HomeMy WebLinkAbout06-1084
G01,DBECK McCAFFERTY & McKEEVER
.
By: JOSEPH A. GOLDBECK, JR.
'ATTORNEY I.D. #16132
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
(215) 825-6318
WWW.GOLDBECKLAW.COM
ATTORNEY FOR PLAINTIFF
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE FOR LONG BEACH MORTGAGE LOAN
TRUST 2004-4
9451 Corbin Avenue
Northridge, CA 91324
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
Plaintiff
vs.
ACTION OF MORTGAGE FORECLOSURE
BRENDA A. BOWES
MICHAEL L. BOWES
Mortgagors and Real Owners
166 Oakville Road
Shippensburg, P A 17257
Defendants
Tenn. ^ OLl /) ./
No. ole, -fU17 CIa.\",
CIVIL ACTION: MORTGAGE
~~P.:CLOOU~F ~'-~
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, PAl 70 I 3
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty A venue
Carlisle, PA 17013
A VISO
LE HAN DEMANDADO A USTED EN LA CORTE. SI DE SEA DEFENDERSE CONTRA LAS
QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO
DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARADEFENDERSE ES
NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRIT A, EL
PUNTO DE VISTA DE USTED Y CUALQUlER OBJECCION CONTRA LAS QUEJAS EN EST A
DEMANDA.
. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL
.
PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A
. FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES
DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER
DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES.
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, P A 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
THIS 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.
Resources available for Homeowners in Foreclosure
ACT NOW!
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.
1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-
9400 or .
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes.
4). Call the Plaintiff (your lender) at 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 Beth at 215-825-6329 or fax 215-825-6429. 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 David
Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of
WM-0683.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
This Action of Mortgage Foreclosure will continue unless you take action to stop it.
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG
BEACH MORTGAGE LOAN TRUST 2004-4,9451 Corbin Avenue, Northridge, CA 91324.
2. The names and addresses of the Defendants are BRENDA A. BOWES, 166 Oakville Road,
Shippensburg, P A 17257 and MICHAEL L. BOWES, 166 Oakville Road, Shippensburg, P A 17257,
who are the mortgagors and real owners of the mortgaged premises hereinafter described.
3. On July 21, 2004 mortgagors made, executed and delivered a mortgage upon the Property hereinafter
described to LONG BEACH MORTGAGE COMPANY, which mortgage is recorded in the Office of
the Recorder of Deeds of Cumberland County as Book 1874, Page 2634. The mortgage has been
assigned to: DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG
BEACH MORTGAGE LOAN TRUST 2004-4 by assignment of Mortgage dated January 31, 2006 as
Book 724, Page 2387. The Mortgage and assignment(s) are matters of public record and are
incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 10] 9(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" ("Property").
5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid
for August 01,2005 and each month thereafter and by the terms the Mortgage, upon default in such
payments for a period of one month or more, the entire principal balance and all interest due and other
charges are due and collectible. '
6. The following amounts are due to Plaintiff on the Mortgage:
Principal Balance
Interest from 07/01/2005
through 02/28/2006 at 6.4000%
Per Diem interest rate at $16.66
Reasonable Attorney's Fee at 5% of Principal Balance as
more fully explained in the next numbered paragraph
Late Charges from 08/01/2005 to 02/28/2006
Monthly late charge amount at $36.03
Costs of suit and Title Search
Fees
Escrow Balance
$95,000.23
$4,048.38
$4,750.01
$288.24
$900.00
$101.50
-$] ,664.00
$103,424.36
7. If the Mortgage is reinstated prior to a Sheriffs Sale, the Attorney's Fees set forth above may be less
than the amount demanded based on work actually performed. The Attorney's Fees requested are in
conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up
to 5% ofthe remaining principal balance in the event the Property is sold to a third party purchaser at
Sheriffs Sale or if the complexity of the action requires additional fees in excess of the amount
demanded in the Action.
8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the
Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such
right exists. If Defendants have 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.
9. Notice of Intention to Foreclose and aN otice of Homeowners' Emergency Mortgage Assistance has
been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the
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 Defendants have 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 Defendants
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$103,424.36,
together with interest at the rate of $16.66, per day and other expenses, costs and charges incurred by the
Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law
until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff s Sale of the Property.
By:
(' !1 // .1.1/' I
J{-'l h ~ cUJL-
GOLDl{EcIl McCAFFERTY & McKEEVER
By: JO~EPH '. GOLDBECK, JR., ESQUIRE
ATTORNEY FOR PLAINTlFF
'LER1EI CATIOt;r
J, .In'"CTll Ie. e'Jldjy"ck Jl., ac: the representative of the Plaintiff
corporat ion vn tlli n named do hereby verify that I am duthorized to and do
make this veritlcation 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, intormation and belief. I understand that false statements
therein an' made subject to the penalties of 18 Pa. C. S. 4904 relating to
unsworn falsification to authorities.
Date: 7 ~2 2 ~c l
. ~-)'~>J /l'.. LJ7 cl (JCC~
"-~~l-'~fL.L a.'..Li~_!L'____
I-
P,~lii6it }l
. .
. .
.
.
SCHEDULE A
ALL that certain lI11ct of land situate in North Newton Township; County of Cumberland and State of
Pennsylvania, bounded and descnbed in accordance with a Subdivision Plan for Ronald an Alice Negley,
recorded in the Office of the Recorder of Deeds for Cumberland County, Pennsylvania, in Plan Book 32, Page
7, as follows:
BEGINNING at a railroad spike in the centerline of Legislative Route 21007 at comer of other land now or
formerly of Ronald P. and Alice K. Negley; thence by land now or formerly of Ronald P. and Alice K.
Negley, South 51 degrees ]5 minutes West 175 feet to an iron pin; thence by the same, North 38 degrees45n
minutes Wesl 200 feel to an iron pin; thence North 51 degrees 15 minutes East 175 feel to a railroad spike in
the center of legislative Route 21007 aforesaid; thence by the centerline of Legislative Route 21007, South 38
degrees 45 minutes East 200 fectto a railroad spike, the place ofBEGINNlNG.
BEING Lot No.4 of the aforesaid Subdivision Plan. CONTAINING 35,000.00 square feet.
BEING the same real estate that Ronald P. Negley and Alice K. Negley, husband and wife, by Deed dated
October 18, 2002 which Deed is recorded in the Office of the Recorder of Deeds in and for Cumberland
County. Pennsylvania Deed Book 254,page 1446, granted and conveyed unto ScOIl A. Bodine and Caren L.
Bodine, husband and wife.
P,~hi6it (j3
HOMEOWNER'S NAME(S):
Michael L. Bowes
PROPERTY ADDRESS:
166 Oak.iIIe Rd
Shippen'burg PA 17257
0665700076
Lbm
Washington Mutual Bank
LOAN ACCT. NUMBER:
ORIGINAL LENDER:
CURRENT LENDER/SERVICER:
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOlJR HOME
FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS.
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF
1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
o IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL.
o IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND
. IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE
AGENCY.
TF.MPORARY STAY OF F'ORRC.LOSITRF. - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty
(30) days from the date of this Notice. During that time you must arrange and attend a "face-to-facell meeting with one of the consumer
credit counseling agencies listed at the end of this Notice. THIS MEETING MIIST nrCUR WITHIN THE NEXT 13m DAYS IF YOI} DO
NOT APPLY FOR FMFRGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGF lIP TO DATE THE PART
OF TH1S NOTlr.F CALl ED "HOW TO ClJRP YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE
UP TO DATE
r.ONSIIMER CREDIT COUNSELING AGRNnRS - If you meet with one of the consumer credit counseling agencies listed at the end of
this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresse!'l and
telenhone numhers of desivnated con"llmer aedit cOlln"elinp ;Il:!"encies for the county in which the nrnpertv i" located are set forth at the
end of this Notice It is only necessary to schedule one face-to~face meeting. Advise your lender immediately of your intentions.
APPUr.ATION FOR MnRTGAGF. ASSlSTANr.F ~ Your mortgage is in default for the reasons set forth later in this Notice (see following
pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender,
you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must
fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit
counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program, and they
will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or
postmarked within thirty (30) days of your face-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME
PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY, AND YOUR
APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
AGENCY Ar.TION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the
eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives
your application. During that time, no foreclosure proceedings will be pursued against you, if you have met the time requirements set
forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application.
NOTE, IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE
FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE
CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.)
oooe04!SP999
HOW TO CURE YOUR MORTGAGE DEFAULT (Brine it uo to date),
NAT1JRE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at:
166 Oakville Rd
Shippensburg PA 17257
IS SERIOUSLY IN DEFAULT BECAUSE,
Non-payment
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now
past due:
Monthly Installments:
D8J0 112005
09/01/2005
10/01/2005
$600.49
$600.49
$600.49
Other charges (explain/itemize):
Uncollected Late Charges
Uncollected Fees;
Corporate advances
Less Credits
TOTAL AMOUNT PAST DUE,
$216.18
$35,60
$0.00
$0.00
$2053.25
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Not applicable):
HOW TO ClJRR THE DF.FAllLT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE
TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2053.25. PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES
WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made elther ny c~sh c~snier's cher:k certified
check or monev order m~de payable and sent to'
Washington Mutual Bank
9451 Corbin Avenue
Northridge, CA 91324
You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter; (Not applicable);
IF YOlT DO NOT r.IfRF. THF. DF.FAITI,T - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the IeTtder
intends to exercise its: riVhtl'l to accele\"ate the morl~3~" debt This means that the entire outstanding balance of this debt will be considered
due immediately, and you may lose the the chance to pay the mortgage in monthly installments. If full payment of the total amount past
due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to forprlo!lp "pon von\"
rnort~aved nroDerty
*IF THF. MORTGAr..F. TS FORF.C-LOSED UPON The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the
lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be
required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you,
you will have to pay all reasonable attonery's fees actually incurred by the lender even if they exceed $.50.00. Any attorney's fees will be
added to the amount you owe the lender, which may also include other reasonable costs. Tfyou ellre thp. default within the THIRTY 13m
DAY Deriod. YOU will not he renuirpd to nay attorney's fees.
OTHF.R LF.NDF.R RF.MF.DIKC\ - The lender may also sue you personally for the upaid principal balance and all other sums due under the
mortgage.
SPY99
Rlr..HT TO ClTRE THR DRFAIIl,T PRIOR TO SHRRTFF'S SALE- If you have not cured the default within the THIRTY (30) DAY period
and foreclosure proceeding::; have begun. rOll may still h;Jve the rif':"t to cure the aefault and nrevent the sale at any time un to one hour
before the Sheriffs Sale You mav do..o by ~ini the total amount then pa.'it due n1lls any late or other charlie!'; thp.n dne rea'innahle
attorney's fee!'; and costs connectp.d with the foreclosure !';ale and any other CO'i."! r.onnp.cted wtth the Sheriff's Sale a... '1J)eclfied 10 writ1nl! by
the lendp.r and bv performinl' any other reQuirements under the mnrtl'ap-e Curing your default in the manner' set forth in this notice will
restore your mortgage to the same position as if you had never defaulted.
RARLTRST POSSJRLF: SHRRTFF'S SALE DATR ~ It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property
could be held would be approximately 9 months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be
sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any
time exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER'
Name of Lender:
Address:
Washington Mutual Bank
9451 Corbin Avenue
Northridge, CA 91324
1-888-852-1745
1-818-775-6260
Collection Department
www.wamuhmneloalls.cmn
Phone Number:
Fax Number:
Contact Person:
Email Address:
RFFRCTS OF SHERIFF'S SALF.: ~ You should realize that a Sherifrs Sale will end your ownership of the mortgaged property and your
right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other
belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE - You _ mayor' X may not sell or transfer your home to a buyer or transferee who will assume the
mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale, and that
the other requirements of the mortgage are satisfied.
YOIl MAY ALSO HAVE THE RIGHT:
. TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM
ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
TO HAVE THE DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED. IF YOU CURE
THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES
IN ANY CALENDAR YEAR.)
TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT
INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
TO ASSERT ANY OTHER DEFENSE YOU BELlEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER.
TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED
We may report information about your account to credit bureaus. Late payments, missed payments or other defaults on your
account may be reflected in yoUl' credit report.
SP999
ACT 91 NOTICE
DATE OF NOTICE: January 19, 2006
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
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.
This is an official notice that the mortgage on your home is in default. and the
lender intends to foreclose. Specific information about the nature of the default is provided in
the attached pages.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be
able to help to save your home. This Notice explains how the program works.
To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT
COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this
Notice with you when vou meet with the Counseling Agency.
The name. address and phone number of Consumer Credit Counseling Agencies serving
your County are listed at the end of this Notice. If you have any questions. yOU may call the
Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired
hearing can call (717) 780-1869.)
This Notice contains important legal information. If you have any questions,
representatives at the Consumer Credit Counseling Agency may be able to help explain it.
You may also want to contact any attorney in your area. The local bar association may be able
to help you find a lawyer.
La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar
viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion
immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al
numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado
"Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la
perdida del derecho a redimir su hipoteca.
Prepared by: GOLDBECK McCAFFERTY & McKEEVER
Suite 5000 - Mellon Independence Center.
701 Market Street
Philadelphia, PA 19106
Fax (215) 627-7734
1
Date: January 19,2006
TO: BRENDA A. BOWES
Homeowners Name: BRENDA A. BOWES and MICHAEL L. BOWES
Property Address: 166 Oakville Road, Shippensburg, P A 17257
Loan Account No.: 0665700076
Original Lender: LONG BEACH MORTGAGE COMPANY
Current LenderlServicer: WASHINGTON MUTUAL
HOMEOWNERS'
EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL
ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE
MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S
EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE
ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
* IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
* IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
* IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date ofthis Notice. During that time you
must arrange and attend a "face-to-face" meeting with one of the designated consumer credit
counseling agencies listed at the end of this Notice.
THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT
APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE
YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO
DATE.
CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one ofthe consumer
credit counseling agencies listed at the end of this notice, the lender may NOT take action against you
for thirty (30) days after the date of this meeting. The names. addresses and telephone numbers of
designated consumer credit counseling agencies for the county in which the property is located are set
2
forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your
lender immediatelv of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the
reasons set forth later in this Notice (see following pages for specific information about the nature of
your default.) If you have tried and are unable to resolve this problem with the lender, you have the
right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance
Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance
Program Application with one ofthe designated consumer credit counseling agencies listed at the end
of this Notice. Only consumer credit counseling agencies have applications for the program and they
will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency.
Your application MUST be filed or postmarked within thirty (30) days of your fact-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR
IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER,
FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR
APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
AGENCY ACTION - Available funds for emergency mortgage assistance are very limited.
They will be disbursed by the Agency under the eligibility criteria established by the Act. The
Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your
application. During that time, no foreclosure proceedings will be pursued against you if you have met
the time requirements set forth above. You will be notified directly by the Pennsylvania Housing
Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION
IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR
INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN
ATTEMPT TO COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for
Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Brio!! it un to date).
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property
located at: 166 Oakville Road, Shippeosburg, PA 17257 IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months
and the following amounts are now past due:
3
(a) Monthly payment from 08/01/2005 thru 1/19/2006
(6 mos. at $600.49/month) $3.602.94
(b) Late charges from 08/01/2005 thru 1/19/2006
(6 mos. at $36.03/month) $216.18
(c) Other charges; Escrow, Inspec., NSF Checks
(d) Other provisions ofthe mortgage obligation, if any
(e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $3,819.12
HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS ofthe
date ofthis notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH
IS $3,819.12, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME
DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check,
certified check or money order made payable and sent to:
WASHINGTON MUTUAL
9451 Corbin Avenue
Northridge, CA 91324
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default
within THIRTY (30) DAYS ofthe date ofthis Notice, the lender intends to exercise its ril!hts to
accelerate the mortl!al!e debt. This means that the entire outstanding balance ofthis debt will be
considered due immediately and you may lose the chance to pay the mortgage in monthly installments.
If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also
intends to instruct its attorneys to start legal action to foreclose upon vour mortl!al!ed property.
IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the
Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the
delinquency before the lender brings legal proceedings against you, you wiII stiII be required to pay the
reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are
started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender
even ifthey exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which
may also include other reasonable costs. If vou cure the default within the THIRTY (30) DAY
period, vou will not be required to pav attornev's fees.
OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the
default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have
the right to cure the default and prevent the sale at any time UP to one hour before the Sheriff's Sale.
You may do so by paving the total amount then past due. plus any late or other charges then due.
reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected
with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements
4
under the mortgage. Curing your default in the manner set forth in this notice will restore your
mortgage to the same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a
Sheriff's Sale of the mortgaged property could be held would be approximately four (4) to six (6)
months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to
you before the sale. Of course, the amount needed to cure the default will increase the longer you wait.
You may find out at any time exactly what the required payment or action will by contacting the
lender.
HOW TO CONTACT THE LENDER:
Name of Lender:
WASHINGTON MUTUAL
Address:
9451 Corbin Avenue
Northridge, CA 91324
Phone Number:
818-775-6225
Fax Number:
818-775-2869
Contact Person:
Shirley Goei
EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of
the mortgaged property and your right to occupy it. If you continue to live in the property after the
Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by
the lender at any time.
ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who
will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees
and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
* TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE
DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF
THIS DEBT.
* TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
* TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO
DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT
HA VE THIS RIGHT TO CURE YOUR DEF AUL T MORE THAN THREE TIMES IN ANY
CALENDAR YEAR.)
5
.
* TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
* TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH
ACTION BY THE LENDER.
* TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
Contact Person: Shirley Goei
Phone Number: 818-775-6225
6
.
PENNSYLVANIA HOUSING FINANCE AGENCY
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
CONSUMER CREDIT COUNSELING AGENCIES
CUMBERLAND COUNTY
CCCS OF WESTERN PENNSYLVANIA INC
2000 Linglestown Road
Harrisburg, P A 171 02
(717) 541-1757
URBAN LEAGUE OF METROPOLITAN HARRISBURG
21 07 N. 6th Street
Harrisburg, PA 17101
(717) 234-5925
FAX (717) 234-9459
COMMUNITY ACTION COMM OF THE CAPITAL REGION
1514 Derry Street
Harrisburg, PA 17104
(717) 232-9757
FAX 234- 2227
FINANCIAL COUNSELING SERVICES OF FRANKLIN
3 I West 3rd Street
Waynesboro, PA \7268
(717) 762-3285
YWCA OF CARLISLE
30 \ G Street
Carlisle, PA 17013
(717) 243-3818
FAX (717) 731-9589
ADAMS COUNTY HOUSING AUTHORITY
139-143 Carlisle Street
Gettysburg, P A 17325
(717) 334-1518
FAX (717) 334-8326
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GOLDBECK McCAFFERTY & McKEEVER
JOSEPH A. GOLDBECK, JR.
Attorney I.D.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
BY: David B. Fein, Esq.
Attorney I.D.#82628
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR LONG BEACH MORTGAGE
LOAN TRUST 2004-4
945 I Corbin A venue
Northridge, CA 91324
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
vs.
BRENDA A. BOWES and MICHAEL L. BOWES
166 Oakville Road
Shippensburg, P A 17257
No. 06-1084
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.
MOTION FOR SUBSTITUTED SERVICE
UNDER P A.R.C.P. 430(a)
Plaintiff, by and through its attorney, David B. Fein. Esq., in support of its Motion for
Substituted Service, represents as follows:
1. Plaintiff is the holder of a first mortgage upon the premises 166 Oakville Road,
Shippensburg, PA, 17257, hereinafter, the "mortgaged premises".
2. Defendants, BRENDA A. BOWES and MICHAEL L. BOWES, are the mortgagors and
real owners of the mortgaged premises.
3. The last known address of Defendants is as set forth in Paragraph 2 of the Complaint.
4. The Sheriff has been unable to effect service of the Complaint upon Defendants at his
property address, 166 Oakville Road, Shippensburg, PA, 17257, after numerous attempts. The property is
vacant. The Defendant's new address is P.O. Box 1573, Mango, FL 33550, per Sheriff. Certified Mail
was sent to P.O. Box 1573, Mango, FL 33550 and as of April 10, 2006 it has yet to be claimed, per
Postmaster.
5. The following investigation was conducted in a good faith attempt to ascertain the
whereabouts of Defendants.
WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff
to serve the Complaint upon Defendants by posting the premises and certified and regular mail to the
Defendants' last known address.
1J?:Jr-
BY: David B. Fein, Esq.
Ccc'G'iiC~!0>
UNI.' ERSAL
,; - ."'A1'~ SERVICES
'-~. .
Ar
,.,
Affidavit of Good Faith Investiqation
Client provided information:
File Number: WM-0683
Attorney Firm: Goldbeck, McCafferty & McKeever
File Name: Bowes
Subjec1 Name: Michaellc Bowes
Property Address:
Street: 1 66 Oakville Road
City: Shippensburg State: PA
Zip:
17257
Skip Results:
lost Known
Street: 1 66 Oakville Road
City: Shippensburg State: PA
Death Records: As of 03/27/2006.
Michaell. Bowes.
Social Security Number search completed.
Employment Search: Unable to verify current employer.
Creditor information:
Creditors indicated the last reported address for Michaell. Bowes as 166 Oakville Road, Shippensburg,
PA 17257
Deportment of Motor Vehicle Records:
The Pennsylvania Department of Motor Vehicles provided no change for Michaell, Bowes
from 166 Oakville Road. Shippensburg, PA 17257
Public licenses (Pilot, Real Estate, etc): Search performed provided no information.
Voter Registration Information:
The County Voters Registration Office has no listing for Michaei l. Bowes.
Notional Postal Address Search: Has no change for Michaell. Bowes from 166 Oakville Road.
Shippensburg, PA 17257
Comments:
717-240-0197: Called possible relative, Scott Bowes. left message on answering machine, no response.
717-486-7853: Called possible neighbor, Stephen Hair. left message on answering machine. no
resp~nse.
717-776-4468: Called possible neighbor. Jerome Negley. answering machine answered. no message
left.
Date of Birth: 06/26/1970 Universal File Number: 47810
Dates: As of 03/27/2006
Phone:
lip: ] 7257
the Social Security Administration has no death record on file for
On 03/27/2006. I. Patti Garrett being duly sworn according to the law. deposes and says:
I am employed by Universal Default Service. I have conducted an investigation into the whereabouts
of the above named subject. Above are the results of my investigation.
/ /-".'--'-'.~:)".;5;-"). -rr- ';Ub.'.Cftt)e(.1 {)rKl ",,,in to b"lo'e nTe,
\. ..' \~__. ' oh-o~.
-~;N~rnij'LpOlliG;;;;:;;ii-' . N;;;<;;;~~--"""'~:-:! 'ff?
Date: 03/27/2006
j;::;;:;;:'~I_. KIM ATTEBERY ~
I. *~~ ",
~&,,;Jl S~~~:;~~As f
"\.,,!,,~!,,-,,, eon,m'-ltOn ~p 09.12'-:xJCtl ,
~
329 OAKS TRAIL PlAZA . SUITE 202 . GARlAND, TEXAS 75043
OffICE: {c}72) 2'26-8883 . FAX: (972) 226-8887
(y.,,"I!t!l<;':C"
'. UNI" ERSAL
;:.E!'A~:" SERVICES
~~e'.
Affidavit of Good Faith Investiqation
Client provided Information:
File Number: WM-0683
Attorney Firm: Goldbeck. McCafferty & McKeever
File Name: Bowes
Subject Name: Brenda A. Bowes
Property Address:
Street: 166 Oakville Road
City: Shippensburg State: PA
Zip:
17257
Skip Results:
Last Known
Street: 1 66 Oakville Road
City: Shippensburg State: PA
Death Records: As of 03/27/2006.
Brenda A. Bowes.
Social Security Number search completed.
Employment Search: Unable to verity current employer.
Creditor information:
Creditors indicated the last reported address for Brenda A. Bowes as 166 Oakville Road, Shippensburg.
PA 17257
Departmenf of Mofor Vehicle Records:
The Pennsylvania Department of Motor Vehicles provided no change for Brenda A. Bowes
from 166 Oakville Road. Shippensburg, PA 17257
Public Licenses (Pilot, Real Estate, efc): Search performed provided no information.
Voter Registration Information:
The County Voters Registration Office has no listing for Brenda A. Bowes.
National Posfal Address Search: Has no change for Brenda A. Bowes from 166 Oakville Road.
Shippensburg. PA 17257
Comments:
717-240"()197: Called possible relative, Scott Bowes. left message on answering machine, no response.
717-486-7853: Called possible neighbor. Stephen Hair. left message on answering machine. no
response.
717-776-4468: Called possible neighbor. Jerome Negley. answering machine answered, no message
left.
Date of Birth:
None Found Universal File Number: 47810
Dates: As of 03/27/2006
Phone:
Zip: 17257
fhe Social Security Administration has no death record on file for
On 03/2712006. I. Patti Garrett being duly sworn according to the law, deposes and says:
I am employed by Universal Default Service. I have conducted an investigation into the whereabouts
of the above named subject. Above are the results of my investigation.
" - ~ - ~ ":1 ----~~} ,.--t-f---- Suu<;< I't~)fjd/an{j s.w,;n tn befOl'e n)8
...~' J//~' ;Y:. oJ-.t-;'7~ ...-
":;'f,;rn<:'m<;1 PuttoGo;':~tl - - N;'!c~~ PL~~--"'""'~--:' ff
Date: 03/27/2006
~""""liitl;'.,. ;
f;'::':"'~'\', KIMATrEBERY !
;; * ~~ NOl.1ry PUbl.", "\
\~ '.;.f! STATf OF TEXAS t
.-- ,,,_~,"i""' Comm...ion E'J:p 09.12-2fl~9 ,
N~_._ ~_~~..._~~
329 OAKS TRAIL PlAZA . SUITE 202 . G MlAND, TEXAS 75043
OFfiCE: {972:) 226-8883 . FAX: (972) 226-8887
8HERIFF'S RETURN - NOT FOUND
~ASE NO: 2006-01084 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
BOWES BRENDA A ET AL
R. Thomas Kline
,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
BOWES MICHAEL L
but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
, NOT FOUND , as to
the within named DEFENDANT
, BOWES MICHAEL L
166 OAKVILLE ROAD
SHIPPENSBURG, PA 17257
166 OAKVILLE ROAD IS VACANT. DEFENDANT'S NEW
ADDRESS IS PO BOX 1573 MANGO, FL 33550.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00
.00
5.00
10.00
.00
21.00
/.~..-.-C~
So answer~.:::::7.. _~~::-."';';;~?:::::::;';'-
.....--____~G''-:..i:.~~~
- ~~/-"7~?> ..~.
?""".-~ ~:.> ~:::':::>-"'-
R. Thomas Kline
Sheriff of Cumberland County
GOLDBECK MCCAFFERTY MCKEEVER
03/07/2006
Sworn and subscribed to before me
this
day of
A.D.
Prothonotary
SHERIFF'S RETURN - NOT FOUND
~ASE NO: 2006-01084 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
BOWES BRENDA A ET AL
R. Thomas Kline
,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
BOWES BRENDA A
but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
, NOT FOUND , as to
the within named DEFENDANT
, BOWES BRENDA A
166 OAKVILLE ROAD
SHIPPENSBURG, PA 17257
166 OAKVILLE RD IS VACANT. DEFENDANT'S NEW
ADDRESS IS PO BOX 1573 MANGO, FL 33550.
Sheriff's Costs:
Docketing
Service
Not Found
Surcharge
18.00
17.60
5.00
10.00
.00
50.60
So ~s~'."./ /...........?. /~
.~/
>...e;-/....." ?-'''
R. Thomas Klle
Sheriff of Cumberland County
GOLDBECK MCCAFFERTY MCKEEVER
03/07/2006
Sworn and subscribed to before me
this
day of
A.D.
Prothonotary
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Label/Receipt Number: 70053110000200365467
Status: Notice Left
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We attempted to deiiver your item at 12:06 pm on March 30, 2006 in
RUSKIN, FL 33570 and a notice was left. It can be redelivered or picked
up at the Post Office. If the item is unclaimed, it will be returned to the
sender. Information, if available, is updated every evening. Please check
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4/1 012006
GOLDBECK McCAFFERTY & McKEEVER
JOSEPH A. GOLDBECK, JR.
Attorney LD.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
BY: David B. Fein, Esq.
Attorney I.D.#82628
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR LONG BEACH MORTGAGE
LOAN TRUST 2004-4
9451 Corbin Avenue
Northridge, CA 91324
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
vs.
No. 06-1084
BRENDA A. BOWES and MICHAEL L. BOWES
166 Oakville Road
Shippensburg, P A 17257
VERIFICATION
I, David B. Fein, Esq., Attorney for Petitioner do hereby verify that the facts set forth in the
foregoing Motion for Substituted Service 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.
il%
BY: David B. Fein, Esq.
GOLDBECK McCAFFERTY & McKEEVER
JOSEPH A. GOLDBECK, JR.
Attorney I.D.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, P A 19106-1532
215-627-1322
BY, David B. Fein, Esq.
Attorney I.D.#82628
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE FOR LONG BEACH MORTGAGE LOAN
TRUST 2004-4 IN THE COURT OF COMMON PLEAS
9451 Corbin A venue
Northridge, CA 91324" OF Cumberland COUNTY
vs.
BRENDA A. BOWES and MICHAEL L. BOWES
166 Oakville Road
Shippensburg, P A 17257
No. 06-1084
MEMORANDUM OF LAW IN SUPPORT OF MOTION
FOR SUBSTITUTED SERVICE UNDER Pa.R.C.P. 430(a)
Plaintiff has filed a Complaint in Mortgage Foreclosure against Defendants, which the
Sheriff has been unable to personally serve upon Defendants. As noted in the attached Motion, Plaintiff
has made a good faith attempt to ascertain Defendants' whereabouts without success. Accordingly, the
Court may approve alternative means of service. See Pa.R.C.P. 430(a).
CONCLUSION
For reasons stated above and in the attached Motion, the Court should enter an order
allowing Plaintiff to serve the Complaint in Mortgage Foreclosure upon Defendants by posting the
premises and certified mail and regular mail to the Defendants' last known address.
Respectfully submitted,
Jif
David B. Fein,~q.
. .
GOLDBECK McCAFFERTY & McKEEVER
JOSEPH A. GOLDBECK, JR.
Attorney 1.0.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
BY: David B. Fein, Esq.
Attorney 1.0.#82628
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR LONG BEACH
MORTGAGE LOAN TRUST 2004-4
9451 Corbin Avenue
Northridge, CA 91324
IN THE COURT OF COMMON PLEAS
Of Cumberland County
vs.
No. 06-1084
BRENDA A. BOWES
MICHAEL 1.. BOWES
166 Oakville Road
Shippensburg, P A 17257
CERTIFICATE OF SERVICE
David B. Fein, Esq., does hereby certify that true and correct copies of the foregoing Motion for
Substituted Service have been served upon the Defendants this 13th day of April 2006, by first class mail,
postage prepaid.
I/?F
BY: David B. Fein, Esq.
(
,
'..1 C.:,.,
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-
GOLDBECK McCAFFERTY & McKEEVER
JOSEPH A. GOLDBECK, JR.
Attorney I.D.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, P A 19106-1532
215-627-1322
BY: David B. Fein, Esq.
Attorney I.D.#82628
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR LONG BEACH MORTGAGE
LOAN TRUST 2004-4
9451 Corbin A venue
Northridge, CA 91324
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
vs.
BRENDA A. BOWES and MICHAEL L. BOWES
166 Oakville Road
Shippensburg, P A 17257
No. 06-1084
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.
MOTION FOR SUBSTITUTED SERVICE
UNDER PA.R.C.P. 430(a)
Plaintiff, by and through its attorney, David B. Fein, Esq., in support of its Motion for
Substituted Service, represents as follows:
1. Plaintiff is the holder of a first mortgage upon the premises 166 Oakville Road,
Shippensburg, PA, 17257, hereinafter, the "mortgaged premises".
2. Defendants, BRENDA A. BOWES and MICHAEL L. BOWES, are the mortgagors and
real owners of the mortgaged premises.
3. The last known address of Defendants is as set forth in Paragraph 2 of the Complaint.
4. The Sheriff has been unable to effect service of the Complaint upon Defendants at his
property address, 166 Oakville Road, Shippensburg, P A, 17257. after numerous attempts. The property is
vacant. The Defendant's new address is P.O. Box 1573, Mango, FL 33550, per Sheriff. Certified Mail
was sent to P.O. Box 1573. Mango, FL 33550 and as of April 10,2006 it has yet to be claimed, per
Postmaster.
5. The following investigation was conducted in a good faith attempt to ascertain the
whereabouts of Defendants.
WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff
to serve the Complaint upon Defendants by posting the premises and certified and regular mail to the
Defendants' last known address.
fJ2f
BY: David B. Fein, Esq.
( UN}ERSAL
'":~m SERVICES
.,..-.....--.//. .
...
--W'
Affidavit of Good Faith Investiqation
Client provided information:
File Number: WM-0683
Attorney Firm: Goldbeck. McCafferty & McKeever
File Name: Bowes
Subject Name: Michael L. Bowes
Property Address:
Street: 166 Oakville Road
City: Shippensburg State: PA
Zip:
17257
Skip Results:
last Known
Street: 166 Oakville Rood
City: Shippensburg State: PA
Death Records: As of 03/2712006,
Michael L. Bowes.
Social Security Number search completed.
Employment Search: Unable to verify current employer.
Creditor information:
Creditors indicated the last reported address for Michael L. Bowes as 166 Oakville Road, Shippensburg,
PA 17257
Department ot Motor Vehicle Records:
The Pennsylvania Deportment of Motor Vehicles provided no change for Michael L. Bowes
from 166 Oakville Road, Shippensburg. P A 17257
Public Licenses (PUot, Real Estate, etc): Search performed provided no information.
Voter Registration 'nformation:
The County Voters Registration Office has no listing for Michael L. Bowes.
National Postal Address Search: Has no change for Michael L. Bowes from 166 Oakville Road.
Shippensburg, PA 17257
Comments:
717-240-0197: Called possible relative. Scott Bowes. left message on answering machine. no response.
717-486-7853: Called possible neighbor. Stephen Hair. left message on answering machine. no
response.
717-776-4468: Called possible neighbor. Jerome Negley. answering machine answered. no message
left.
Date of Birth:
06/26/1970
Dates: As 01
Phone:
Zip: 17257
the Social Security Administration has no death record on file lor
Universal File Number: 47810
03/27/2006
On 03/27/2006, \, Palli Garrett being duly sworn according to the law, deposes and says:
I am employed by Universal Default Service. I have conducted an investigation into the whereabouts
of the above named subject. Above are the results of my investigati?n.
1/' ~. ---:,1"'-;[:;) , _ '''b''''''''''d.ond ,wom to bel<><e me.
',.=J:L...kitU.J.i1t.. ... .......... ..... ...L~.....J12b:::e<.~/
M1rn1 Name! Potti GmeH No,my Publ,c :-C-'if
Date: 03/2712006
~,~" ')
/;:;..'~~., KIM ATTEBERY
ll*':'-'(.~ '.' ~.
i. >*3 NotIry PubUe
\'+.;.~;;I'l STAn Of mAS i
""""",,,,,,,"" ~tlQn ttp f$.12-2CICi .
329 OAKS TRAIL PlAZA . SUITE 202 . GARlAND, TEXAS 75043
OFFICE: (972) 226-8883. FAX; (972) 226-8887
.(~UNI ERSAL
::: S,RVIC'S
~ ..
At
Affidavit of Goad Faith Investiaation
Client provided information:
File Number: WM-D683
Attorney Firm: Goldbeck. McCafferty & McKeever
File Name: Bowes
Subject Name: Brenda A. Bowes
Property Address:
Street: 166 Oakville Road
City: Shippensburg State: PA
Zip: 17257
Skip Results:
lost Known
Street: 166 Oakville Road
City: Shippensburg State: PA
Death Records: As of 03/27/XY06,
Brenda A. Bowes.
Social Security Number search complefed.
Employmenl Search: Unable to verify current employer.
Creditor information:
Creditors indicated the last reported address for Brenda A. Bowes as 166 Oakville Road. Shippensburg,
PA 17257
Departmenl of Motor Vehicle Records:
The Pennsylvania Department of Motor Vehicles provided no change for Brenda A. Bowes
from 166 Oakville Road. Shippensburg. P A 17257
Public licenses (Pilot, Real Estate. etc): Search performed provided no information.
Voter Registration Information:
The County Voters Registration Office has no listing for Brenda A. Bowes.
National Postal Address Search: Has no change for Brenda A. Bowes from 166 Oakville Road,
Shippensburg. PA 17257
Comments:
717-240-0197: Called possible relative. Scott Bowes. left message on answering machine. no response.
717-486-7853: Called possible neighbor. Stephen Hair. left message on answering machine. no
response.
717-776-4468: Called possible neighbor, Jerome Negley. answering machine answered. no message
left.
Date of Birth:
None Found Universal File Number: 47810
Dates: As of 03/27/2006
Phone:
Zip: 17257
the Social Security Administration has no death record on file for
On 03/2712006. I. Patti Garrett being duly swom according to the law. deposes and says:
I am employed by Universal Default Service. I have conducted an investigation into the whereabouts
of the above named subject. Above are the results of my investigation.
..............:::c.]52.. 1l SUb"',i\;>edandsw"i,.. 10 b",fl)H','ne
(' ,." / l _ ~ _ - ,. _ . _ - ,- - _ -
'..~"~...."./c.. ../ltc,U,..'_ ..... .......L~J.tztt::e/A~:' /
.~tf-, _ nT'Nurne( Patti GOlleft N01(if'{ PubHc ~-.'--'ff
,
Date: 03/27/2fJ06
..
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It. .(:"...,.,~...~~,,," eomm:.tfon&p f)9.12.2(la9 :
~- -, . ""- ~~.'
329 OAKS TRAIL PlAZA . SUITE 202 . GAAlAND, TEXAS 75043
OFACE : (972) 226-8883 . FAX: (972) 226-8887
SHERIFF'S RETURN - NOT FOUND
~ASE NO: 2006-01084 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
BOWES BRENDA A ET AL
R. Thomas Kline
,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
BOWES MICHAEL L
but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
, NOT FOUND , as to
the within named DEFENDANT
, BOWES MICHAEL L
166 OAKVILLE ROAD
SHIPPENSBURG, PA 17257
166 OAKVILLE ROAD IS VACANT. DEFENDANT'S NEW
ADDRESS IS PO BOX 1573 MANGO, FL 33550.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00
.00
5.00
10.00
.00
21.00
So a~s~~,~~~?~
-- ~~:.:;~~.~-----
R. Thomas Kline
Sheriff of Cumberland County
GOLDBECK MCCAFFERTY MCKEEVER
03/07/2006
Sworn and subscribed to before me
this
day of
A.D.
Prothonotary
SHERIFF'S RETURN - NOT FOUND
GASE NO: 2006-01084 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
BOWES BRENDA A ET AL
R. Thomas Kline
,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
BOWES BRENDA A
but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
, NOT FOUND , as to
the within named DEFENDANT
, BOWES BRENDA A
166 OAKVILLE ROAD
SHIPPENSBURG, PA 17257
166 OAKVILLE RD IS VACANT. DEFENDANT'S NEW
ADDRESS IS PO BOX 1573 MANGO, FL 33550.
Sheriff's Costs:
Docketing
Service
Not Found
Surcharge
18.00
17.60
5.00
10.00
.00
50.60
So answer.s.~' / /-~,::;.;;~
.__=:y/_<_cce'/ .'
,- ~~~/
R. Thomas Kle
Sheriff of Cumberland County
GOLDBECK MCCAFFERTY MCKEEVER
03/07/2006
Sworn and subscribed to before me
this
day of
A.D.
Prothonotary
USPS - Track & Confirm
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Label/Receipt Number: 7005 3110 0002 0036 5467
Status: Notice Left
track & Confirm
Enter Label/Receipt Number.
We attempted to deliver your item at 12:06 pm on March 30, 2006 in
RUSKIN, FL 33570 and a notice was left. It can be redelivered or picked
up at the Post Office. If the item is unclaimed, it will be returned to the
sender.. Inlormation, il available, is updated every evening. Please check
again later..
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Copyright'i';} 1999.2004 USPS. All Rights Reserved. Terms of Use Privacy Policy
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4/10/2006
GOLDBECK McCAFFERTY & McKEEVER
JOSEPH A. GOLDBECK, JR.
Attorney LD.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
BY: David B. Fein, Esq.
Attorney I.D.#82628
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR LONG BEACH MORTGAGE
LOAN TRUST 2004-4
9451 Corbin A venue
Northridge, CA 91324
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
vs.
No. 06-1084
BRENDA A. BOWES and MICHAEL L. BOWES
166 Oakville Road
Shippensburg, PA 17257
VERIFICATION
I, David B. Fein, Esq., Attorney for Petitioner do hereby verify that the facts set forth in the
foregoing Motion for Substituted Service 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.
BY: David B. Fein, Esq.
/J!;F
GOLDBECK McCAFFERTY & McKEEVER
JOSEPH A. GOLDBECK, JR.
Attorney I.D.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
BY: David B. Fein, Esq.
Attorney I.D.#82628
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE FOR LONG BEACH MORTGAGE LOAN
TRUST 2004-4 IN THE COURT OF COMMON PLEAS
9451 Corbin A venue
Northridge, CA 91324" OF Cumberland COUNTY
vs.
BRENDA A. BOWES and MICHAEL L. BOWES
166 Oakville Road
Shippensburg, P A 17257
No. 06-1084
MEMORANDUM OF LAW IN SUPPORT OF MOTION
FOR SUBSTITUTED SERVICE UNDER Pa.R.C.P. 430(a)
Plaintiff has filed a Complaint in Mortgage Foreclosure against Defendants, which the
Sheriff has been unable to personally serve upon Defendants. As noted in the attached Motion, Plaintiff
has made a good faith attempt to ascertain Defendants' whereabouts without success. Accordingly, the
Court may approve alternative means of service. See Pa.R.C.P. 430(a).
CONCLUSION
For reasons stated above and in the attached Motion, the Court should enter an order
allowing Plaintiff to serve the Complaint in Mortgage Foreclosure upon Defendants by posting the
premises and certified mail and regular mail to the Defendants' last known address.
Respectfully submitted,
/)Jff
David B. Fein, Esq.
GOLDBECK McCAFFERTY & McKEEVER
JOSEPH A. GOLDBECK, JR.
Attorney I.D.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
BY: David B. Fein, Esq.
Attorney I.D.#82628
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR LONG BEACH
MORTGAGE LOAN TRUST 2004-4
9451 Corbin A venue
Northridge, CA 91324
IN THE COURT OF COMMON PLEAS
Of Cumberland County
vs.
No. 06-1084
BRENDA A. BOWES
MICHAEL L. BOWES
166 Oakville Road
Shippensburg, P A 17257
CERTIFICATE OF SERVICE
David B. Fein, Esq., does hereby certify that true and correct copies of the foregoing Motion for
Substituted Service have been served upon the Defendants this 13th day of April 2006, by first class mail,
postage prepaid.
IJJJF
BY: David B. Fein, Esq.
I"
..
DEUTSCHE BANK NATIONAL TRUST : IN THE COURT OF COMMON PLEAS OF
COMPANY, AS TRUSTEE FOR : CUMBERLAND COUNTY, PENNSYLVANIA
LONG BEACH MORTGAGE LOAN TRUST 2004-4
PLAINTIFF
V.
BRENDA A. BOWES and
MICHAEL L. BOWES
DEFENDANTS
: 06-1084 CIVIL
ORDER OF COURT
AND NOW, this 151 day of May, 2006, upon consideration of the Plaintiff's Motion
for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that
Plaintiff's good faith efforts to ascertain the present whereabouts of Defendants have
been unsuccessful, Plaintiff's Motion is GRANTED.
IT IS HEREBY ORDERED AND DIRECTED:
1. That the Sheriff and/or Plaintiff is directed to serve the Complaint in Mortgage
Foreclosure upon Defendants by posting a copy of the Complaint upon the premises,
166 Oakville Road, Shippensburg, PA 17257;
2. That the Plaintiff serve the Complaint by certified and regular mail to the
Defendants' last known addresses at 166 Oakville Road, Shippensburg, PA 17257 and
P. O. Box 1573, Mango, FL 33550.
3. That the Plaintiff effect service by publication to include the notice prescribed
in Pa.R.C.P. 430, in a legal journal and newspaper of general circulation in Cumberland
County, Pennsylvania;
4. All future service of legal papers, including but not limited to motions, petitions
and rules be made by certified and regular mail to Defendants' last known addresses.
By the Court,
~o\.p
rft;
\~
J.
M. L. Ebert, Jr.,
"I
o ~1 :2 t'ld 1- J. SDGZ
~"",,"
,.
(.
David B. Fein, Esquire
Attorney for Plaintiff
Cumberland County Sheriff's Office
Brenda A. Bowes
Michael L. Bowes
Defendants
.
-~c.u~ sJ'J17~
v1d a BAS
GOLDBECK McCAFFERTY & McKEEVER
By: JOSEPH A. GOLDBECK. JR.
ATIORNEY LD. #16132
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPIllA, PA 19106-1532
(215) 627-1322
A TIORNEY FOR PLAINTIFF
DEUTSCHE BANK NATlONAL TRUST
COMPANY, AS TRUSTEE FOR LONG
BEACH MORTGAGE LOAN TRUST 2004-4
9451 Corbin Avenue
Northridge, CA 91324
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTlON - LAW
Plaintiff
ACTION OF MORTGAGE FORECLOSURE
vs.
BRENDA A. BOWES
MICHAEL L. BOWES
166 Oakville Road
Shippensburg, PA 17257
Term
No. 06-1084
Defendant(s)
PRAECIPE TO REINSTATE COMPLAINT
Kindly reinstate the Complaint in the above captioned matter.
GOLDBECK, McCAFFERTY & McKEEVER
~a~
By Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
-vi ..... ~
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2006-01084 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
BOWES BRENDA A ET AL
R. Thomas Kline
,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
BOWES BRENDA A
but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
, NOT FOUND , as to
the within named DEFENDANT
, BOWES BRENDA A
166 OAKVILLE ROAD
SHIPPENSBURG, PA 17257
166 OAKVILLE RD IS VACANT. DEFENDANT'S NEW
ADDRESS IS PO BOX 1573 MANGO, FL 33550.
Sheriff's Costs:
Docketing
Service
Not Found
Surcharge
18.00
17,60
5.00
10,00
.00
50.60
~
R. Thomas Kl e
Sheriff of Cumberland County
GOLDBECK MCCAFFERTY MCKEEVER
03/07/2006
Sworn and subscribed to before me
this
:Uv
day of ~
~~
t '
pr6tho r
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2006-01084 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
BOWES BRENDA A ET AL
R. Thomas Kline
,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
BOWES MICHAEL L
but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
, NOT FOUND , as to
the within named DEFENDANT
, BOWES MICHAEL L
166 OAKVILLE ROAD
SHIPPENSBURG, PA 17257
166 OAKVILLE ROAD IS VACANT. DEFENDANT'S NEW
ADDRESS IS PO BOX 1573 MANGO, FL 33550.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00
.00
5.00
10.00
.00
21.00
so~a.nswers',. ...- ~~~?
- ~~~:-:-:-
~' .--' ~;;:>~.::::-~----
R. Thomas Kline
Sheriff of Cumberland County
GOLDBECK MCCAFFERTY MCKEEVER
03/07/2006
Sworn and subscribed to before me
this
JIAk
day of ~
~~~ A~
14'
Pl?6t ~
r-""--
GOLDBECK McCAFFERTY & McKEEVER
By: JOSEPH A. GOLDBECK, JR.
AnORNEYIoD. #16132
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106-1532
(215) 627-1322
AnORNEY FOR PLAINTIFF
DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR LONG BEACH MORTGAGE
LOAN TRUST 2004-4
9451 Corbin Avenue
Northridge, CA 91324
IN THE COURT OF COMMON
PLEAS
OF Cumberland COUNTY
CIVIL ACTION - LAW
vs.
BRENDA A. BOWES and MICHAEL L. BOWES
Mortgagor(s)
166 Oakville Road
Shippensburg, P A 17257
ACTION OF MORTGAGE
FORECLOSURE
Term
No. 06-1084
Defendant(s)
CERTIFICATE OF SERVICE
JOSEPH A. GOLDBECK, JR. ESQUIRE hereby certifies that on
~/J( It~~
I
he did serve upon Defendant(s) BRENDA A. BOWES and MICHAEL L. BOWES a true and correct
copy of the above-captioned Complaint by certified and regular mail in accordance with the Court Order
dated May 1, 2006. The undersigned understands that the statements herein and subject to the penalties
provided by 18 P.S. Section 4904.
Respectfully submitted,
~a~
OLD CK McCAFFERTY & McKEEVER
BY: JOSEPH A. GOLDBECK, JR. ESQUIRE
o
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SHERIFF'S RETURN - REGULAR
..
CASE NO: 2006-01084 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
BOWES BRENDA A ET AL
MICHAEL BARRICK
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
BOWES BRENDA A
the
DEFENDANT
, at 1929:00 HOURS, on the 9th day of May
, 2006
at 166 OAKVILLE ROAD
SHIPPENSBURG, PA 17257
by handing to
POSTED PROPERTY AT
166 OAKVILLE RD SHIPPENSBURG
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
14.08
6.00
10.00
.00
48.08
,r~~
R. Thomas Kline
...
h' J' ~
me t 1.S IL
day of
05/10/2006
GOLDBECK MCCAFFERTY MCKEEVER
BY'~~ ~
Deputy~riff
Sworn and Subscribed to before
A.D.
.-.
SHERIFF'S RETURN - REGULAR
..
CASE NO: 2006-01084 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
BOWES BRENDA A ET AL
MICHAEL BARRICK
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
BOWES MICHAEL L
the
DEFENDANT
, at 1929:00 HOURS, on the 9th day of May
, 2006
at 166 OAKVILLE ROAD
SHIPPENSBURG, PA 17257
by handing to
POSTED PROPERTY AT
166 OAKVILLE RD SHIPPENSBURG
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Posting
Surcharge
So Answers:
6.00
.00
6.00
10.00
.00
22.00
~. ,,/ /// //.
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..- ""::"'.A-~~,....,;:'ii(~. ,,/_e~~
, ~ "/ ~
R. Thomas Kline
me this
..,
Ii. -
day of
05/10/2006
GOLDBECK MCCAFFERTY MCKEEVER
BY:~ ~
.~
C Deputy Sfi'eriff
Sworn and Subscribed to before
~~
( Pr ot y
A.D.
In the Court of Common Pleas of Cumberland County
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST
2004-4
9451 Corbin A venue
Northridge, CA 91324
Plaintiff
vs.
BRENDA A BOWES
MICHAEL L BOWES
(Mortgagor(s) and Record Owner(s))
166 Oakville Road
Shippensburg, P A 17257
No. 06-1084
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 Judgment in favor ofPlaintHTand against BRENDA A BOWES and MICHAEL L BOWES by default for
want of an Answer.
Assess damages as follows:
Debt
$105,434.40
Interest - 07/01/2005 to 06/20/2006
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.
---
AND NOW .J~. U , '-oo(f, , Judgment is entered in favor of
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST
2004-4 and against BRENDA A BOWES and MICHAEL L BOWES by default for want of an Answer and damages
assessed in the sum of $ I 05,434.40 as per the above certificatiolL C eu-, . ~
~~~7
e party against whom judgment
en days prior to the date of the
I certify that written notice of the intention to file this praecipe was mailed or deliver
is to be entered and to his attorney of record, if any, after the default occurred and at I
filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney 1.0. #16132
Suite 5000 - Mellon Independence Center
70 I Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR LONG BEACH MORTGAGE
LOAN TRUST 2004-4
9451 Corbin Avenue
Northridge, CA 91324
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
vs.
CIVIL ACTION LAW
BRENDA A BOWES
MICHAEL L BOWES
(Mortgagor(s) and Record owner(s))
166 Oakville Road
Shippensburg, PAl 7257
ACTION OF MORTGAGE FORECLOSURE
No. 06-1084
Defendant(s)
ORDER FOR JUDGMENT
Please enter Judgment in favor of DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2004-4, an ainst BRENDA A BOWES and
MICHAEL L BOWES for failure to file an Answer in the above action wi in 20) days (or sixty (60) days if
defendant is the United States of America) from the date of service of the 0 aint, in the sum of$105,434.40.
I hereby certify that the above names are correct and that the precis
creditor is DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TR
MORTGAGE LOAN TRUST 2004-49451 Corbin Avenue Northridge,
known addressees) of the Defendant(s) is/are BRENDA A BOWES, P B
MICHAEL L BOWES, P.O Box 1573 Mango, FL 33550;
resi nee address of the judgment
E FOR LONG BEACH
1324 and that the name(s) and last
1573 Mango, FL 33550 and
GOLDBE
BY: Joseph
Attorney for
ASSESSMENT OF DAMAGES
. '
TO THE PROTHONOTARY:
Kindly assess the damages in this case to be as follows:
Principal Balance
$95,000.23
Interest from 07/01/2005 through
06/20/2006
$5,914.30
Reasonable Attorney's Fee
$4,750.01
Late Charges
$432.36
Costs of Suit and Title Search
$900.00
Fees
Escrow
$101.50
-$1,664.00
AND NOW, this
2kJ
~
day of J ~ ' 2006 damages are assessed as above.
, "
GOLDBECK McCAFFERTY & McKEEVER
By: JOSEPH A. GOLDBECK, JR.
ATTORNEY I.D. #16132
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PIULADELPHIA, PA 19106.1532
(215) 627-1322
ArrORNEY FOR PLAINTIFF
DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR LONG BEACH MORTGAGE
LOAN TRUST 2004-4
9451 Corbin Avenue
Northridge, CA 91324
IN THE COURT OF COMMON
PLEAS
OF Cumberland COUNTY
CIVIL ACTION - LAW
vs.
BRENDA A. BOWES and MICHAEL L. BOWES
Mortgagor(s)
166 Oakville Road
Shippensburg, PA 17257
ACTION OF MORTGAGE
FORECLOSURE
Term
No. 06-1084
Defendant(s)
CERTIFICATE OF SERVICE
JOSEPH A. GOLDBECK, JR. ESQUIRE hereby certifies that on ?/lrCl("
he did serve upon Defendant(s) BRENDA A. BOWES and MICHAEL L. BOWES a true and correct
copy of the above-captioned Complaint by certified and regular mail in accordance with the Court Order
dated May I, 2006. The undersigned understands that the statements herein and subject to the penalties
provided by 18 P.S. Section 4904.
Respectfully submitted,
~.a~
OLD CK McCAFFERTY & McKEEVER
BY: JOSEPH A. GOLDBECK, JR. ESQUIRE
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PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No, 587, approved May 16,1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
Viz
May 12, 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
12;d~
Not ~
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAl
HENRY f. COYNE, NOTARY PU8UC
HAMPOEN TWP., CUM8ERlJ.ND COUNlY
MY COMMISSlON EXPIRES JUNE 17, 2008
'.
CUMBERLAND LAW JOURNAL
NOTICE
In the Court of Common Pleas
Cumberland County
Clvll Action-Law
Term No. 06-1084
DEUTSCHE BANK NATIONAL
TRUsr COMPANY, AS TRUSTEE
FOR LONG BEACH MORTGAGE
LOAN TRUsr 2004-4
Plaintiff
vs.
BRENDA A. BOWES &
MICHAEL L. BOWES
Mortgagor and Real Owner
Defendant
ACTION OF MORTGAGE
FORECLOSURE
NCYfICE OF ACTION IN
MORTGAGE FORECLOSURE
BRENDA A. BOWES & MICHAEL
L. BOWES, MORTGAGORS AND
REAL OWNERS, DEFENDANTS
whose last known address Is 166
Oakvllle Road Shippensburg, PA
17257.
TIllS FIRM IS A DEBT COlLEC-
TOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT OWED TO
OUR CUENT. ANY INFORMATION
OBTAINED FROM YOU WILL BE
USED FOR THE PURPOSE OF
COLLECTING TIlE DEBT.
You are hereby not1fled that Plain-
tiff DEUTSCHE BANK NATIONAL
TRUST COMPANY, AS TRUSTEE
FOR LONG BEACH MORTGAGE
LOAN TRUST 2004-4, has filed a
Mortgage Foreclosure Complaint
endorsed with a notice to defend
against you in the Court of Com-
mon Pleas of Cumberland Connty.
Pennsylvania. docketed to No. 06-
12
1084 wherein Plaintiff seeks to fore-
close on the mortgage secured on
your property located, 166 0akvl11e
Road, Shlppensburg, PA 17257
whereupon your property will be
sold by the Sheriff of Cumberland.
NOTICE
You have been sued in court. If
you wish to defend against the c!atms
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 attor-
ney 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 fur-
ther notice for any money claim 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 PA-
PER TO YOUR LAWYER AT ONCE.
IF YOU DO NOT HAVE A LAWYER
OR CANNOT AFFORD ONE, GO TO
OR TELEPHONE TIlE OFFICE SET
FORTII BELOW. TIflS OFflCE CAN
PROVIDE YOU WITH INFORMA-
TION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO
!fiRE A LAWYER, TIflS OFflCE MAY
BE ABLE TO PROVIDE YOU WITH
INFORMATION ABOUT AGENCIES
THAT MAY OFFER LEGAL SERV-
ICES TO ELIGIBLE PERSONS AT A
REDUCED FEE OR NO FEE.
LEGAL SERVICES INC.
40 I E. Louther St.
CarlIsle, PA 17013
(717) 243-9400
. .,
CUMBERLAND LAW JOURNAL
CUMBERLAND COUNIY
BAR ASSOCIATION
32 South Bedford St.
Carlisle, PA 17013
JOSEPH A. GOLDBECK, JR.
ESQUIRE
GOLDBECK McCAFFERlY
& McKEEVER, PC
Attorneys for Plaintiff
Suite 5000
Mellon Independence Center
70 I Market Street
Philadelphia. PA
9106-1532
May 12
13
PROOF OF PUBLICATION
State of Pennsylvania, County of Cumberland
Tammy Shoemaker, Classified Advertising Manager, of The Sentinel, of the County
and State aforesaid, being dilly sworn, deposes and says that THE SENTINEL, a
newspaper of general circulation in the Borough of Carlisle, County and State
aforesaid, was established December 13th, 1881, since which date THE SENTINEL has
been regularly issued in said County, and that the printed notice or publication
attached hereto is exactly the same as was printed and published in the regular editions
and issues of THE SENTINEL on the following day(s)
May 19, 2006
COPY OF NOTICE OF PUBLICATION
t........ ,_
;" leTA,
L~iYYtC~lNc g
"~flj>w : : l
, CIwl1Nl. 1''' 17013 !',
, <. .... ",,'., ..717:'143,1po><k
'\:'::;'..f.tfi-a.ya:..iI..::..~" 'Ie..' ,:
"',<' !"-;'~~f.wt~- " ',' ''.'''.' _:___:\.,:n~
" " CatIIoIt, .,7013' I
. <. .' i \.'. f'
Jr.: ~
, """"~
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p~, '''"1oe-l582 I
Affiant further deposes that he/she is not
interested in the subject matter of the
aforesaid notice or advertisement, and that
all allegations in the foregoing statement
as to time, place and character of
~~~
Sworn to and subscribed before me this
24th. day of May 2006.
C~Jri.1tiA(J) X UJ
Notary p~
My commission expires: 1/' /fJS
COMMONWEALTH OF PENNSYLVANIA
NoCartal SaaI
Christina L. WcIt8, ~PubIIc
CarlIsle 8010, Cumbel111hd CoonIy
My CanmIseicn E>cplres Sept. 1 , 2008
Member. Pennsylvania Assoclatlon Of Notaries
WM-0683
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.
DATE OF TIDS NOTICE: June 9, 2006
TO:
MICHAEL L BOWES
166 Oakville Road
Shippensburg, PA 17257
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST
2004-4
9451 Corbin Avenue
Northridge, CA 91324
IN THE COURT OF COMMON
PLEAS
of Cumberland County
CIVIL ACTION - LAW
Plaintiff
ACTION OF MORTGAGE
FORECLOSURE
vs.
BRENDA A BOWES
MICHAEL L BOWES
(Mortgagor(s) and Record Owner(s))
166 Oakville Road
Shippensburg, P A 17257
Term
No. 06-1084
Defendant(s}
TO: MICHAEL L BOWES
166 Oakville Road
Shippensburg, P A 17257
IMPORTANT NOTlC:R
YOU ARE IN DEFAULT BECAUSE YOU RAVE 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
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 RAVE 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
TRA T MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle,PA 17013
G EVER
B oseph A. Gtlldbeck, Jr., Esq,
Attorney for Plaintiff
Suite 5000 - Mellon Independem:e Ceuler
701 Markel Street
Philadelphia, PA 19106 215-627-1322
WM-0683
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.
DATE OF THIS NOTICE: June 9, 2006
TO:
MICHAEL L BOWES
P.O Box 1573
Mango, FL 33550
In the Court of Common Pleas
of Cumberland County
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST
2004-4
9451 Corbin Avenue
Northridge, CA 91324
CIVIL ACTION - LAW
Plaintiff
ACTION OF
MORTGAGE FORECLOSURE
vs.
BRENDA A BOWES
MICHAEL L BOWES
(Mortgagor(s) and Record Owner(s))
166 Oakville Road
Shippensburg, P A 17257
Term
No. 06-1084
Defendant(s)
TO: MICHAEL L BOWES
P.O Box 1573
Mango, FL 33550
IMPORT ANT NOTTCF.
YOU ARE IN DEF AUL T 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 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.
LEGAL SERVlCES!NC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
JOffpli)t q()f4fjpC~v> J'r
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 5000 - 701 Market Street.
Philadelphia, PA 19106 215-825-6318
WM-0683
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.
DATE OF THIS NOTICE: June 9, 2006
TO:
BRENDA A BOWES
166 Oakville Road
Shippensburg, PA 17257
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST
2004-4
9451 Corbin Avenue
Northridge, CA 91324
IN THE COURT OF COMMON
PLEAS
of Cumberland County
CIVIL ACTION - LAW
Plaintiff
ACTION OF MORTGAGE
FORECLOSURE
vs.
BRENDA A BOWES
MICHAEL L BOWES
(Mortgagor(s) and Record Owner(s))
166 Oakville Road
Shippensburg, PA 17257
Term
No. 06-1084
Defendant(s}
TO: BRENDA A BOWES
166 Oakville Road
Sbippensburg, P A 17257
TMPORTANTNOTTCR
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAlLED TO ENTER A ~TTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN ~TING WITH THE COURT YOUR DEFENSES OR OBJECTIONS
TO THE CLAlMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF
THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE
YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS 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.
LEGAL SERVICES lNC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOClA nON
2 Liberty Avenue
Carlisle, PA 17013
G E~R
B oseph A. Goldbeck, Jr.. Esq.
Attorney for Plaintiff
Suite 5000 - Melton Independence Center
701 Market Street
Pliiladelphia,PA 19106 215-627-1322
WM-0683
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.
DATE OF TIDS NOTICE: June 9, 2006
TO:
BRENDA A BOWES
P.O Box 1573
Mango, FL 33550
In the Court of Common Pleas
of Cumberland County
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST
2004.4
9451 Corbin Avenue
Northridge, CA 91324
CIVIL ACTION. LAW
Plaintiff
ACTION OF
MORTGAGE FORECLOSURE
vs.
BRENDA A BOWES
MICHAEL L BOWES
(Mortgagor(s) and Record Owner(s))
166 Oakville Road
Shippensburg, PA 17257
Term
No. 06.1084
Defendant(s)
TO: BRENDA A BOWES
P.O Box 1573
Mango, FL 33550
IMPORT ANT NOneF,
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITIEN APPEARANCE PERSONALLY
OR BY ATIORNEY 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 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 TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. TIllS 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.
LEGAL SERVICES lNC
8ltvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
Josry6 ~ '4 qO(JhfC'v. Jr
GOWBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 5000 - 701 Market Street.
Philadelphia, PA 19106 215-825.6318
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, BRENDA A BOWES, is
about unknown years of age, that Defendant's last known
residence is P.O Box 1573, Mango, FL 33550, 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 wi thin the
provisions of the Soldiers' and Sailors' Civil Relief Action of
Congress of 1940 and its Amendments.
Date:
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, MICHAEL L BOWES, is
about unknown years of age, that Defendant's last known
residence is P.O Box 1573, Mango, FL 33550, 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 wi thin the
provisions of the Soldiers' and Sailors ivil Relief Action of
Congress of 1940 and its Amendments.
Date:
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
2004-4
945 I Corbin Avenue
Northridge, CA 91324
Plaintiff
No. 06-1084
vs.
BRENDA A BOWES
MICHAEL L BOWES
(Mortgagors and Record Owner(s))
166 Oakville Road
Shippensburg, P A 17257
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 4;,r h
~'tong
Prothon
d against you.
By:
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
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
r
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 2004-4
9451 Corbin Avenue
Northridge, CA 91324
Plaintiff
vs.
BRENDA A BOWES
MICHAEL I. BOWES
Mortgagor(s) and Record Owner(s)
166 Oakville Road
Shippensburg, P A 17257
Defendant( s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 06-1084
TO THE PROTHONOTARY:
PRAECIPE FOR WRIT OF EXECUTION
Issue Writ of Execution in the above matter:
Amount Due
Interest from
07/01/2005 to
06/20/2006 at
6.4000%
(Costs to be added)
$105,434.40
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WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C,P. 3180-3183 AND Rule 3257
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR LONG BEACH
MORTGAGE LOAN TRUST 2004-4
9451 Corbin Avenue
Northridge, CA 91324
In the Court of Common Pleas of
Cumberland County
vs.
No. 06-1084
BRENDA A BOWES
MICHAEL L BOWES
166 Oakville Road
Shippensburg, P A 17257
WRIT OF EXECUTION
(MORTGAGE FORECLOSURE)
Commonwealth of Pennsylvania:
County of Cumberland
To the Sheriff of Cumberland County,.Pennsylvania
To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the
following described property:
PREMISES: 166 Oakville Road Shippensburg, PA 17257
See Exhibit "A" attached
AMOUNT DUE
$105,434.40
Interest From 07/01/2005
Through 06/20/2006
(Costs to be added)
Dated:
Deputy
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All that certain tract of land situate in North Newton Township; County of Cumberland and State of
Pennsylvania, bounded and described in accordance with a Subdivision Plan for Ronald and Alice
Negley, recorded in the Office of the Recorder of Deeds for Cumberland County, Pennsylvania, in Plan
Book 32, page 7, as follows:
Beginning at a railroad spike in the centerline of Legislative Route 21007 at corner of other land now or
formerly of Ronald P. and Alice K. Negley; thence by land now or formerly of Ronald P. and Alice K.
Negley, South 51 degrees 15 minutes West 175 feet to an iron pin; thence by the same, North 38 degrees
45 minutes West 200 feet to an iron pin; thence North 51 degrees 15 minutes East 175 feet to a railroad
spike in the center of Legislative Route 21007 aforesaid; thence by the centerline of Legislative Route
21007, South 38 degrees 45 minutes East 200 feet to a railroad spike, the place of beginning.
Being Lot No.4 of the aforesaid Subdivision Plan. Containing 35,000.00 square feet.
Being known as 166 Oakville Road, Shippensburg P A, 17527
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.<1bldbeck McCafferty & McKeever
BY: Joseph A. Goldbeck, Jr.
Attorney J.D. #16132
Suite 5000 - Mellon Independence Center
70 I Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR LONG BEACH
MORTGAGE LOAN TRUST 2004-4
9451 Corbin Avenue
Northridge, CA 91324
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
vs.
CNIL ACTION - LAW
BRENDA A BOWES
MICHAEL L BOWES
(Mortgagor(s) and Record Owner(s))
166 Oakville Road
Shippensburg, PA 17257
ACTION OF MORTGAGE FORECLOSURE
Defendant( s)
No. 06-1084
AFFIDAVIT PURSUANT TO RULE 3129
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN
TRUST 2004-4, 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 infoonation concerning the real property located at:
166 Oakville Road
Shippensburg, P A 17257
I.Name and address of Owner(s) or Reputed Owner(s):
BRENDA A BOWES
P.O Box 1573
Mango, FL 33550
MICHAEL L BOWES
P.O Box 1573
Mango, FL 33550
2. Name and address ofDefendant(s) in the judgment:
BRENDA A BOWES
P.O Box 1573
Mango, FL 33550
MICHAEL L BOWES
P.O Box 1573
Mango, FL 33550
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 - 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, Suite 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.
TENANT~OCCUPANTS
166 Oakville Road
Shippensburg, P A 17257
(attach separate sheet if more space is needed)
I verifY that the statements made in this affidavit are true and correct to b
information and belief. I understand that false statements herein are made subj ct to
relating to unsworn falsification to authorities.
t of my personal knowledge or
penalties of 18 Pa. C.S. Section 4904
GOLDBECK Me
BY: Joseph A. Go be
Attorney for Plain ff
DATED: June 20. 2006
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N006-1084 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DEUTSCH BANK NATIONAL TRUST CO. AS
TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2004-4 Plaintiff (s)
From BRENDA A. AND MICHAEL L. BOWES, POBOX 1573, MANGO FL 33550
(I) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE
LOCATED AT 166 OAKVILLE ROAD, SHIPPENSBURG PA 17257 (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) 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 $105,434.40
Interest FROM 7/1/05 TO 6/20/6 @ 6.4000%
Atty's Comm %
Atty Paid $223.58
Plaintiff Paid
Date: JUNE 26, 2006
L.L. $.50
Due Prothy $1.00
Other Costs
Prothonotary
(Seal)
By:
Deputy
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK JR., ESQ.
Address: 701 MARKET ST
STE 5000 - MELLON INDEPENDENCE CTR.
PHILADELPHIA PA 19106
Attorney for: PLAINTIFF
Telephone: (215) 627-1322
Supreme Court ill No. 16132
t
.,0
06-1084
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney 1.0.#16132
Suite 5000 - Mellon Independence Center
70 I Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR LONG BEACH
MORTGAGE LOAN TRUST 2004-4
9451 Corbin Avenue
Northridge, CA 91324
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
vs.
BRENDA A BOWES
MICHAEL L BOWES
Mortgagor(s) and Record Owner(s)
ACTION OF MORTGAGE
FORECLOSURE
166 Oakville Road
Shippensburg, PA 17257
Term
No. 06-1084
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: BOWES, BRENDA A.
BRENDA A. BOWES
166 Oakville Road
Shippensburg, PAl 7257
Your house at 166 Oakville Road, Shippensburg, PAl 7257 is scheduled to be sold at Sheriff's
Sale on Wednesday, December 06, 2006, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse
to enforce the court judgment of$105,434.40 obtained by DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2004-4 against you.
NOTICE OF OWNER'S RIGHTS
YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale you must take immediate action:
t
06-1084
."
1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2004-4, the back payments, late
charges, costs and reasonable attorney's fees due. To find out how much you must pay call:
215-627-1322
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 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 frod
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 Sheriff's 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 LA WYER 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 mc
8 Irvine Row
Carlisle, PA 17013
CUMBERLAND COUNTY BAR ASSOCIA nON
2 Liberty Avenue
Carlisle, PA 17013
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, . ,. 06-1084
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney 1.0.#16132
Suite 5000 . Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR LONG BEACH IN THE COURT OF COMMON PLEAS
MORTGAGE LOAN TRUST 2004-4
9451 Corbin Avenue of Cumberland County
Northridge, CA 91324
Plaintiff CIVIL ACTION - LAW
vs.
BRENDA A BOWES
MICHAEL L BOWES
Mortgagor(s) and Record Owner(s)
ACTION OF MORTGAGE
FORECLOSURE
166 Oakville Road
Shippensburg, PA 17257
Term
No. 06-1084
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: BOWES. MICHAEL L
MICHAEL L. BOWES
166 Oakville Road
Shippensburg, P A 17257
Your house at 166 Oakville Road, Shippensburg, P A 17257 is scheduled to be sold at Sheriff's
Sale on Wednesday, December 06,2006, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse
to enforce the court judgment of $1 05,434.40 obtained by DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2004-4 against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale you must take immediate action:
, , ,;>>
06-1084
L The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2004-4, the back payments, late
cbarges, costs and reasonable attorney's fees due. To find out how much you must pay call:
215-627-1322
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.
L If the Sheriff's 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 of7I 7-240-6390.
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 of7 17-240-6390.
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 Sheriff's 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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Joseph A. Goldbeck, Jr.
Attorney J.D. #16132
Suite 5000 - Mellon Independence Center
70 I Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS
TRUSTEE FOR LONG BEACH MORTGAGE LOAN
TRUST 2004-4
9451 Corbin Avenue
Northridge, CA 91324
IN THE COURT OF
COMMON PLEAS
Plaintiff
vs.
of Cumberland County
BRENDA A BOWES
MICHAEL L BOWES
Mortgagor(s) and Record Owner(s)
166 Oakville Road
Shippensburg, PA 17257
CNIL ACTION - LAW
ACTION OF
MORTGAGE FORECLOSURE
Defendant( s)
NO. 06-1084
CERTIFICATION AS TO THE SALE OF REAL PROPERTY
I, Joseph A. Goldbeck, Jr., Esquire hereby certify that I am the attorney of re ord for the Plaintiff in this
action, and I further certify that this property is subject to Act 91 of 1983 an e tiff has complied with all
the provisions of the Act.
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SHORT DESCRIPTION
IMPROVEMENTS consist of a residential dwelling.
BEING PREMISES: 166 Oakville Road
Shippensburg, PA 17257
SOLD as the property of BRENDA A BOWES and MICHAEL L BOWES
TAX PARCEL #30-10-616-20
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney J.D. #16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, P A 19106
215-825-6312
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR LONG
BEACH MORTGAGE LOAN TRUST 2004-4
9451 Corbin Avenue
Northridge, CA 91324
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
vs.
No. 06-1084
BRENDA A BOWES
MICHAEL L BOWES
(Mortgagor(s) and Record owner(s))
166 Oakville Road
Shippensburg, P A 17257
PRAECIPE TO SATISFY JUDGMENT
TO THE PROTHONOTARY:
Kindly Satisfy the Judgment in the above captioned matter upon payment of your costs
only.
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JOSEPH A. GOLDBECK, JR., ESQUIRE
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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
215-825-6321
Attorney for Plaintiff
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR LONG
BEACH MORTGAGE LOAN TRUST 2004-4
9451 Corbin Avenue
Northridge, CA 91324
IN THE COURT OF COMMON
PLEAS
of Cumberland County
Plaintiff
vs.
BRENDA A BOWES
MICHAEL L BOWES
(Mortgagor(s) and Record owner(s))
166 Oakville Road
Shippensburg, P A 17257
No. 06-1084
PRAECIPE TO SETTLE. DISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly mark the above case Settled, Discontinued and Ended upon payment of your costs
only.
{j?It~-
JOSEPH A. GOLDBECK, JR., ESQUIRE
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Deutsche Bank National Trust Company
As Trustee for Long Beach Mortgage
Loan Trust 2004-4
VS
Brenda A. Bowes and Michael L. Bowes
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2006-1084 Civil Term
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
Levy
Mileage
Posting
Share of Bills
Surcharge
30.00
1,900.00
15.00
15.00
13.20
6.00
15.94
30.00
$2,025.14 ~~
So Answers:
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R. Thomas Kline, Sheriff
$1.50 quO
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Goldbeck McCafferty & McKeever
BY: Joseph A. Goldbeck, Jr.
Attorney J.D. #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 2004-4
9451 Corbin Avenue
Northridge, CA 91324
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
vs.
CIVIL ACTION - LAW
BRENDA A BOWES
MICHAEL L BOWES
(Mortgagor(s) and Record Owner(s))
166 Oakville Road
Shippensburg, P A 17257
ACTION OF MORTGAGE FORECLOSURE
Defendant(s)
No. 06-1084
AFFIDAVIT PURSUANT TO RULE 3129
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN
TRUST 2004-4, 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:
166 Oakville Road
Shippensburg, P A 17257
l.Name and address ofOwner(s) or Reputed Owner(s):
BRENDA A BOWES
P.O Box 1573
Mango, FL 33550
MICHAEL L BOWES
P.O Box 1573
Mango, FL 33550
2. Name and address ofDefendant(s) in the judgment:
BRENDA A BOWES
P.O Box 1573
Mango, FL 33550
MICHAEL L BOWES
P.O Box 1573
Mango, FL 33550
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
P A 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, Suite 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
166 Oakville Road
Shippensburg, P A 17257
(attach separate sheet ifmore space is needed)
I verify that the statements made in this affidavit are true and correct to b t of my personal knowledge or
information and belief. I understand that false statements herein are made subj ct to penalties of 18 Pa. C.S, Section 4904
relating to unsworn falsification to authorities.
DATED: June 20, 2006
,
06-1084
,
...
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney LD.#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 2004-4
9451 Corbin Avenue
Northridge, CA 91324
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
vs.
BRENDA A BOWES
MICHAEL L BOWES
Mortgagor(s) and Record Owner(s)
ACTION OF MORTGAGE
FORECLOSURE
166 Oakville Road
Shippensburg, P A 17257
Term
No. 06-1084
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: BOWES, MICHAEL L.
MICHAEL L BOWES
P.O Box 1573
Mango, FL 33550
Your house at 166 Oakville Road, Shippensburg, P A 17257 is scheduled to be sold at Sheriffs
Sale on Wednesday, December 06, 2006, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse
to enforce the court judgment of $1 05,434.40 obtained by DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2004-4 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:
.
06-1084
.
1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2004-4, the back payments, late
charges, costs and reasonable attorney's fees due. To find out how much you must pay call:
215-627-1322
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 Sheriff's 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 71 7-240-6390.
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 fmd
out if this has happened, you may call the Sheriff of 7 17-240-6390.
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, PA 17013
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, P A 17013
J
~
06-1084
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#I6132
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 2004-4
9451 Corbin Avenue
Northridge, CA 91324
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
vs.
BRENDA A BOWES
MICHAEL L BOWES
Mortgagor(s) and Record Owner(s)
ACTION OF MORTGAGE
FORECLOSURE
166 Oakville Road
Shippensburg, P A 17257
Term
No. 06-1084
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: BOWES, BRENDA A.
BRENDA A BOWES
P.O Box 1573
Mango, FL 33550
Your house at 166 Oakville Road, Shippensburg, P A 17257 is scheduled to be sold at Sheriffs
Sale on Wednesday, December 06, 2006, at 10:00 AM, in Commissioners Hearing Rrn 2nd FL Courthouse
to enforce the court judgment of $1 05,434.40 obtained by DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2004-4 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
t
06-1084
1. The sale will be cancelled if you pay to DEUTSCHE BANK NATIONAL TRUST COMPANY,
AS TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2004-4, the back payments, late
charges, costs and reasonable attorney's fees due. To fmd out how much you must pay call:
215-627-1322
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 Sheriff's 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 fmd
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 LA WYER 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, P A 17013
All that certain tract of land situate in North Newton Township; County of Cumberland and State of
Pennsylvania, bounded and described in accordance with a Subdivision Plan for Ronald and Alice
Negley, recorded in the Office of the Recorder of Deeds for Cumberland County, Pennsylvania, in Plan
Book 32, page 7, as follows:
Beginning at a railroad spike in the centerline of Legislative Route 21007 at corner of other land now or
formerly of Ronald P. and Alice K. Negley; thence by land now or formerly of Ronald P. and Alice K.
Negley, South 51 degrees 15 minutes West 175 feet to an iron pin; thence by the same, North 38 degrees
45 minutes West 200 feet to an iron pin; thence North 51 degrees 15 minutes East 175 feet to a railroad
spike in the center of Legislative Route 21007 aforesaid; thence by the centerline of Legislative Route
21007, South 38 degrees 45 minutes East 200 feet to a railroad spike, the place of beginning.
Being Lot No.4 of the aforesaid Subdivision Plan. Containing 35,000.00 square feet.
Being known as 166 Oakville Road, Shippensburg P A, 17527
WRIT OF EXECU.TION and/~ATTACHMENT
, .
COMMONWEALTH OF PENNSYL VANIA)
COUNTY OF CUMBERLAND)
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DEUTSCH BANK NATIONAL TRUST CO. AS
TRUSTEE FOR LONG BEACH MORTGAGE LOAN TRUST 2004-4 Plaintiff (s)
From BRENDA A. AND MICHAEL L. BOWES, POBOX 1573, MANGO FL 33550
N006-1084 Civil
CIVIL ACTION - LAW
(1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE
LOCATED AT 166 OAKVILLE ROAD, SHIPPENSBURG PA 17257 (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 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 him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $105,434.40
Interest FROM 7/1/05 TO 6/20/6 @ 6.4000%
Arty's Comm %
Arty Paid $223.58
Plaintiff Paid
Date: JUNE 26, 2006
L.L. $.50
Due Prothy $1.00
Other Costs
(Seal)
Prothonotary
By:
Deputy
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK JR., ESQ.
Address: 701 MARKET ST
STE 5000 - MELLON INDEPENDENCE CTR.
PHILADELPIDA PA 19106
Attorney for: PLAINTIFF
Telephone: (215) 627-1322
Supreme Court ID No. 16132
Real Estate Sale # 61
On September 11, 2006 the Sheriff levied upon the
defendant's interest in the real property situated in
North Newton Township, Cumberland County, PA
Known and numbered as 166 Oakville Road,
Shippensburg, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
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By: ~~
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Real ~state Sergeant
Date: September 11,2006
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