 Maple Avenue
Walnut Bottom, P A 17266
l.Name and address ofOwner(s) or Reputed Owner(s):
ROBERT L. SHOFF
26 Maple Avenue
Walnut Bottom, P A 17266
2. Name and address ofDefendant(s) in the judgment:
ROBERT L. SHOFF
26 Maple Avenue
Walnut Bottom, PA 17266
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be
sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, P A 17013
. .
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
4. Name and address of the last recorded holder of every mortgage of record:
LONG BEACH MORTGAGE COMPANY
1400 S. DOUGLASS ROAD
STE 100
ANAHEIM, CA 92806
5. Name and address of every other person who has any record interest in or record lien on the property and whose
interest may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the
property which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property
which may be affected by the sale.
TENANTS/OCCUPANTS
26 Maple Avenue
Walnut Bottom, PA 17266
(attach separate sheet if more space is needed)
I verifY that the statements made in this affidavit are true and correct to the best of my personal knowledge
or infonnation and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
Section 4904 relating to unsworn falsification to authorities.
DATED: May 11,2006
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
}SS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff's Deed in which Long Beach Mtg Loan Trust 2004-5. Tr is the grantee the same having been
sold to said grantee on the 7th day of June A.D., 2006, under and by virtue of a writ Execution issued on
the 13th day of January, A.D., 2006, out of the Court of Common Pleas of said County as of Civil Term,
2005 Number 1116, at the suit of Deutsche Bank Natl Tr Co. Tr for Long Beach Mtg Ln Trust 2004-5
against Robert L Shoff is duly recorded in Deed Book No. 275, Page 1878.
IN TESTIMONY WHEREOF, I have hereunto set my hand
.-IIk,
and s 1 of said office this d 9 day of
, A.D. 02 d'tJ {;
\
Deutsche Bank National Trust Company
As Trustee for Long Beach Mortgage
Mortgage Loan Trust 2004-5
VS
Robert L. Shoff
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2005-1116 Civil Term
Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on
March 07,2006 at 12:22 o'clock PM, she served a true copy of the within Real Estate Writ,
Notice and Description, in the above entitled action, upon the within named defendant, to wit:
Robert L. Shoff, by making known unto Ronald Martin, Jr., adult in charge of residence, at 26
Maple Avenue, Walnut Bottom, Cumberland County, Pennsylvania, its contents and at the same
time handing to him personally the said true and correct copy of the same.
Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on
April 05, 2006 at 5:20 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice,
Poster and Description, in the above entitled action, upon the property of Robert L. Shoff located
at 26 Maple Ave., Walnut Bottom, Pennsylvania, according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the
above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff
mailed a notice of the pendency of the action to the within named defendant, to wit: Robert L.
Shoff by regular mail to his last known address of26 Maple Ave., Walnut Bottom, PA 17266.
This letter was mailed under the date of April 03, 2006 and never returned to the Sheriff's Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due
and legal notice had been given according to law, he exposed the within described premises at
public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on June
07,2006 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Joseph
Goldbeck for Deutsche Bank National Trust Company, as Trustee for Long Beach Mortgage
Loan Trust 2004-5. It being the highest bid and best price received for the same, Deutsche Bank
National Trust Company as Trustee for Long Beach Mortgage Loan Trust 2004-5 of 9451
Corbin Avenue, Northridge, CA 91324, being the buyer in this execution, paid to SheriffR.
Thomas Kline the sum of $1,102.16.
Sheriff's Costs:
Docketing
Poundage
Posting Bills
Advertising
Acknowledging Deed
Auctioneer
$30.00
21.61
30.00
30.00
30.00
10.00
Prothonotary
Mileage
Certified Mail
Levy
Surcharge
Law Journal
Patriot News
Share of Bills
Distribution of Proceeds
Sheriffs Deed
So Answers:
1.00
24.64
4.64
30.00
30.00
407.00
369.20
19.57
25.00
39.50
$1,102.16 /
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R. Thomas Kline, Sheriff
ByJa<i~(SMd~
Real Estate Sergeant
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Goldbeck McCatTerty & McKeever
BY: Joseph A. Goldbeck, Jr.
Attomey 1.0. #16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia. P A 19106-1532
215-627-1322
Attomey for PlaintitT
DEUTSCHE BANK NATIONAL TRUST
COMP ANY, AS TRUSTEE FOR LONG BEACH
MORTGAGE LOAN TRUST 2004-5
9451 Corbin Avenue
Northridge, CA 91324
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
vs.
CIVIL ACTION - LAW
ROBERT L. SHOFF
(Mortgagor(s) and Record Owner(s))
26 Maple Avenue
Walnut Bottom, P A 17266
ACTION OF MORTGAGE FORECLOSURE
Defendant( s)
No. 05-1116
AFFIDAVIT PURSUANT TO RULE 3129
DEUTSCHE BANK NATIONAL TRUST COMPANY. AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN
TRUST 2004-5. Plaintitfin the above action, by its attomey, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the
praecipe for the writ of execution was filed the tollowing information concerning the real property located at:
26 Maple Avenue
Walnut Bottom, P A 17266
I.Name and address ofOwner(s) or Reputed Owner(s):
ROBERT L. SHOFF
26 Maple Avenue
Walnut Bottom, P A 17266
2. Name and address of Defenclant(s) in the judgment:
ROBERT L. SHOFF
26 Maple Avenue
Walnut Bottom, P A 172 66
3. Name and last known address of every judgmcnt creditor \vhose judgment is a record lien un the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcemcnt
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
,.
4. Name and address of the last recorded holder of every mortgage of record:
LONG BEACH MORTGAGE COMPANY
1400 S. DOUGLASS ROAD
STE 100
ANAHEIM, CA 92806
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of \vhom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be atTected by the sale.
TENANTS/OCCUP ANTS
26 Maple Avenue
Walnut Bottom. P A 17266
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unswom falsification to authorities.
DATED: January 11, 2006
r
I
05-1116
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, P A 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR LONG BEACH
MORTGAGE LOAN TRUST 2004-5
9451 Corbin Avenue
Northridge, CA 91324
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
vs.
ROBERT L. SHOFF
Mortgagor(s) and Record Owner(s)
ACTION OF MORTGAGE
FORECLOSURE
26 Maple Avenue
Walnut Bottom, PAl 7266
Term
No. 05-1116
Defendant( s
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: SHOFF, ROBERT L.
ROBERT L. SHOFF
26 Maple Avenue
Walnut Bottom, P A 17266
Your house at 26 Maple Avenue, Walnut Bottom, P A 17266 is scheduled to be sold at Sheriffs
Sale on Wednesday, June 07,2006, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to
enforce the court judgment of $72,298.95 obtained by DEUTSCHE BANK NATIONAL TRUST
COMP ANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2004-5 against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT TillS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2004-5, the back payments, late
charges, costs and reasonable attorney's fees due. To find out how much you must pay call:
215-627 -1322
,.
,
05-1116
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717 -240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, P A 17013
CUMBERLAND COUNTY BAR ASSOCIA nON
2 Liberty Avenue
Carlisle, PA 17013
All those two certain pieces or parcels of land situate in South Newton Township, County of
Cumberland and State of Pennsylvania, bounded and described as follows, to wit:
Tract No.1: Beginning at an iron pin in the center of the public road leading from Jacksonville to the
Stoughstown public road also known as Maple Avenue; thence by the center of the same, north 36
degrees west, a distance of29.8 feet to an iron pin in the center of the public road; thence along lands,
now or formerly of John Robinson, south 57 degrees 40 minutes west, a distance of 161.2 feet to a stake;
thence by lands now or formerly of Clarence Gardner, south 37 degreed 40 minutes east, a distance of
134.3 feet to a stake; thence by lands now or formerly of Mrs. John Myers, north 41 Y2 degrees east, a
distance of 16.9 feet to a post; thence along lands now or formerly of Lena B. Thrush Estate and being
Tract No.2 hereinafter described, north 41 degrees 30 minutes west, a distance of83.4 feet to a stake,
thence continuing by lands now or formerly of Lena B. Thrush Estate and being Tract No.2 hereinafter
described, north 51 degrees 30 minutes east, a distance of 147.6 feet to the place of beginning.
Containing .55 acres.
Tract No.2: Bounded on the east by the public road leading from Jacksonville to the Stoughstown
public road also know as Maple Avenue, on the north and west by lands now or formerly of the Estate of
Lena B. Thrush, being Tract No.1 hereinafter described; and on the south by land now or formerly of
John Killinger and Mae Killinger, his wife, containing one-fourth acre, more or less.
The above two tracts of land containing a total frontage of 96 feet more or less, and being improved with
a dwelling house, known as 26 Maple Avenue, Walnut Bottom, South Newton Township, Cumberland
County, Pennsylvania.
TAX PARCEL # 41-31-2230-004
WRIT OF EXKCUTION and/or A TT ACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 05-1116 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2004-5, Plaintiff (s)
From ROBERT L. SHOFF
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property ofthe defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $72,298.95
Interest FROM 8/1/04 TO 4/30/05 AT 7.0500%
L.L.
Atty's Conun
%
Due Prothy $1.00
Other Costs
Atty Paid $1089.50
Plaintiff Paid
(Seal)
(L~
p;;'thonotary- 1
By:
Date: JANUARY 13, 2006
Deputy
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK, JR., ESQUIRE
Address: SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106-1532
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ID No. 16132
Real Estate Sale # 06
On February 03,2006 the Sheriff levied upon the
defendant's interest in the real property situated in
South Newton Township, Cumberland County, P A
Known and numbered as 26 Maple Ave.,
Walnut Bottom, more fully described on Exhibit" A"
filed with this writ and by this reference incorporated herein.
Date: February 03, 2006
By:
j(,ct\..t"')~VlLl \
Real Estate Sergeant
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THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16,1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Joseph A. Dennison, being duly sworn according to law, deposes and says:
That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the
laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market
Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-
News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market
Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were
established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever
smce;
That the printed notice or publication which is securely attached hereto is exactly as printed and published
in their regular daily and/or Sunday/ Metro editions which appeared in the 19th and 26th day(s) of April and the
3rd day(s) of May 2006. That neither he nor said Company is interested in the subject matter of said printed notice
or advertising, and that all of the allegations of this statement as to the time, place and character of publication are
true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed
and adopted severally by the stockholders and board of directors of the said Company and subsequently duly
recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M",
Volume 14, Page 317.
PUBLICATION
COPY
SALE#6
'~
~.....,.....,..,...,',., ,.,
My commission expires June 6, 2006
CUMBERLAND COUNTY SHERIFF'S OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
REM. ESTATE -.eNO. CI6
...... .......'..CIifI.......
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~ " .~.J~..1!)~'U.&
BeMh..-~ ~....'Du8t
5
VS
Robert L Shoff
- AttonwI'........ GoIchck
DESCRf'"C*
ALL TIIOSE lWO CElUAIN pieces or parcels
of land situate in South Newton Township. County
of ~..... ~ ofJ>enDsylvania,
boo1IdeII_~~. to wit:
'I'aACT NO. t: ........ !It an iron pin in the
C$Iet of. JlIIbIir:....:...,from Jacbonville
to the ~_.... ~ also biwmas
MIple AWll!UIl;.*,=- .". the ceDlIlfof. the same,
00I'lII36'" west, .~ of 29.8 feet to an
iron pin iBthe _ of lbe Jdltic road; tha1ce
aloog lands; BOW oc foaIedy of JoIm Robiasoo.
SOU1b 57 .... 40...... west. a distlIIIl:e of
161.2 feet to a sate; .thaa:e by 1aJids now or
fonnedy erq.a:eGadliec. 80lIIh 37 degrees 40
minuIl:s east, a distlIIIl:eof 134.3 feet to a Slake;
tIlaIlc by.... _or ~ 6f Mrs. John
MJaJ...,.41___-. ~of 16.9
feet 10.."" 1heuce aIoag' _ BOW or formerly
ofu.aJl.1'lImsfi,&tl\fe and being Tract No. 2
~~'JMidh414egrees 30 minutes
west, a......., of 33.4 feet to astake,thence
~'Y 1Imds now or funnerly of Lena B.
....J!.llIIre IlIIIlI:!eiIg'Traict No. 2 bereinafter
~:... n clples. 30 minuIes east, a
diMe 01147.6 feet tolhe place of begimIing.
CoIlI8ilW .ss acres. ,
TItAC'f NO. 2: ~ on the east by the
pubJ1I: 1V8d 1eadiDg jrondacbonville to the
St~ JlIl* nlillalto. know as Maple
=':===.~~~
Tral:rNo; 1 ~~ ._the so1llh
by .. now. OC ~ of Jolla. Killinger and
Mae IiIlinp. his wile. ,.COIIIlIiDiJlg. '*"foortb.
acre, more or less.
The above two tracts of land containing a total
IiOIdage of, 96 feet . QlOle or less. ... being
~. . ~Iaouse, kDowJ1 as 26
.... ~. ~'~..SQUdl Newton
k~ ~';.3~_'-Y1wDia
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEAL TH OF PENNSYL VANIA
ss.
COUNTY OF CUMBERLAND
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
VIZ:
April 7, 14,21,2006
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
SWORN TO AND SUBSCRIBED before me this
21 day of April. 2006
t~!-i~,~~N
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REAL ESTATIi; SALE NO. 6
Writ No. 2005-1116 Civil
Deutsche Bank National Trust
Company, as Trustee for Long
Beach Mortgage Loan Trust
2004-5
vs.
Robert L. Shoff
Atty.: Joseph Goldbeck
All those two certain pieces or
parcels ofland situate in South New-
ton Township, County of
Cumberland and State of Pennsyl-
vania, bounded and described as
follows, to wit:
1ract No.1: Beginning at an iron
pin in the center of the public road
leading from Jacksonville to the
Stoughstown public road also known
as Maple Avenue; thence by the
center of the same, north 36 de-
grees west, a distance of 29.8 feet
to an iron pin in the center of the
public road; thence along lands,
now or formerly of John Robinson,
south 57 degrees 40 minutes west,
a distance of 161.2 feet to a stake:
thence by lands now or formerly of
Clarence Gardner, south 37 degrees
40 minutes east, a distance of 134.3
feet to a stake; thence by lands now
or formerly of Mrs. John Myers,
north 41 1/2 degrees east, a dis-
tance of 16.9 feet to a post; thence
along lands now or formerly of Lena
B. Thrush Estate and being 1ract
No.2 hereinafter described, north
41 degrees 30 minutes west, a dis-
tance of 83.4 feet to a stake, thence
continuing by lands now or formerly
of Lena B. Thrush Estate and being
Tract No.2 hereinafter described,
north 51 degrees 30 minutes east.
a distance of 147.6 feet to the place
of beginning. Containing .55 acres.
Tract No.2: Bounded on the east.
by the public road leading from
Jacksonville to t.he Stoughst.own
public road also know as Maple Av-
enue, on t.he north and west by
lands now or formerly of the Est.ate
of Lena B. Thrush, being Tract No.
1 hereinafter described; and on the
south by land now or formerly of
John Killinger and Mae Killinger, his
wife, containing one-fourth acre,
more or less.
The above two tracts of land con-
taining a total frontage of 96 feet
more or less, and being improved
with a dwelling house, known as 26
Maple Avenue, Walnut. Bottom, South
Newton Township, Cumberland
County, Pennsylvania.
TAX PARCEL # 41-31-2230-004.
Assie:nment of Bid
NO. 05-1116 - SHOFF
26 Maple Avenue
Walnut Bottom, P A 17266
I, Joseph A. Goldbeck, Jr., Esquire, as attorney for the successful bidder, hereby
assign my bid at the Sheriff Sale dated June 07, 2006 to:
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH
MORTGAGE LOAN TRUST 2004-5
9451 Corbin Avenue
Northridge, CA 91324
GOLDBECK MCCAFFERTY & MCKEEVER
Date: June 14. 2006
?'t~~
JOSEPH A. GOLDBECK, JR.