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HomeMy WebLinkAbout14-5985 Supreme Ca nnsylvaiva COU „leas Fotzi Y/se Onrly s i '6 . 1. z �� DOZ?lcet iib � j f'' County The information collected on this form is used solely for court administration purposes. This form does not su plemenI or replace the filing and service ofpleadin s or otherpa ers as mquired by law or rules of court. Commencement of Action: D Complaint Q Writ of Summons Q Petition Q Transfer from Another Jurisdiction Q Declaration of Taking C } Lead Plaintiff's Name: Lead Defendant's Nagar: 14 �-pQ John Doe and/or Tenant Occupant Dollar Amount Requested: Qwithin arbitration limits Are money damages requested? Q Yes M No (check one) Qoutside arbitration limits .: Is this a Class Ac on Suit? Q Yes 0 No Is this an MDJAppeal? Yes ® No . Name ofPlaindWAppellant's Attorney: UDREN LAW OFFICE,P.0 Q Check here if you have no attorney(are a Self-Represented[Pro Se]Litigant) Nature.of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim,check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS Q Intentional Q Buyer Plaintiff Acluunistive Agencies Q Malicious Prosecution Q Debt Collection:Credit Card Q Board of Assessment Q Morar Vehicle Q Debt Collection:Other Q Board of Elections Q Nuisance Dept.of T . Q Premises Liability Transportation Statutory Appeal:Other Q Product Liability(does not include mass tort) Q Employment Dispute: �Slander/Libel/Defamation Discrimination 13 Other: Q Employment Dispute:Other Q Zoning Board ®Other. Q Other: MASS TORT Q Asbestos :. Tobacco Toxic Tort•DES Q Toxic Tort-Implant phi qL PROPERTY MISCELLANEOUS Q Toxic Waste ®Ejectment Q Other J Q Common Law/Statutory Arbitration Q Eminent Domain/Condemnation Q Declaratory Judgment Q Ground Rent Q Mandamus Q Landlord/Tent Dispute Q Non-Domestic Relations Q Mortgage Foreclosure:Residential Resuaining Orden. PROFESSIONAL LIABLITY ®Mortgage Foreclosure:Commercial Q Quo arum Q Dental Q Partition Q Replevin Q Legal ©Quiet Title Q Other. Q Medical Q Other: Q Other Professional: Updated 1/1/1011 t t o � ? V a. {U t P'.,�f F This is a non-jury matter 29 114 OF -8 AN ;' ; Assessment of Damages Hearing not required L rl-3E rk � U CUE �� Not arbitration matter UDREN LAW OFFICES, P.C. PENINCYL.VA't'iIA ATTORNEY FOR PLAINTIFF 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 pleadings@udren.com U.S. Bank, N.A. , as Trustee for COURT OF COMMON PLEAS the Registered Holders of CIVIL DIVISION Structured Asset Securities Cumberland County Corporation Mortgage Pass-Through Certificates, Series 2007-TC1 ` S�i P 5720 Premier Park Drive ; NO. II West Palm Beach, FL 33407 Plaintiff V. John Doe and/or Tenant/Occupant 19 Holly Estates Drive Gardners, PA 17324 Defendant (s) CIVIL ACTION COMPLAINT IN EJECTMENT YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 "� Iv ! /�✓((!! 717-249-3166 2W 249G3� AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus obj eciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SERVICE DE REFERENCIA E INFORMACION LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 1. Plaintiff is the corporation or individual named on the caption, and whose address or principal office appears in the caption. 2 . Defendant (s) are those named as such on the caption, and occupy the premises (hereinafter "Premises") which address is set forth on the caption. 3 . Premises, a legal description of which is attached hereto, was sold at Sheriff ' s Sale in accordance with law on August 6, 2014, and Plaintiff became owner thereof as a result of being the successful bidder and thus the purchaser at said sale, and remains real owner thereof . A true and correct copy of the deed in favor of Plaintiff is attached hereto as Exhibit "A" . 4 . The person(s) in possession of Premises are the Defendant (s) herein, and are occupying Premises without right or claim to title. 5 . Plaintiff has demanded possession of Premises from Defendant (s) who have refused to deliver up the possession thereof . WHEREFORE, Plaintiff demands judgment for immediate possession of Premises, issuance of a Writ of Possession and a judgment of its costs and disbursement in s action. UDRE LAW CES, P.C. ATTO EY PLAINTIFF AMANDA . RAUER.. ESO DIRE PA, I.I . # 307028 ooGooc Tax Parcel No 08-16-0210-094 Know all Men by these Presents That I,Ronny R.Anderson, Sheriff of the County of Cumberland,In the State of Pennsylvania,for and in consideration of the sum of$ 1.00 (One Dollar)to me in hand paid,do hereby grant and convey to U.S.Bank,N.A.,as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates,Series 2007- TC1 2012-728 Civil Term U.S. Bank,N.A., as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007- TC1 Vs Unknown Heirs,Successors,Assigns and All Persons,Firms or Associations Claiming Right Title or Interest From or Under Patricia M. Sobotor,Deceased Michael P. Sobotor Patricia M. Sobotor,Deceased ALL that certain piece or,parcel of land,situate, lying and being in Dickinson Township, Cumberland County,Pennsylvania,bounded and described in accordance with a certain Final Subdivision Plan for Holly Estates prepared by Thomas and Associates, Surveyors, dated November 29, 1977, consisting of 1 page, a copy of which is recorded in Cumberland County Plan Book 33,page 136 on September 20, 1978, and incorporated herein by reference as follows; BEGINNING at a point on the Westwardly line of Holly Estates drive (50 feet wide right of way)at the southeast corner of Lot No. 10 on a certain Subdivision for Richard B.Anderson recorded in Plan Book28,page 135; thence by the Westwardly line of the said Holly Estate Drive, South 17 degrees 29 minutes 28 seconds West 150 feet to a point being the northeast corner of Lot NO.8 on Plan of Holly Estates;thence by Lot No. 8 North 72 degrees 30 minutes 32 seconds West 299.14 feet to a point on line of lands now or formerly of John Delp; thence by lands of Delp,North 17 degrees 10 minutes 56 seconds East 149.15 feet to a point being the southwest corner of Lot No, 9 on Subdivision for Richard E.Anderson; thence by Lot No.9 and Lot No. 10 on Subdivision for Richard E. Anderson, South 72 degrees 40 minutes 32 seconds East 299.94 feet to a point,the place of beginning. Containing 1.0256 acres,more or less. BEING all of Lot NO.7 on Plan of Holly Estates,and known and numbered as 19 Holly Estates Drive, Gardners, PA 17324. BEING KNOWN AS: 19 Holly Estates Drive, Gardners,PA 17324 PROPERTY ID NO.: 08-16-0210-094 TITLE TO SAID'PREMISES IS VESTED IN Patricia M.Sobotor and Michael P. Sobotor, husband and wife BY DEED FROM Patricia M.Knudson,now by marriage known as Patricia M Sobotor DATED 09/08/1999 RECORDED 09/14/1999 IN DEED BOOK 207 PAGE 735. The same having been sold by me to the said grantee on the 6th day of August Anno Domini Two Thousand and Fourteen(2014)after due advertisement according to law,under and by Virtue of a Writ of Execution issued on the 218t of February Anno Domini 2014 out of the Court of Common Pleas of Cumberland County,Pennsylvania, as of Civil Term,Two Thousand and Twelve(2012) Number 728 at the suit of U.S.Bank,N.A.,as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2007-TCI Vs Unknown Heirs,Successors,Assigns and All Persons,Firms or Associations Claiming Right Title or Interest From or Under Patricia M.Sobotor,Deceased,Michael P. Sobotor, Patricia M. Sobotor,Deceased In Witness Whereof,I have hereunto affixed my signature this 26th day of A gust Anno Domini Two Thousand and Fourteen(2014) onny .Anderson, Sheriff Commonwealth of Pennsylvania,ss. County of Cumberland Before the undersigned, David D. Buell,Prothonotary of the Court of Common Pleas of Cumberland County,Pennsylvania,personally appeared Ronny R. Anderson, Sheriff of Cumberland County aforesaid, and in due form of law declared that the facts Set forth in the foregoing Deed are true, and that he acknowledged the same in order that Said deed might be recorded. Witness my hand and seal of said Court,this 26th day of August Anno Domini Two Thousand and Fourteen(2014) on ,, �'r, t; t•t r rr� RdMftcumoe Urg country CaMe,PA MIP Caren E*U the Fnt MOMby of M.2018 I hereby certify that the residence And Post Office address of the �; , •.„ -�-�e, . ,� Within Grantee is 5720 Premier Park Drive .4 ••• . West Palm Beach FL 33407 Richard W. Stewart Solicitor TAMMY SHEARER RECORDER OF DEEDS 4. CUMBERLAND COUNTY I COURTHOUSE SQUARE CARLISLE, PA 1.7013 717-240-6370 Instrument Number-201420907 Recorded On 9/16/2014 At 11:30:25 AM *Total Pages-5 *Instrument Type-DEED-SHERIFFS Invoice Number-168497 User ID-MSW *Grantor-SOBOTOR,PATRICIA M *Grantee-REGISTERED HOLDERS OF STRUCTURED ASSET SECURTTTTES CORP MTG PASS-T' *Customer-UDREN LAW OFFICES *FEES STATE WRIT TAX $0.50 Certification Page STATE JCS/ACCESS TO $35.50 JUSTICE DO NOT DETACH RECORDING FEES - $12.50 RECORDER OF DEEDS PARCEL CERTIFICATION $15.00 This page is now part FEES of this legal document. AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 CARLISLE AREA SCHOOL $0.00 DISTRICT DICKINSON TOWNSHIP $0.00 TOTAL PAID $80.00 I Certify this to be recorded in Cumberland County PA RECORDER OF DEEDS "-Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 00Go0C liilllllllllllllllllllllllll VERIFICATION The undersigned an attorney for the Plaintiff and is authorized to make this verification. I verify that the facts set forth in the foregoing pleading are true and correct to the best of my information and belief . The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities . UDR OFFICES, P. C. AVIA ,O L. R, ESQUIRE DATED: October 7, 2014 D, # 307028 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson= ;LEO -OFFICE Sheriff OF THE PROTHONOTARY cviribeizb Jody S Smith Chief Deputy 2014 OCT 21 PM 2: 58 Richard W Stewart Solicitor OFF CE (F TK,, :U;RIFF CUMBERLAND COUNTY PENNSYLVANIA U.S. Bank, NA vs. John Doe (et al.) Case Number 2014-5985 SHERIFF'S RETURN OF SERVICE 10/13/2014 08:25 PM - Deputy William Cline, being duly sworn according to law, served the requested Complaint in Ejectment by handing a true copy to a person representing themselves to be Michael Sobotor, who accepted as "Adult Person in Charge" for John Doe at 19 Holly Estates Drive, Dickinson Twp, Gardners, PA 17324. WIL" AM CLI E, DEPUTY 10/13/2014 08:25 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Occupant/Tenant, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Ejectment as "Not Found" at 19 Holly Estates Drive, Dickinson Twp, Gardners, PA 17324. The only occupant of the property is Michael Sobotor. SHERIFF COST: $56.43 SO ANSWERS, October 15, 2014 RONNR ANDERSON, SHERIFF (c) CountySuite Sheriff, Tele osofi. Inc. P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com U.S. Bank, N.A. , as Trustee for : COURT OF COMMON PLEAS the Registered Holders of ; CIVIL DIVISION Structured Asset Securities ; Cumberland County Corporation Mortgage Pass- Through Certificates, Series 2007-TC1 . NO. 14-5985 Civil 5720 Premier Park Drive West Palm Beach, FL 33407 Plaintiff v V. ; r , John Doe and/or Tenant/Occupant 19 Holly Estates Drive Gardners, PA 17324 Defendants) PRAECIPE TO INDEX DEFENDANT PURSUANT TO PA.R.C. P. 410 (b) (2) TO THE PROTHONOTARY: Kindly index as a Defendant, pursuant to Pa.R.C. P. 410 (b) (2) , Michael Sobotor, who was found in possession of the real property subject of the within action in Ejectment. UDREN LAW OFFICES, P. C. Attorney for Plaintiff AN c rd o LC r '�121 I E".0 1 1.; PA 10 202194 UDREN LAW OFFICES, P.C. 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 pleadings@udren.com U.S. Bank, N.A., as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass - Through Certificates, Series 2007-TC1 5720 Premier Park Drive West Palm Beach, FL 33407 Plaintiff v. Michael Sobotor and/or Tenant/Occupant 19 Holly Estates Drive Gardners, PA 17324 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 14-5985 Civil PRAECIPE FOR JUDGMENT IN EJECTMENT TO THE PROTHONOTARY: Kindly enter Judgment in Ejectment in favor of the Plaintiff and against the Defendant(s), Michael Sobotor, and Tenant/Occupant, for possession of the premises appearing in the caption, for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof. I hereby certify that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. t 4 ,k Attorney for n if rouwe La, PA ID DEFAULT JUDGMENT ENTERED AS INDICATE DATE : It \ 1114 t_fertatsC„ Com EQ1. 2194 PRO PROTHY .si63tPci a l cid/ 7 3b/ I..0-.! Ma:LW D H 212<1„4 Sheriff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson cluriowN 17 THE PROTHONOTARY FILED-OFFICE 11:114.0CT 21 Pll 258 CUMBERLAND COUNTY ()FP C.& QF sKrurr PENNSYLVANIA Jody S Smith Chief Deputy Richard W Stewart Solicitor U.S. Bank, NA vs. John Doe (et al.) Case Number 2014-5985 SHERIFF'S RETURN OF SERVICE 10/13/2014 08:25 PM - Deputy William Cline, being duly sworn according to law, served the requested Complaint in Ejectment by handing a true copy to a person representing themselves to be Michael Sobotor, who accepted as "Adult Person in Charge" for John Doe at 19 Holly Estates Drive, Dickinson Twp, Gardners, PA 17324. AM CUE, DEPUTY 10/13/2014 08:25 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Occupant/Tenant, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Ejectment as "Not Found" at 19 Holly Estates Drive, Dickinson Twp, Gardners, PA 17324. The only occupant of the property is Michael Sobotor, SHERIFF COST: $56.43 SO ANSWERS, October 15, 2014 RONRR ANDERSON, SHERIFF (c) CountySulte Sherif f. Teleosoft. Inc. UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsftdren.com U.S. Bank, N.A., as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass - Through Certificates, Series 2007-TC1 5720 Premier Park Drive West Palm Beach, FL 33407 Plaintiff v. Michael Sobotor and Tenant /Occupant 19 Holly Estates Drive Gardners, PA 17324 Defendant(s) Michael Sobotor 19 Holly Estates Drive Gardners, PA 17324 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 14-5985 Civil DATE of Notice: November 3, 2014 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHARPREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMBDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 J. Eric Kishba gh, Esquire PA ID 33078 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL NEW JERSEY 08003-3620 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856 669-5400 pleadingsitudren.com U.S. Bank, N.A., as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass - Through Certificates, Series 2007-TC1 5720 Premier Park Drive West Palm Beach, FL 33407 Plaintiff v. Michael Sobotor and Tenant/Occupant 19 Holly Estates Drive Gardners, PA 17324 Defendant(s) TO: Tenant/Occupant 19 Holly Estates Drive Gardners, PA 17324 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 14-5985 Civil DATE of Notice: November 3, 2014 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER. TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Aasociation 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 NOTIFICACION IMPORTANTLY USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL.SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 J. Eric Kishbaugh, Esquire PA ID 33078 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL NEW JERSEY 08003-3620 UDREN LAW OFFICES, P.C. 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 pleadings@udren.com U.S. Bank, N.A., as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass - Through Certificates, Series 2007-TC1 5720 Premier Park Drive West Palm Beach, FL 33407 Plaintiff v. Michael Sobotor and/or Tenant/Occupant 19 Holly Estates Drive Gardners, PA 17324 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 14-5985 Civil AFFIDAVIT OF NON-MILITARY SERVICE UNDER Pa.R.C.P 76 THE UNDERSIGNED states, upon information and belief, that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Michael Sobotor Age: Over 18 Residence: As captioned above Employment: Unknown The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. DATED: November 14, 2014 ti Attor NIrtt4 o�rLlan f f lLLa PA !D 202194 Department of Defense Manpower Data Center Status Report Pursuant to Servicemenibers Civil Relief Act Last Name: SOBOTOR First Name: MICHAEL Middle Name: Active Duty Status As Of: Nov -14-2014 Results as of : Nov -14-2014 01:40:15 PM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA c� NA ./'r' ' +r} -+� —r.. ,'":.. '' if NN, NA This response reflectsthe individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Component NA f; .. NA N. '-- ' tService f "PNo 4} NA This response reflects where the individual left active duty s atus within 367 days preceding the Acture Duty Status Date I: • ` The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA .. NA -\ \e +No!! . ;r NA This response reflects whether the indmdual or his/her unit has recetved earty.nbtification toreport for active duty Upon searching the data banks of the Department of Defense Manpowei Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiersand Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this iricludes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: IFZB417A2OCBZ40 UDREN LAW OFFICES, P.C. 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 pleadingsftdren.com U.S. Bank, N.A., as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass - Through Certificates, Series 2007-TC1 5720 Premier Park Drive West Palm Beach, FL 33407 Plaintiff v. Michael Sobotor and/or Tenant/Occupant 19 Holly Estates Drive Gardners, PA 17324 Defendant (s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 14-5985 Civil PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Issue Writ of Possession in the above matter, for possession of the property captioned under Defendants above, a description of which is attached hereto: (gg-so Sco.ut LO it 1( d tfr / ,, Attorney for P • P.$ 1)( 5\ ftl f LY Nicole La13tta, Eq,Lzh, h PA ID 202194 s 1(,(0 Tax Parcel No 08-16-0210-094 1 111 OOCa00C Know all Men by these Presents That I, Ronny R. Anderson, Sheriff of the County of Cumberland, In the State of Pennsylvania, for and in consideration of the sum of $ 1.00 (One Dollar) to me in hand paid, do hereby grant and convey to U.S. Bank, N.A., as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass -Through Certificates, Series 2007 - TCI 2012-728 Civil Term U.S. Bank, N.A., as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass -Through Certificates, Series 2007 - TCI Vs Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right Title or Interest From or Under Patricia M. Sobotor, Deceased Michael P. Sobotor Patricia M. Sobotor, Deceased ALL that certain piece or, parcel of land, situate, lying and being in Dickinson Township, Cumberland County, Pennsylvania, bounded and described in accordance with a certain Final Subdivision Plan for Holly Estates prepared by Thomas and Associates, Surveyors, dated November 29, 1977, consisting of 1 page, a copy of which is recorded in Cumberland County Plan Book 33, page 136 on September 20, 1978, and incorporated herein by reference as follows; BEGINNING at a point on the Westwardly line of Holly Estates drive (50 feet wide right of way) at the southeast comer of Lot No. 10 on a certain Subdivision for Richard 13. Anderson recorded in Plan Book28, page 135; thence by the Westwardly line of the said Holly Estate Drive, South 17 degrees 29 minutes 28 seconds West 150 feet to a point being the northeast corner of Lot NO.8 on Plan of Holly Estates; thence by Lot No. 8 North 72 degrees 30 minutes 32 seconds West 299.14 feet to a point on line of lands now or formerly of John Delp; thence by lands of Delp, North 17 degrees 10 minutes 56 seconds East 149.15 feet to a point being the southwest comer of Lot No, 9 on Subdivision for Richard E. Anderson; thence by Lot No.9 and Lot No. 10 on Subdivision for Richard E. Anderson, South 72 degrees 40 minutes 32 seconds East 299.94 feet to a point, the place of beginning. Containing 1.0256 acres, more or less. BEING all of Lot NO.7 on Plan of Holly Estates, and known and numbered as 19 Holly Estates Drive, Gardners, PA 17324. BEING KNOWN AS: 19 Holly Estates Drive, Gardners, PA 17324 PROPERTY ID NO.: 08-16-0210-094 TITLE TO SAID'PREMISES IS VESTED IN Patricia M.Sobotor and Michael P. Sobotor, husband and wife BY DEED FROM Patricia M.Knudson, now by marriage known as Patricia M Sobotor DATED 09/08/1999 RECORDED 09/14/1999 IN DEED BOOK 207 PAGE 735. IA tof 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U.S. BANK, N.A., AS TRUSTEE FOR THE REGISTERED HOLDERS OF STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007 -TCI VS. No. 14-5985 Civil Teliii_ MICHAEL SOBOTOR AND/OR TENANT/OCCUPANT Costs. Attorney's $ $217.18 Plaintiff's Prothonotary $ 2.25 DUE CO COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff (s)) U.S. BANK, N.A., AS TRUSTEE FOR THE REGISTERED HOLDERS OF STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-TC1 being: (Premises as follows): **SEE LEGAL DESCRIPTION** (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defendant (s) and sell his/her (or their) interest therein. Date 11/18/2014 (Seal) David D. Buell, Prothonotary, Common Pleas Court of Cumberland County 2 of 2 No 14-5985 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U. S. BANK, N.A., AS TRUSTEE FOR THE REGISTERED HOLDERS OF STRUCTURED ASSET SECURITIES CORPORATION, SERIES 2007 -TC 1 vs. MICHAEL SOBOTOR AND/OR TENANT/OCCUPANT WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ $217.18 Plff (s)$ Prothy $ 2.25 Sheriff Plaintiff (s) attorney name and address: NICOLE LABLETTA, ESQUIRE UDREN LAW OFFICES, P.C. 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 By virtue of this writ, on the Attorney for Plaintiff (s) Where papers may be served day of . I caused the within named , to have possession of the premises described with the appurtenances, and Sworn and subscribed to before me this Day of So Answers, Sheriff By Prothonotary Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff - 1 HE PROTI-IONOr dlildnn,r Jody S Smith Chief Deputy Richard W Stewart Solicitor OFFICE OF ME bwI<;RIFF 2F! DEC -2 Pi 3: I3 CUMBERLAND COUNTY PENNSYLVANIA U.S. Bank, NA vs. Michael P Sobotor (et al.) Case Number 2014-5985 SHERIFF'S RETURN OF SERVICE 11/26/2014 08:30 PM - Deputy Christopher Sharpe, being duly sworn according to law, served the requested Writ of Possession by "personally" handing a true and attested copy to a person representing themselves to be the Defendant, to wit: Michael P Sobotor at 19 Holly Estates Drive, Dickinson Twp., Gardners, PA 17324, Cumberland County, and informed Defendant of contents of same. RISTOP, ' R SHARPE, DEPUTY SHERIFF COST: $52.68 SO ANSWERS, December 01, 2014 RONNS' R ANDERSON, SHERIFF (c) CountySuito Sharif,, Te!eosott, Inc. a Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY �tvrx%1, of LiIBfltte l OFFICE • rFrE c>F+ERIFF "'I': �► ,i1,2,1 12 I U v: OTI1EIE_RLI-', CCU: --1. ,S. PEN SYLV NI! U.S. Bank, NA vs. Case Number Michael P Sobotor (et al.) 2014-5985 SHERIFF'S RETURN OF SERVICE 11/26/2014 08:30 PM - Deputy Christopher Sharpe, being duly sworn according to law, served the requested Writ of Possession by "personally" handing a true and attested copy to a person representing themselves to be the Defendant, to wit: Michael P Sobotor at 19 Holly Estates Drive, Dickinson Twp., Gardners, PA 17324, Cumberland County, and informed Defendant of contents of same. 01/05/2015 By virtue of this writ, Sheriff Ronny R. Anderson caused the within named Plaintiff to have possession of the premises described as 19 Holly Estates Drive, Gardners, PA 17324. SHERIFF COST: $97.73 SO ANSWERS, January 08, 2015 RONNY R ANDERSON, SHERIFF 99373 0-1:3/5"&;"1 (c) CountySuite Sheriff, Te!eosoft, Inc. lof 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA, U.S. BANK, N.A., AS TRUSTEE FOR THE REGISTERED HOLDERS OF STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-TC1 VS. No. 14-5985 Civil Term MICHAEL SOBOTOR AND/OR TENANT/OCCUPANT Costs Attorney's $ $217.18 Plaintiff's $ . Prothonotary $ 2.25 DUE CO COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff (s)) U.S. BANK, N.A., AS TRUSTEE FOR THE REGISTERED HOLDERS OF STRUCTURED ASSET SECURITIES CORPORATION MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-TC1 being: (Premises as follows): **SEE LEGAL DESCRIPTION** (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defendant (s) and sell his/her (or their) interest therein. David D. Buell, Prothonotary, Common Pleas Court of Cumberland County PA Date 11/18/2014 Seal w;m5TE COPY -«OM RECORD Ir. Teatir,:o yyi%herecf, 1 here unto set my hand Court at Carlisle. Pa. a�,;�� '",e seal o said . In15 day of — s AsA—_:.L.O Prothonotary 2 of 2 No 14-5985 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA U. S. BANK, N.A., AS TRUSTEE FOR THE REGISTERED HOLDERS OF STRUCTURED ASSET SECURITIES CORPORATION, SERIES 2007 -TC 1 VS. MICHAEL SOBOTOR AND/OR TENANT/OCCUPANT WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ $217.18 Plff (s). . $ Prothy $ 2.25 Sheriff $ Plaintiff (s) attorney name and address: NICOLE LABLETTA, ESQUIRE UDREN LAW OFFICES, P.C. 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 Attorney for Plaintiff (s) Where papers may be served By virtue of this writ, on the day of . I caused the within named , to have possession of the premises described with the appurtenances, and Sworn and subscribed to before me this Day of So Answers, Sheriff By Prothonotary Deputy Tax Parcel No 08-16-0210-094 Know all Men by these Presents 11 11 OOGOOC That I, Ronny R. Anderson, Sheriff of the County of Cumberland, In the State of Pennsylvania, for and in consideration of the sum of $ 1.00 (One Dollar) to me in hand paid, do hereby grant and convey to U.S. Bank, N.A., as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass -Through Certificates, Series 2007- TC1 2012-728 Civil Term U.S. Bank, N.A., as Trustee for the Registered Holders of Structured Asset Securities Corporation Mortgage Pass -Through Certificates, Series 2007- TC1 Vs Unknown Heirs, Successors, Assigns and All. Persons, Firms or Associations Claiming Right Title or Interest From or Under Patricia M. Sobotor, Deceased Michael P. Sobotor Patricia M. Sobotor, Deceased ALL that certain piece or, parcel of land, situate, lying and being in Dickinson Township, Cumberland County, Pennsylvania, bounded and described in accordance with a certain Final Subdivision Plan for Holly Estates prepared by Thomas and Associates, Surveyors, dated November 29, 1977, consisting of 1 page, a copy of which is recorded in Cumberland County Plan Book 33, page 136 on September 20, 1978, and incorporated herein by reference as follows; BEGINNING at a point on the Westwardly line of Holly Estates drive (50 feet wide right of way) at the southeast corner of Lot No. 10 on a certain Subdivision for Richard B. Anderson recorded in Plan Book28, page 135; thence by the Westwardly line of the said Holly Estate Drive, South 17 degrees 29 minutes 28 seconds West 150 feet to a point being the northeast corner of Lot NO.8 on Plan of Holly Estates; thence by Lot No. 8 North 72 degrees 30 minutes 32 seconds West 299.14 feet to a point on line of lands now or formerly of John Delp; thence by lands of Delp, North 17 degrees 10 minutes 56 seconds East 149.15 feet to a point being the southwest corner of Lot No, 9 on Subdivision for Richard E. Anderson; thence by Lot No.9 and Lot No. 10 on Subdivision for Richard E. Anderson, South 72 degrees 40 minutes 32 seconds East 299.94 feet to a point, the place of beginning. Containing 1.0256 acres, more or less. BEING all of Lot NO.7 on Plan of Holly Estates, and known and numbered as 19 Holly Estates Drive, Gardners, PA 17324. BEING KNOWN AS: 19 Holly Estates Drive, Gardners, PA 17324 PROPERTY ID NO.: 08-16-0210-094 TITLE TO SAID'PREMISES IS VESTED IN Patricia M.Sobotor and Michael P. Sobotor, husband and wife BY DEED FROM Patricia M.Knudson, now by marriage known as Patricia M Sobotor DATED 09/08/1999 RECORDED 09/14/1999 IN DEED BOOK 207 PAGE 735. io